Our privacy practices are part of a larger corporate

commitment to respect individuals, from plan sponsors

and participants, to our sales organization and our own

employees. As a long-standing member of the financial

services industry, we have always worked to ensure that our

business practices prevent any breach of confidentiality

andwe work to maintain the highest standards of conduct.

When you, as a company or an individual, apply for coverage

under a group benefits plan, you share personal information

• offering you complementary products and services; or

• meeting regulatory requirements.

We will contact you and obtain your consent if it ever becomes

necessary to use your information for any other purpose.

COLLECTING YOUR PERSONAL INFORMATION

In most cases, when you sign up for your benefit program

weobtain all the information we need directly from your

employer or from you (from the employer’s application

forms, or from your enrolment form). This may include name,

address, phone number, age, occupation, salary, family status

When you make a claim for benefits, we may also collect

information to determine the eligibility of the claim, and the

nature of theexpense. We may contact you, your healthcare

professionals or other benefitproviders.

All this information will be collected with the individual’s

knowledge and consent. We will make every reasonable

attempt to keep this information accurate and current, and

we ask that you advise us of changes in order to keep our

records up-to-date. This will allow us to provide you with the

best service possible.

We employ best practices to protect collected information

from loss and unauthorized access.

Our systems are designed to prevent unauthorized access

and, within our organization, we limit access to your personal

information to only those individuals who administer your

group plan and benefits. Each employee in our organization

has signed a confidentiality agreement further protecting your

personal information.

Privacy Compliance Officer

Johnston Group Inc.

Your personal information is kept only as long as we need

it to administer your group plan and fulfill regulatory

obligations. Our organization has policies and procedures

in place to securely deleteor physically destroy all personal

information when it is no longer needed.

or when using cloud-based services), we protect the

confidentiality of your personal information and ensure it is

We use enrolment and claim information only to administer

your group benefit plan and to ensure you receive all the

benefits you’re entitled to receive. As a result we may

disclose your personal information to:

• insurance companies and service providers providing

benefits under your group contract;

• physicians or other healthcare institutions for the purpose

of determining coverage eligibility, and processing and

adjudicating your claims;

• your authorized representatives, such as individuals with

your request within 30days and provide you with access to

the information we have onfile.

Your request should be submitted to us in writing and you

will be required to provide proof of your identity.

This Privacy Policy has described the collection, protection

and disclosure of the personal information we need to

administer your group benefit program. It is your right to

choose not to provide us with some or all of your personal

information, or to deny us the use or disclosure of your

information for certain purposes. If you exercise this right,

you want to:

• better understand the kinds of information we collect,

• express any concern about our privacy policies or how

we’ve handled information about you, or

• ask questions about our privacy policies.

Johnston Group Inc. has always been, and will continue to be, committed to protecting your privacy,

ensuring yourpersonal information remains confidential.

Privacy Policy