Thank you, Mr. Chairman and members of the committee.
I would like to thank the committee very much for giving us this opportunity to contribute to your review of the Personal Information Protection and Electronic Documents Act.
My name is, as indicated, Frank Zinatelli, and I am vice-president and associate general counsel of the Canadian Life and Health Insurance Association Inc., CLHIA.
I'd like to begin by saying a word or two about my colleagues who are seated with me at the table.
Dale Philp is assistant vice-president and senior counsel with Sun Life Financial, where she focuses on products and distribution group insurance issues. She is deeply involved with privacy issues in the life and health insurance industry, both within her own company and as chair of the CLHIA's privacy committee, where industry issues of common interest relating to the protection of personal information are discussed.
Yves Millette is the CLHIA's senior vice-president, Quebec affairs. Mr. Millette's lengthy experience in Quebec matters affecting our industry has given him a good familiarity with Quebec's privacy legislation. And of course, as you know, Quebec was the first Canadian jurisdiction to introduce private sector privacy legislation.
We welcome this opportunity to make constructive contributions to the committee as you seek to develop your report to Parliament on this sensitive, complex, and vitally important area.
With your permission, Chairman, we would like to make a few introductory comments. Together with Ms. Philp and Mr. Millette, we will provide the committee with the industry's views pertaining to the PIPEDA review.
By way of background, the CLHIA represents life and health insurance companies accounting for 99% of the life and health insurance in force across Canada. The industry protects about 24 million Canadians and some 20 million people internationally.
For over 100 years, Canada's life and health insurers have been handling the personal information of Canadians. The very nature of the insurance product requires that a large portion of the information exchanged between companies and their clients is personal in nature, and protecting its confidentiality has long been recognized by the industry as an absolute necessity for maintaining access to such information.
Indeed, our industry would not have survived if it were not able to have the trust placed in it by Canadians. Correspondingly, chairman, life and health insurers have taken a leadership role in developing standards and practices for the proper stewardship of personal information.
In 1980 we adopted right-to-privacy guidelines which represented, as far as I know, the first privacy code to be adopted by any industry group in Canada. Those guidelines served the industry and its customers well for 23 years, until they were superseded by personal information protection statutes across Canada in 2004.
In 1991 the industry included a provision in its consumer code of ethics which requires members to respect the privacy of individuals by using personal information only for the purposes authorized, and not revealing it to any unauthorized person.
And a commitment to this provision, by the way, is one of the requirements for membership in the CLHIA.
The committee should also be aware that the life and health insurance industry participated actively in the development of personal information protection rules across Canada such as, for example, Quebec's private sector privacy legislation in 1994.
The CSA model code is now schedule 1 of PIPEDA. The development of PIPEDA itself.... We worked also on the personal information protection acts of Alberta and B.C. and of course on the health information legislation in Alberta, Saskatchewan, Manitoba, and Ontario.
I will now turn it over to my colleague, Dale Philp, to continue our remarks.