Legal and Compliance
Combined Insurance is committed to making every reasonable effort to ensure persons with disabilities are treated with dignity and respect and in a manner that respects their independence. We are committed to meeting the needs of people with disabilities in a timely manner and do so by preventing and removing barriers to accessibility and meeting accessibility requirements.
Every reasonable effort is made by Combined Insurance to provide accessibility to disabled individuals and implement procedures to facilitate accessibility. This may require alternative formats and flexible approaches.
ACCESSIBILITY ACCOMPLISHMENTS
Customer Service Policy
We developed and implemented a customer service policy that addresses the Customer Service Standards under the Integrated Accessibility Standards Regulation (O. Reg. 191/11).
Accessibility Training
We developed and deployed training on the Customer Service Standards under the Integrated Accessibility Standards Regulation (O. Reg. 191/11) and aspects of the Ontario Human Rights Code that relate to persons with disabilities. This training is mandatory for all employees and sales representatives who communicate with customers.
Feedback Process
Combined Insurance has a process for receiving and responding to feedback regarding accessibility.
Employment
We developed and deployed a written process as a guideline to accommodate an employee with a disability and to facilitate an employee’s return to work after absence due to disability.
We are committed to continue providing employees with disabilities with individualized emergency response information, in an accessible format when required.
Information and Communications
Combined Insurance is committed to meeting the communication needs of people with disabilities. We have taken steps to ensure all new websites and content on those sites conform with WCAG 2.0, Level AA.
ACCESSIBILITY PLAN
Combined Insurance currently has the outlined actions below in place to improve opportunities for people with disabilities. We continue to monitor the accessibility acts and regulations and review this accessibility plan as necessary.
Customer Service
We are committed to providing accessible customer service to people disabilities. We monitor the Customer Service Standards on a regular basis to ensure that they are reflective of Combined Insurance's current practices as well as legislative requirements.
Training
We provide training to employees and sales representatives on Ontario’s accessibility laws, which incorporate the requirements of the Integrated Accessibility Standards and the Human Rights Code, as it pertains to people with disabilities.
Information and Communications
We are committed to meeting the information and communication needs of people with disabilities. We consult with people with disabilities to determine their information and communication needs and provide materials in accessible formats or with communication supports upon request. This is done in a timely manner that takes into account the person’s accessibility needs and at a cost that is no more than the regular cost charged to other persons.
Employment
We are committed to fair and accessible employment practices.
We take steps to notify the public that, when requested, Combined Insurance accommodates people with disabilities during the recruitment, assessment and selection process.
We inform current and new employees of our accessible employment practices and provide supports or accommodation to employees with disabilities. Combined Insurance will develop and implement a process for documented individual accommodation plans and return-to-work accommodations for employees that have been absent due to a disability.
FOR MORE INFORMATION
Questions or comments about Combined Insurance’s accessibility plans, policies and practices are welcome and appreciated. Please contact a Customer Service Representative at 1-888-234-4466 between 8 a.m. and 7 p.m. EST, Monday through Friday to express your comments. If you wish to communicate with the Company in writing, please send the comments to the address below. You may also send the Company your comments through our website at www.combined.ca or by fax at (905) 305-8600.
Combined Insurance Company of America
P.O. Box 3720, MIP Markham, ON L3R 0X5
Attention: Compliance Department
Introduction
At Combined Insurance, we are proud to offer high-quality products and exceptional customer service. While we strive to exceed your expectations, we also understand that complaints may arise. As a commitment to maintaining our strong relationship with you, we take all complaints seriously because your satisfaction is crucial to our success, and as such, we endeavor to respond promptly and courteously. We are always striving to improve, and your valuable feedback enables us to understand your needs better and continue delivering excellent service. Combined Insurance has a multi-level complaint escalation process.
Purpose of the Policy
The purpose of this Policy is to provide consumers with a clear and fair procedure for dealing with their complaints. This Policy explains the process put in place by Combined Insurance to handle the receipt of consumer concerns or complaints, the delivery of the acknowledgement of receipt and notices to the complainant, the creation of the complaint file, the fair and thorough review of the complaint and the compilation of complaints for the purpose of preparing and filing reports with the appropriate provincial regulators, as required. In addition, this Policy outlines the right of the complainant to request the transfer of the complaint file to the Autorité des marchés financiers (“AMF”) for Québec residents or the OmbudService for Life and Health Insurance (“OLHI”) for all Canadian residents.
Definition of a Complaint
A complaint is as an expression of dissatisfaction from, or on behalf of, a consumer about the practices and decisions of the insurer, its representatives, or its selling intermediaries. For the purpose of this Policy, a complaint is the expression of at least one of the following three elements:
- A reproach against Combined Insurance.
- The identification of a real or potential harm that a consumer has experienced or may experience; or
- A request for a remedial action.
