Stewart Title Guaranty Company is a leading provider of title insurance to homeowners, commercial property owners and mortgage lenders. We have a long standing commitment to protecting the Personal Information of our customers and our employees. We consider Personal information to include information about an identifiable individual, but does not include the name, title, business address or telephone number of an employee of an organization. Our privacy policy is set out below:

1.0    Accountability

1.1    We are responsible for all Personal Information under our control.

1.2    While many employees within Stewart Title have responsibility for the day-to-day collection and processing of Personal Information and all are required to comply with the Privacy Policy, our Privacy Office is responsible to ensure compliance with the Privacy Policy.

1.3    We remain responsible for Personal Information which has been transferred to a third party for processing. Where Personal Information is transferred to a third party service provider for processing, contractual safeguards are imposed to protect the Personal Information.

2.0    Identifying Purposes

2.1    When we collect Personal Information, we will identify the purpose for which the Personal Information is required in a way that an individual can reasonably understand how that information will be used or disclosed.

2.2    We will only collect, use and disclose Personal Information from our customers and employees for the following business reasons:

(a)    to determine which of our products and related services meet the needs of individual customers;

(b)    to process applications for insurance and assess risk;

(c)    to investigate and adjudicate claims made under our policies;

(d)    to develop, enhance, market or provide products and services;

(e)    to manage and continually develop our businesses and operations, including personnel and employment matters; and

(f)    to meet legal and regulatory requirements.

2.3    If we want to use Personal Information for a purpose other than what was identified at the time the Personal Information was collected, then we will obtain the prior consent of the individual to that additional use.

3.0    Consent

3.1    Personal Information will only be collected, used, or disclosed with the knowledge and consent of the individual, except where inappropriate.

3.2    Whether the consent is express or implied, may vary depending upon the sensitivity of the information and the reasonable expectations of the individual. Consent may be withdrawn at any time, subject to legal or contractual restrictions and reasonable notice. We will inform individuals of any implications of withdrawing consent.

3.3 Consent for the use or disclosure of personal information will be obtained at the time of collection. In certain circumstances, consent may be sought after the information has been collected but before use (such as where we want to use information that has already been collected for a purpose not previously identified).

3.4    The supply of services will not be conditional upon an individual consenting to the collection, use, or disclosure of Personal Information beyond that required to fulfill legitimate purposes.

3.5    Personal Information may be collected, used, or disclosed without the knowledge or consent of the individual in certain circumstances, as permitted or required by law. These circumstances include, Personal Information which is subject to solicitor-client privilege or is publicly available, where collection or use is clearly in the interests of the individual and consent cannot be obtained in a timely way, to investigate a breach of an agreement or a contravention of a law, to act in response to an emergency that threatens the life, health or security of an individual, for debt collection, or to comply with a subpoena, warrant or court order.

4.0    Limiting Collection of Personal Information

4.1    We will only collect the amount and type of Personal Information which is necessary for our identified purposes and we will only collect Personal Information by fair and lawful means.

5.0    Limiting Use, Disclosure, and Retention

5.1    Personal Information will be used or disclosed only for the purposes identified by law.

5.2    Access to Personal Information is limited to those employees who require access for business purposes.

5.3    When Personal Information is no longer required to fulfill the purpose for which it was collected, it will be destroyed, erased, or made anonymous, provided there are no legal requirements for its continued retention. Our systematic practices for information and records retention and destruction apply to Personal Information.

6.0    Accuracy

6.1    We will use our best efforts to ensure that Personal Information is as accurate, complete, and up-to-date as is necessary for the purposes for which it is to be used, including information that is transferred to third parties for information processing, and information that is used to make a decision about an individual.

7.0    Safeguards

7.1    Personal Information will be protected with safeguards appropriate to the sensitivity of the information.

7.2    These safeguards will protect Personal Information with safeguards appropriate to the sensitivity of the information held. Employees will be made aware of the importance of maintaining the confidentiality of Personal Information, and we will exercise care in the disposal or destruction of Personal Information to prevent unauthorized parties from gaining access to it.

7.3    We will safeguard Personal Information by physical measures (for example, locked filing cabinets and restricted access to offices), organizational measures (for example, security clearances and limiting access on a "need-to-know" basis), and technological measures (for example, the use of passwords and encryption).

8.0    Openness

8.1    Information about our policies and procedures respecting Personal Information will be readily available to individuals, including how to gain access to Personal Information, the type of Personal Information held by us, including a general account of its use, general information concerning our policies respecting Personal Information, and how to contact our Privacy Office.

9.0 Individual Access

9.1 A   ccess to Personal Information, including how we use and disclose the Personal Information may be obtained on written request. An individual can challenge the accuracy and completeness of his or her Personal Information and have it amended as appropriate.

9.2    An individual's written request for access to Personal Information will be answered within a reasonable time and at a reasonable cost. We will assist any individual who informs us that they need assistance in preparing a written request. We may require an individual to provide sufficient information to permit us to provide an account of the existence, use and disclosure of Personal Information.

9.3    If an individual successfully demonstrates the inaccuracy or incompleteness of Personal Information, we will amend the Personal Information. If a challenge is not resolved to the satisfaction of the individual, we will document the substance of the unresolved challenge. The amended information or the existence of the unresolved challenge, as the case may be, will be transmitted to third parties having access to the information in question.

9.4    Requests for access to all the Personal Information we hold about an individual may be refused if permitted or required by law. In such a case, the reasons for denying access will be provided to the individual upon request. Exceptions may include: information that contains references to other individuals or contains confidential commercial information, which cannot be severed from the record; information collected in the course of investigating a breach of an agreement or in the course of a formal dispute resolution process; and information that is subject to solicitor-client privilege.

10.0    Challenging Compliance

10.1    A challenge concerning our compliance with any portion(s) of the Privacy Policy should be sent in writing to our Privacy Office, and more specifically Karen Decker. Address for service is as follows:




10.2    All written complaints will be investigated. If we find a complaint to be justified, we will take all appropriate measures, including, if necessary, amending our policies and practices. A complainant shall be informed of the outcome of the investigation regarding his or her complaint.

10.3    We encourage the use of our internal information and resolution process to resolve a complaint. However, an individual may also seek advice from the Office of the Privacy Commissioner of Canada at 1.800.282.1376 or www.privcom.gc.ca/contactus/index_e.asp and, if appropriate, file a written complaint with that office.