Privacy policy for producers

Privacy/confidentiality

Sun Life Financial is committed to respecting and protecting our clients' personal information. As distributors of our products, you are required to protect our clients' non-public personal information (including financial and health information) from unauthorized disclosure.

Your duties as a Producer

• Understand this Privacy Policy
• Protect your client's non-public personal information from unauthorized disclosure at all times
• Understand Sun Life Financial's Privacy Policy
• Non-public personal information of clients may only be shared with those who have a need to know for purposes of providing sales and service support

Maintaining privacy

Respect for privacy is necessary to build strong business relationships. Personal information may only be used for the purposes for which it was originally collected, unless otherwise permitted or required by law or Sun Life Financial is authorized by the client to use it for another purpose.

Access to personal information within Sun Life Financial is restricted to those employees who have a legitimate business reason to access it. Sun Life Financial may communicate personal information to its agents and service providers to service or administer a client's account or transactions.

Limited Use and Sharing of Non-Public Personal Information by Sun Life Financial

Collecting personal information from clients is essential to our ability to offer high-quality investment, retirement and insurance products. When a client applies for a product or service with us, we need to obtain information from them in order to determine whether or not we can provide the product or service to the client. As part of that process, we may collect information about the client, commonly known as non-public personal information. Examples of non-public personal information include the following:

• Information we receive from the client on applications or other forms, such as their name, address, date of birth, and financial information
• Information about a client's transactions with us, our affiliates or others, such as other life insurance policies or annuities that the client may own; and
• Information about a client's medical/health history

Limited Use and Sharing of Non-Public Personal Information by Sun Life Financial

We use the non-public personal information we collect to help us provide the products and services the client has requested and to maintain and service the client's account(s) with us. Once we obtain non-public personal information from a client, we do not disclose it to any third party except as authorized by the client, or as permitted or required by law or regulation. For example, there may be times when Sun Life Financial is required to disclose a client's non-public personal information in order to respond to a subpoena, or when complying with an inquiry by a governmental agency or regulator, wherever situated.

We are permitted to share a client's non-public personal information within Sun Life Financial to help us develop innovative financial products and services. We may also disclose a client's non-public personal information to companies or affiliates that help us conduct our business or perform services on our behalf.

Our Treatment of Information about Former clients

Our protection of a client's non-public personal information extends beyond the period of the client's relationship with us. If the client relationship with us ends, we will not disclose the information to non-affiliated third parties other than as permitted or required by law or this policy.

Security of Non-Public Personal Information

Sun Life Financial maintains physical, electronic and procedural safeguards to protect non-public personal information from unauthorized use or improper access.

Sun Life Financial Employee Access to Non-Public Personal Information

To comply with Bermuda regulations, we restrict access to non-public personal information to those employees who have a business "need to know" that information in order to provide products or services to a client or to maintain a client's account(s). All Sun Life Financial employees are governed by a strict code of conduct and are required to maintain the confidentiality of client information.

Guidelines for Sending Client Information by Fax

As stated in the Privacy Policy above, Sun Life Financial is committed to protecting the non-public personal information that we collect from our clients. However, the success of our Policy relies most heavily on those of us who may have access to confidential information, and the prudence that each of us should regularly exercise.

Faxing, a capability that is used daily, poses some risks with respect to exercising such discretion. Whether done electronically though a desktop application, or through a physical fax machine, the efficiency and convenience that faxing offers is somewhat countered by the risk that confidential information could be so easily shared. In order to help mitigate this risk, the following practices should be considered. You should also consult guidance published by your firm:

• Documents including client or policy specific information should not be faxed unless the recipient (e.g. client or producer) has satisfied standard authentication protocols. As an example, if we receive a phone call from a client or producer asking that certain forms be faxed to them, we will first verify that they have provided the details that would be required for us to provide the same type of information to them over the telephone. Generally, callers are required to provide multiple details (e.g., name, policy number, date of birth) prior to any client or policy specific information being shared
• When sending information using physical fax machines, documents containing confidential information should never be left unattended. The sender of a fax should remain at a fax machine until all pages have been scanned, and immediately remove the pages

Guidelines for Sending Client Information by E-mail

• At times, your work may require you to communicate confidential or sensitive information, including client information. If you use e-mail for such communication be particularly aware of its limitations as a secure delivery mechanism and take all appropriate precautions to help ensure the information is kept confidential
• Avoid sending your e-mail to too many people and carefully consider who really needs to read your message. You can avoid a potential breach of confidentiality by double-checking to ensure recipients' names are correct
• Do not include someone in the "cc" or "bcc" fields unless there is a clear reason for that person to receive your e-mail. Think about who really needs to know
• All e-mail messages directed to locations outside of Sun Life Financial will have the following text automatically appended: "This e-mail message (including attachments, if any) is intended for the use of the individual or entity to which it is addressed and may contain information that is privileged, proprietary, confidential and exempt from disclosure. If you are not the intended recipient, you are notified that any dissemination, distribution or copying of this communication is strictly prohibited. If you have received this communication in error, please notify the sender and erase this e-mail message immediately"

Following these guidelines or similar guidance published by your firm will help to protect the confidentiality of non-public personal information we collect from our clients.