Thanks, Bob.
Good morning, everyone. My name is Peter Fredericks. I'm the vice-president of our association. As is Mr. Kimball, I'm a working broker in Bedford, Nova Scotia, a town of about 28,000. There are five other brokers in my town, actually. I employ four people.
Our day-to-day operation, from a security and privacy standpoint, is very similar to Mr. Kimball's, so I won't go through that again with you.
We have three issues we would like to raise on the Privacy Commissioner this morning. The first is the actual role and mandate of the Office of the Privacy Commissioner. We believe the ombudsman model is the appropriate and effective model for this organization. We believe it is essential that parties have access to collaborative dispute resolution, and we believe it is a fair practice to have a judicious overseer.
The second issue we wish to bring up is work product. It's an area that we believe needs clarification. It's widely accepted that information obtained during the usual course of business is proprietary to the firm. The current law, we feel, is unclear both in the definition of work product and in the fact that it should be excluded from falling under personal information. Our position is that the analysis and expertise surrounding the use of personal information is proprietary to the broker and should not be included in personal information under the law.
Our third issue is with respect to duty to notify in the event of a breach of personal information. We concede and agree wholeheartedly that this is a sensitive topic for all Canadians. Our profession is one that is based on assessing risk and placing it with the proper coverages.
Our basic reason for being is to protect our clients, whether it's protecting their homes, their cars, their business, or of course their privacy. It just flows that a breach in privacy would necessarily involve assessing the degree of breach, informing a client, and mitigating any future breaches--it's key to our profession. We believe it just makes good business sense to follow this model. Because of the nature of the insurance industry, we believe that regulating this duty would be challenging at best and practically unworkable at worst.
For us, the bottom line is that if a briefcase containing three clients' files is stolen, obviously the broker involved is going to make every effort possible to assist those three customers and do whatever is right to make sure that information is protected. Our concern is being regulated by this body to contact, in my case, all 2,500 of my customers to inform them that three customers' files had been stolen.
Those are basically our concerns with the issues before you. We'd like to thank you very much for the opportunity to be here this morning. We're more than happy to answer any questions you may have.