TO: ALL RIBO REGISTRANTS
DATE: Thursday April 16th, 2020
RE: COVID 19 Update
RIBO Office Remains Closed
RIBO supports and follows public health recommendations to reduce the spread of COVID-19. As the threat to the public posed by the pandemic remains high, we have extended our work from home plan for all employees until further notice. The RIBO office will remain closed during this time period.
We remain available to assist you, although with reduced capacity. For maximum efficiency, all correspondence should be made through email. For all other inquiries, please submit a message through the RIBO website: Contact Us Form and the message will be directed to the appropriate resource.
Please note that individual staff will continue to monitor and respond to their email.
Our general phone line remains open at 416-365-1900 / 1-800-265-3097. Please listen carefully to the instructions in the recorded message. It may be updated during this time. Messages will be monitored and forwarded to the appropriate person.
- Form 1 Position Reports that were due March 31, 2020 have been extended to April 30, 2020.
- Form 1 Position Reports can now be completed online by navigating to the Member Login page at RIBO.com. Soft copies of the report can also be emailed to firstname.lastname@example.org (note: one ‘e’ in her name).
- Scheduled Discipline Hearings and Complaints Meetings normally held at RIBO remain postponed.
- Licensing examinations will not be scheduled nor sent to the examination centres until further notice.
- All new registrations will be delayed during the closure.
- The online Complaint Form is being monitored and processed in the usual manner.
Principal Broker Oversight
With most brokers working from home, Principal Brokers are under added pressure to provide meaningful oversight to the licensed individuals for whom they are responsible. RIBO, and the public we serve, rely upon Principal Brokers to establish and maintain a compliance regime that supports and reflects the structure of the brokerage(s), and ensures clients are fairly treated. As an example, client personal information must be protected if removed from or accessed outside of the office. Certainly, oversight can be more difficult when brokers are working from a home office, but the responsibilities of the Principal (as well as the broker) remain the same. Principal Brokers are encouraged to review their supervision policies and procedures and, where necessary, revise them to include business disruption scenarios where staff are required to work remotely. Similarly, review your brokerage cyber risk policies and ensure they reflect any additional risks from remote work locations.
Preservation of Client Information
Brokers are reminded a client’s confidential information must be protected and should not be given to anyone without first obtaining the client’s express written or oral consent to do so. This includes a client’s personal email address. Broker’s client files should include documentation of any express client consent, including with whom the information may be shared and for what purpose(s). Without such consent, brokers should encourage insurers to send policy documents to you by email and refrain from providing confidential email addresses to insurers.
Similarly, with many brokers working remotely during the pandemic, please be mindful of your ongoing duty to protect not only personal information but also any property entrusted to you by your clients. Be diligent about creating a work area that allows you to preserve and protect the confidentiality of client information.
For reference, the RIBO Code of Conduct states, at Section 14 (5) and (6) of Regulation 991:
14 (5) A member shall hold in strict confidence all information acquired in the course of the professional relationship concerning the business and affairs of the member’s client, and the member shall not divulge any such information unless authorized by the client to do so, required by law to do so or required to do so in conducting negotiations with underwriters or insurers on behalf of the client.
14 (6) A member shall observe all relevant rules and laws regarding the preservation and safekeeping of property of the client entrusted to the member and when there are no such rules or laws or the member is in doubt, the member must take the same care of such property as a careful and prudent person would take of the person’s own property of like description.
As we noted in our last email, the Provincial government has determined that brokers are an “essential workplace”. That said, RIBO strongly encourages brokerages, whenever possible, to work from home, practice social distancing, and keep any required visits to your office to an absolute minimum.
RIBO staff and Council are alive to the challenges presented by this pandemic. We remain actively engaged with industry trade associations, the Provincial Government, and insurance regulators across the country. Like you, we are all seeking opportunities to make our organizations less vulnerable to future disruptions. We appreciate your continued patience and understanding as policies and procedures may need changing on short notice to the profession.
Again, please stay safe and mindful of the recommendations of government officials. Let’s continue to do our part to get through this pandemic safely.