Individual Responsible for Applying this Policy
The Chief Complaint Officer, Ahlam Bukhari, is an employee of Combined Insurance who is responsible for applying this Policy. This person ensures that Combined Insurance’s staff who handle complaints are trained and provides them with the necessary information for compliance with this Policy. The Chief Complaint Officer reviews and responds to formal complaints and serves as an intermediary with the various regulatory bodies that govern Combined Insurance with respect to dispute resolution and the handling of complaints. This person is also responsible for transferring the complaint file to the AMF or OLHI, as applicable, at the complainant’s request as well as for annual reporting to the appropriate provincial regulators with regards to complaints.
Dissatisfaction (Level 1)
If consumers have a concern, they should first contact a Customer Service Representative at 1 888 234-4466 between 8 a.m. and 7 p.m. Eastern time, Monday through Friday. Most
situations can be resolved quickly and easily by speaking with a Customer Service Representative. Or, consumers may communicate with the Company in writing by mail at the address below:
Combined Insurance Company of America
P.O. Box 3720, MIP
Markham, Ontario L3R 0X5
Attention: Customer Service
Concerns can also be sent through Combined Insurance’s website at www.combined.ca under “Contact Us” or by fax at 905 305-8600.
Complaints (Level 2)
If a concern or complaint cannot be quickly resolved by the Customer Service team, it will be forwarded to the department that handles and makes decisions about the subject matter outlined in the communication. The person handling the complaint will send the consumer a letter within five (5) business days to acknowledge receipt of the complaint. A written response will be sent once the complaint has been reviewed, generally within thirty (30) business days.
If this does not resolve the concern, there are additional steps that can be taken.
Formal Complaints - Chief Complaint Office (Level 3)
When a concern or dispute cannot be resolved in the course of normal Company business (Levels 1 and 2), or if the consumer remains dissatisfied with the written response that has been provided, a formal complaint can be sent in writing to the Chief Complaint Officer at:
Combined Insurance Company of America
P.O. Box 3720, MIP
Markham, Ontario L3R 0X5
Attention: Chief Complaint Officer
Upon receipt of a formal complaint, the Chief Complaint Officer ensures that the concern or complaint has been handled and has gone through the escalation steps in the internal process described above, failing which the Chief Complaint Officer returns the request to the appropriate department so these steps can be followed. If the complaint was properly escalated through the internal process, the Chief Complaint Officer will:
- Make sure the complaint process has been followed and that the complaint has been fairly considered;
- Send the consumer an acknowledgment of receipt and notice, within 5 business days. The correspondence will include a description of the complaint, specifying the real or potential harm, the reproach against the Company or the requested remedial action, the Chief Complaint Officer’s name and contact information along with a copy of this Policy. In the case of an incomplete complaint, more information will be requested. If a response is not provided within a set deadline, the complaint will be deemed to have been abandoned;
- Review and analyze the complaint in a fair and impartial manner, requesting more information if required;
- Provide the consumer with a final written response (final position letter) within 30 business days of receiving all the information necessary for the examination, explaining the outcome along with the reasons behind the decision. If the examination of the complaint cannot be completed within 30 business days, the consumer will be informed of the status and progress of the examination and provided with an approximate response date;
- The response shall include a notification of the external recourses available to consumers if they remain dissatisfied and wish to pursue or transfer their complaint file. For Québec residents, this will include a reminder that transferring the file does not interrupt the prescriptive period for civil remedies.
Complaint File, Register and Regulatory Reporting
A separate file is created for each complaint received. Subject to continued compliance with applicable privacy laws, each complaint file contains the complainant’s written complaint and the defining element(s) of a complaint, as described above, all supporting documentation, information and notes, the acknowledgement of receipt and the outcome of the complaint examination process (the analysis and supporting documents), a copy of the complaint response and, if applicable, the Chief Complaint Officer’s final position letter outlining the justification behind the decision. Such records are kept in accordance with applicable laws and the Company’s record retention policy.
The information related to the complaint is entered in a complaint register and given a file number. An annual report is filed with the Canadian Council of Insurance Regulators (CCIR).
Complaint Transfer
Complaints Transfer (Level 4)
If consumers are dissatisfied with the outcome of the handling of their complaint by the Chief Complaint Officer or the complaint examination process, they can request that the complaint file be transferred to the appropriate regulatory body or consumer organization at any time.
For residents of Québec, the file may be transferred to the Autorité des marchés financiers (AMF) for their review (www.lautorite.qc.ca). The AMF may be reached by calling toll-free at 1-877-525-0337, via email at information@lautorite.qc.ca, or by mail:
All Canadian residents including those in Québec, may contact the OmbudService for Life & Health Insurance (OLHI) (www.olhi.ca). The OLHI is a national independent complaint resolution and information service for consumers of Canadian life and health insurance products and services. The OLHI deals with concerns about life and health insurance products and services that have not been resolved through the Company’s dispute resolution system. The OLHI can be reached by calling:
Toll-free Canada: 1 888-295-8112
Toll-free Québec: 1 866-582-2088
All correspondence should be sent to OLHI’s Toronto office:
OmbudService for Life & Health Insurance
2 Bloor Street West, Suite 700
Toronto, ON M4W 3E2
Policy Review
This Policy is effective as of July 2021. It is reviewed every two years or earlier to reflect changes in applicable legislation or guidance..
