SUTTON SPECIAL RISK INC.
TORONTO, OC

As a Managing General Underwriter and Third Party Administrator since 1978, Sutton Special Risk has always focused on delivering flexible and affordable insurance solutions for our clients. Our attention to service means we respond quickly and effectively. To provide our clients with exceptional security and global reach, Sutton underwrites business on behalf of several ‘A’ rated carriers. Our carrier partners share our appetite for risk and our willingness to customize plans to suit our clients’ needs. Our partnerships allow us to offer industry-leading high sums insured and broad coverage, including special hazards. This document sets out the obligations of Sutton Special Risk Inc. ("the Company") with regard to data protection and the rights of people with whom it works in respect of their personal data. In order to provide our products and services, the Company is required to collect sensitive and confidential personal information from our clients. We are committed to protecting the privacy and the confidentiality of such personal information. The following Privacy Guidelines have been developed in accordance with the Personal Information Protection and Electronic Documents Act (PIPEDA), HIPAA, and Lloyd’s. Personal Information does not include the name, title, business address or telephone number of an employee or an organization. Sutton Special Risk is responsible for the personal information in its control, including information that may be transferred to a third party service provider performing services for, or on its behalf. Personal information will not be used, disclosed or retained for purposes other than those for which the information was collected, except with the permission of the individual, or as permitted or required by law. • an account of personal information made available to third party service providers. An individual may request to be informed of the existence, use and disclosure of personal information pertaining to him or her. Appropriate access will be provided to such information held. Sutton Special Risk may choose to make personal medical information available only through a physician designated by the individual. In certain situations as permitted by law, access to all personal information held with respect to an individual may not be possible. Exceptions to the access requirement will be limited and specific, and the reasons for denying access will be provided to the individual. The Company shall ensure that all of its employees, contractors, agents, consultants, partners or other parties working on behalf of the Company comply with the following when processing and / or transmitting personal data: •Personal data may be transmitted over secure networks only – transmission over unsecured networks is not permitted in any circumstances; •Where Personal data is to be sent by facsimile transmission the recipient should be informed in advance of the transmission and should be waiting by the fax machine to receive the data; The Company shall ensure that the following measures are taken with respect to the collection, holding and processing of personal data: •All employees, contractors, agents, consultants, partners or other parties working on behalf of the company are made fully aware of both their individual responsibilities and the Company’s responsibilities under PIPEDA, HIPAA, and Lloyd’s. •All employees, contractors, agents, consultants, partners or other parties working on behalf of the Company handling personal data will be appropriately trained to do so. •All employees, contractors, agents, consultants, partners or other parties working on behalf of the Company handling personal data will be bound to do so in accordance with the principles of PIPEDA, HIPAA, Lloyd’s and this Policy by contract. Failure by any employee to comply with the principles or this Policy shall constitute a disciplinary offence. Failure by any contractor, agent, consultant, partner or other party to comply with the principles or this Policy shall constitute a breach of contract. In all cases, failure to comply with the principles or this Policy may also constitute a criminal offence. •All contractors, agents, consultants, partners or other parties working on behalf of the Company handling personal data must ensure that any and all of their employees who are involved in the processing of personal data are held to the same conditions as those relevant employees of the Company arising out of this Policy and PIPEDA. •Where any contractor, agent, consultant, partner or other party working on behalf of the Company handling personal data fails in their obligations under this Policy that party shall indemnify and hold harmless the Company against any costs, liability, damages, loss, claims or proceedings which may arise out of that failure. Welcome to Sutton Special Risk Canada Sutton Special Risk is a premier provider of specialized insurance products including Personal Accident, Critical Illness, Life, Kidnap & Ransom, Professional Sports, War & Terrorism risk, and Contingency products like event cancellation and non-appearance. Our clients include employer & affinity groups, expatriates, business travelers, executives & business owners, entertainment professionals and of course, professional and amateur athletes and associations.