PRIVACY GUIDELINES

Personal information is any information relating to an identified or identifiable individual. It includes-but is not limited to-health and financial information.

We only collect personal information that is relevant to the conduct of our business.

We only use lawful means to collect personal information.

We will inform clients why we are collecting personal information from them either before or at the time we collect it. We will not use the information for another purpose without consent.

When it is appropriate, we will collect personal information directly from clients and, when appropriate, either notify them or obtain consent before collecting personal information from other sources. This does not apply to personal information we obtain from an employer or other sponsor of a group policy or plan in order to underwrite, administer, or adjudicate claims for the group policy or plan. We retain the right to investigate contentious matters as necessary within legal bounds.


COLLECTION OF PERSONAL INFORMATION

TK Financial Group’s Guiding Principles require the highest standards of integrity in all we do. One way we live up to this commitment is by ensuring the privacy and confidentiality of personal information we receive from clients, staff, providers and the community at large. We recognize and respect every individual's right to privacy. We also recognize our obligation to preserve the confidentiality of personal information, and have adopted these Privacy Guidelines for our use in the collection, use and disclosure of personal information.

USE AND DISCLOSURE OF PERSONAL INFORMATION

We do not disclose personal information to a third party-or use it for any purpose other than that for which we collected it-without consent, unless such disclosure or use is:
required by law reasonably necessary to determine eligibility or entitlement for an insurance benefit or to protect TK Financial Group’s interests against criminal activity, fraud or material misrepresentation in connection with an insurance contract, or
in the discharge of a public duty.

ACCESS TO PERSONAL INFORMATION

We limit access to personal information to the employees or agents of TK Financial Group who need it for use or disclosure in accordance with these Privacy Guidelines.
If you want to request personal information we have retained in our records, write to us and identify yourself appropriately. We will respond within 60 days, and advise you of any personal information about you that we have retained in our records, subject to legal and ethical considerations.

If we decide not to disclose personal information to you, we will provide written reasons for our decision. If you disagree with our decision, you may appeal in writing to our Personal Information Officer.

ACCURACY OF PERSONAL INFORMATION

We make every reasonable effort to ensure that all personal information we collect is as accurate and complete as possible.

If we find that personal information we have retained is incorrect, we will correct it or help to get it corrected within 60 days. You may request-in writing-that we clarify or correct personal information we have on file. We will respond to your request within 60 days. If we refuse your request, we will provide you with our reasons in writing. If you disagree, you may appeal in writing to our Personal Information Officer.

SECURITY OF PERSONAL INFORMATION COMPLIANCE WITH OUR PRIVACY GUIDELINES

We have established and will continue to maintain appropriate safeguards to protect the security and confidentiality of personal information.

We provide a copy of TK Financial Group's Privacy Guidelines to our employees, agents, clients, plan sponsors, providers and other persons or organizations who receive personal information and act for or on behalf of TK Financial Group. They are required to comply with our Privacy Guidelines.

COMPLIANCE WITH OUR PRIVACY GUIDELINES

We have appointed a Personal Information Officer to administer requests for access to, or clarification or correction of, personal information. TK Financial Group's Personal Information Officer will investigate any complaints about privacy or confidentiality, and will respond in writing within 60 days of receiving a written request or complaint.
The Personal Information Officer reports at least annually to TK Financial Group's senior management, on all complaints related to these Privacy Guidelines.

QUESTIONS

If you have any questions, concerns or complaints about privacy or confidentiality at TK Financial Group-or if you would like to obtain an additional copy of our Privacy Guidelines-please write to:

Personal Information Officer

TK Financial Group

100-880 Lady Ellen Place

Ottawa, Ontario K1Z 5L9