Last updated: September 2024
At Combined Canada, we recognize that our success directly depends on customer satisfaction. We are dedicated to delivering exceptional service and treating our customers fairly. Transparency is a core value in all our interactions, and we strive to keep our customers well-informed about our products and services. Combined Insurance aims to provide customers with confidence, offering robust protection backed by our commitment to integrity.
Combined Insurance is committed to upholding the highest business standards possible. To ensure this, we comply with government policy and actively participate in insurance associations (the names and links of which are noted for your reference).
Canadian Life and Health Insurance Association (CLHIA)
The Canadian Life and Health Insurance Association (CLHIA), established in 1894, is a voluntary trade association that represents the collective interests of its member life and health insurers. The Association's membership accounts for 99 per cent of the life and health insurance in force in Canada and administers about two-thirds of Canada's pension plans.
For more details about this association, please visit their website.
Assuris
Combined Insurance is a member of Assuris. Assuris is the not for profit organization that protects Canada policyholders in the event their life insurance company fails. Details about Assuris’ protection are available at below link or by calling the Assuris Information Centre at 1 866 878-1225.
This Privacy Policy (“Policy”) describes how Combined Canada (“Combined Canada”), a branch of Combined Insurance Company of America (“CICA”), collects, uses, discloses, and protects the Personal Information of individuals who apply for, purchase, or receive Combined Canada products and services.
The Policy (“Policy”) applies solely to the Personal Information practices of Combined Canada. This Policy expands on and specifies the application of the CICA Privacy Policy in the Canadian legal and regulatory context.
The Policy applies to Personal Information collected or used by Combined Canada in relation to Combined Canada products and services accessed via our website, mobile applications, and telephone or in person.
“Personal Information” means information about an identifiable individual. The Personal Information we collect may include:
a. Identifiers: Name, address, date of birth, social insurance number (“SIN”).
b. Contact information: Phone number, email address.
c. Financial information: Income, employment, assets & liabilities, payment information.
d. Personal Health Information: Medical history, condition, disabilities, etc.
e. Audio call recordings.
f. Online activity: IP address, browsing history, page visits, links clicked, duration on pages, location data such as IP address location, etc. are governed by our website’s Terms of Use posted on our website.
We collect Personal Information directly from individuals or from third party sources, always with appropriate consent when required:
a. Directly from individuals/customers through applications, forms, surveys, website use, etc.
b. Healthcare providers, Insurance databases such as MIB
c. Agents, Brokers, Service Providers acting for customers or on our behalf
d. Publicly available sources
We collect Personal Information to provide individuals with products and services. Specific purposes may include:
a. Establishing identity and determining eligibility
b. Providing quotes or advice
c. Underwriting and administering policies
d. Processing claims
e. Internal modeling, analytics, and improvement of products/services
f. Communicating, marketing, and providing customer service
g. Meeting legal and regulatory requirements
We limit collection, use, disclosure, and retention to what is necessary for identified purposes. We obtain consent where required by law before collecting, using, or disclosing Personal Information for a new purpose.
We may use or disclose Personal Information internally, between Combined Canada and CICA and Chubb Group of Insurance Companies, brands, affiliates, and subsidiaries, to provide individuals with products and services and for other purposes identified here.
We do not sell Personal Information. We may share Personal Information with third party service providers acting on our behalf and pursuant to contractual restrictions regarding information use and disclosure.
We may disclose Personal Information without consent to comply with legal requirements, for example in response to a court order or law enforcement request, as required or permitted by PIPEDA or other laws.
We may disclose anonymous, de-identified or aggregated information to third parties, but this information will not be identifiable to any individual.
We store your Personal Information outside of Canada.
We implement physical, technical, and organizational safeguards appropriate for the sensitivity of Personal Information in our custody or control. These safeguards aim to protect Personal Information from unauthorized access, use or disclosure.
We require third party service providers to protect the Personal Information they process on our behalf consistent with privacy and security obligations under our contractual agreements.
We retain Personal Information only as long as necessary to meet identified purposes or as legally required. When no longer required, we have a roadmap to securely destroy the information.
Individuals may request access, correction, withdrawal of consent or request deletion of their Personal Information. They may also file a complaint with Combined Canada, the Privacy Commissioner of Canada or other competent authority regarding our Personal Information practices.
