Privacy Policy

​Our Privacy Policy:

Millennium CreditRisk Management Limited (Millennium) has been in the insurance business since 1994 and has long practiced confidentiality in the handling of all personal information it has collected from its clients. Millennium only uses the information it is given to provide the services for which it has been retained. These services include:

  • providing credit and political risk insurance products for our clients and brokers. 

This Privacy Policy is based on the Canadian Standards Association Model Code for the Protection of Personal Information, and the Federal Personal Information Protection and Electronic Documents Act (“PIPEDA”). Within this policy, we Millennium will address how the staff, Officers and Directors of Millennium intend to collect, use, and disclose Personal Information in the context of these principles. This policy reflects Millennium’s commitment to the privacy of our clients’ Personal Information. Millennium ‘s collection, use and disclosure of its staff’s Personal Information is dealt with in a separate policy.

Millennium may disclose Personal Information to any individual or organization for services that are provided to assist it in the conduct of its mandate, including an individual or organization that performs services on its behalf, but only if that individual or organization agrees to use the Personal Information solely for the purposes of performing tasks on behalf of, and under the instruction of, Millennium and, with respect to that information, to act in a manner consistent with the relevant principles articulated in this Privacy Policy.

In order to be certain you are aware of the scope of the information to which our Privacy Policy refers, please note the following definition (as defined in PIPEDA):

Personal Information: Means information about an identifiable individual, but does not include the name, title or business address or telephone number of an employee of an organization. Personal Information includes personal health information with respect to an individual, whether living or deceased, and means (a) information concerning the physical or mental health of the individual; (b) information concerning any health services provided to the individual; (c) information concerning the donation by the individual of any body part or any bodily substance of the individual or information derived from the testing or examination of a body part or bodily substance of the individual; (d) information that is collected in the course of providing health services to the individual; or (e) information that is collected incidentally to the provision of health services to the individual.

Personal Information for the purpose of this policy, shall not include information disclosed as aggregate data. Aggregate data for the purpose of this policy, refers to data that does not reveal, and cannot be manipulated to reveal, member-specific information.


1. Accountability

The Personal Information Millennium collects, or is provided, is used and disclosed for the purposes of conducting the services it provides. As part of the employment process, Millennium's staff, Directors and Officers will sign a confidentiality agreement which outlines Millennium's expectation of its employees to act responsibly in the handling of client information.

  • Millennium’s management has developed and adopted this Privacy Policy and is refining its Security and Records Retention policies.
  • Millennium has assigned a Privacy Officer(s) to provide client service on matters of privacy relating to Millennium’s use, disclosure, security and retention of personal or personal health information. Millennium’s Privacy Officer(s) will also be responsible for maintaining this policy and updating staff on changes to both privacy legislation and business practices.
  • Millennium has held an awareness seminar for key members of staff on privacy legislation and will continue to update all staff on privacy related issues and legislation.
  • property/casualty insurance applications, premium collection and claim payment
  • individual claim assessments, legal processes and claim payment

Millennium collects personal information in the course of providing services to our clients. The following is an example of circumstances in which Millennium may be provided, or required to collect, personal information:

2. Identify the purpose

Millennium collects personal information in the course of providing services to our clients. The following is an example of circumstances in which Millennium may be provided, or required to collect, personal information:

3. Obtain consent

Consent to use personal information is required to be obtained at the time of its collection. If Millennium collects personal information directly from an individual, Millennium will obtain express consent for the collection, use and disclosure of such information. However, Millennium may receive personal information collected by other parties. Where possible in these circumstances, Millennium will take reasonable measures to require that consent for its use of the personal information has been obtained.

If Millennium uses personal information it has collected, or has been provided, for any reasons other than those disclosed to an individual at the time consent was given, then Millennium will seek to obtain consent for the new use of the information.

4. Limit collection

Millennium limits its collection of personal information to that which is reasonably required to accurately complete the services for which it has been retained. It is committed to respecting the privacy of an individual’s personal information and will not collect personal information which is not reasonably required.

5. Limit use, disclosure and retention

Millennium limits its use and disclosure of personal information to the purpose(s) described at the time the information is collected. Millennium retains personal information it collects only as long as is necessary to completely fulfill our services. Millennium maintains a records retention policy. The retention policy has been developed to meet Millennium record retention requirements consistent with good business practices and known industry standards.

In the event that Millennium decides to purchase, sell, reorganize or transfer the assets of a business, including any Personal Information held by that business, Millennium’s client information may be subject to review for such purpose by another party. Should Millennium or such other party wish to use any Personal Information for purposes not described herein, then consent for such use of the information will first be obtained.

Note: As is the case with all companies, Millennium may be lawfully bound to disclose personal information for purposes other than those described at the time consent was obtained. These purposes have been described in applicable privacy legislation as those designed to protect personal and/or public interest.

6. Be accurate

Millennium recognizes that personal information can change and encourages its clients to keep their personal information current so that Millennium may provide the best services possible. Within a reasonable time of being notified, Millennium will update records to reflect changes in personal information. 

7. Use appropriate safeguards

Millennium has inventoried the various ways in which it stores personal information, and has taken reasonable measures to ensure the security of this information within its premises, at offsite storage locations and in its system databases. 

Furthermore, Millennium will require its staff to sign a confidentiality agreement within which is detailed it’s expectation that staff will respect and safeguard client information. Through this agreement, employees are aware that a breech of confidentiality could result in termination of their employment.

8. Be Open

Millennium’s Privacy Officer is mandated to ensure that its Privacy Policy and internal Security and Record Retention Policies are maintained. 

Should you wish to question why specific information is required, our Privacy Officer is available to answer any such inquiries.
In all matters of privacy, including access requests and privacy concerns, we encourage our clients to contact our Privacy Officer:

David Black
Principal Broker
705 Fountain Street North, PO Box 1510
Cambridge, Ontario
N1R 5T2
Phone:1-800-763-3499 Ext. 307 Fax:1-877-368-4606

9. Give individual access

It is extremely important for clients to know that they have access to their personal information. Requests for personal information held by Millennium, or corrections to such information, can be made by contacting the sponsoring employer, or, in the case of direct client relationships, personal information can be requested or corrected by contacting the Privacy Officer(s) by e-mail, phone or fax. In response to such requests, Millennium will correct or provide that personal information which can be corrected or retrieved at a reasonable cost to Millennium or the sponsoring employer, and will do so in a timely manner. In order to guard against fraudulent requests for access, Millennium will require sufficient information to allow it to confirm the identity of the person making the request before granting access or making corrections. 

Note: As is the case with all companies, Millennium may be lawfully bound to deny access of an individual to their personal information. Reasons for such a denial have been described in applicable privacy legislation as those designed to protect personal and/or public interest.

10. Provide recourse

Millennium will review any and all concerns over privacy matters that are submitted to Millennium. Privacy concerns are managed by its Privacy Officer(s), who provide both a response to the concern as well as contact information for regulatory authorities. Millennium ‘s Privacy Officer(s) will use any concerns to assist in measuring the effectiveness of its Privacy Policy, as well as business practices. Amendments to the Privacy Policy will be described on Millennium ‘s website, along side the updated policy. Whether or not Personal Information already collected and used at Millennium will be affected by any such amendments, will also be discussed on the website along side the notice of the change.