We may update this Privacy Policy from time to time as our Personal Information practices evolve. The revised Privacy Policy will be made available via our website. These changes will apply to the way we handle your Personal Information going forward. We encourage you to check this policy periodically for updates.
If you have any requests, questions, or concerns regarding our Privacy Policy or practices, please contact our Chief Privacy Officer at:
Chief Privacy Officer
P.O. Box 3720, MIP
Markham (Ontario) L3R 0X5
Email: Compliance@ca.combined.com
To fill out a Personal Information request, please click on the link below.
We will respond to requests as soon as possible and generally within 30 business days.
Combined Insurance and Chubb make no representations about the suitability of the content of this site for any purpose. All content is provided "as is" without any warranty of any kind. Combined Insurance and ace limited hereby disclaim all warranties and conditions with regard to the content, including but not limited to all implied warranties and conditions of merchantability, fitness for a particular purpose, title and non-infringement. In no event shall Combined Insurance nor Chubb be liable for any special, indirect, exemplary or consequential damages or any damages whatsoever, including but not limited to loss of use, data or profits, without regard to the form of any action, including but not limited to contract, negligence or other tortuous actions, arising out of or in connection with the use, copying or display of the content. Although Combined Insurance and Chubb believe the content to be accurate, complete and current, Combined Insurance and Chubb make no warranty as to the accuracy, completeness or currency of the content. It is your responsibility to verify any information before relying on it. The content of this site may include technical inaccuracies or typographical errors. From time to time changes are made to content herein. Combined Insurance and Chubb may make changes in the products and/or the services described herein at any time.
Some of the sites listed as links herein are not under the control of either Combined Insurance or Chubb. Accordingly, Combined Insurance and Chubb make no representations whatsoever concerning the content of those sites. The fact that Combined Insurance or Chubb have provided a link to a site is not an endorsement, authorization, sponsorship or affiliation with respect to such site, its owners or its providers. Combined Insurance and Chubb have not tested any information, software or products found on these sites and therefore cannot make any representations whatsoever with respect thereto. There are risks in using any information, software or products found on the internet, and Combined Insurance and Chubb caution you to make sure that you completely understand these risks before retrieving, using, relying upon or purchasing anything via the internet.
Combined Insurance, Combined Insurance Company of America and Combined Life Insurance Company of New York are registered trademarks of Combined Insurance. Chubb and the Chubb logo are service marks of the Chubb.
Combined Insurance uses links through its site to allow you to elect to contact us via e-mail. Although we will ask you to call or write us about many topics we consider too sensitive to be done via e-mail, we do accept questions and welcome your comments and suggestions. In addition, you may also be offered the opportunity to have one of our representatives contact you. To better serve you in this regard, we may require that minimal personal information be provided to us, such as your name and telephone number. We may keep this information on file to help us help you in the future. We may also share this information with a subsidiary, business partner, representative or affiliate of Combined Insurance so that they may contact you about other goods and services or to assist you in the support, renewal or purchase of Combined Insurance products and services.
A “cookie” is a piece of information that our web site sends to your browser which then stores this information on your system. If the cookie is stored, the web site remembers information about you and your preferences. If the cookie is temporary it will only remember information about you until you exit the current browser window. If your cookie is permanent it will retain information about you until you disable or delete the cookie. Many people like to use cookies to save time. Remember – cookies only contain information which you have already provided to us. They are not able to get into your hard drive and return to the sender with personal or other information from your computer.
We only use cookies in two ways. The first is for temporary cookies. When you visit our site, our web server automatically sends your browser a temporary cookie which is used to help your browser navigate our site. Any information is erased when you close your current browser window. If you visit our site from one of our business partners our web server may send your browser a temporary cookie that reflects an “origination code” for that business partner. This information is used for statistical and marketing purposes.
If you visit our web site and request information from us, we may also use cookies. If you click on a box that says something like “please remember my profile” we'll send a cookie. If you want more information check out the following:
Microsoft Internet Explorer users visit:
What is unclaimed property?
Unclaimed or “abandoned” property refers to property or accounts within financial institutions or companies—in which there has been no activity generated (or contact with the owner) regarding the property for one year or a longer period.
If you believe that you are the owner of unclaimed property (such as a claim payment or refund of premiums) being held by Combined Insurance and would like to request a search of our database, please submit your request in writing to:
Combined Insurance Company of America
Attention: Director, Corporate Compliance
150 Commerce Valley Drive West
Suite 700
Markham, ON L3T 7Z3
Please allow 4-6 weeks for us to respond to you.
The provinces of Alberta, British Columbia, New Brunswick and Quebec have formal Unclaimed Property Programs in place. For more information, please see click on province specific link below:
Alberta: https://www.alberta.ca/unclaimed-property
British Columbia: https://www.bcunclaimed.ca/about/unclaimed-property-process
New Brunswick: https://fundsfindernb.ca/report-property