MVP program · Fintech & financial services
Minimum Viable Privacy Program for Insurance Brokerages & MGAs
Minimum Viable Privacy gives a small brokerage or a newly forming MGA the foundations in twelve months: a gap review of how client data moves through your BMS and carrier relationships, essential policies, readiness workshops and staff training, for $5,499 CAD per year. It is the right starting point for a six-person brokerage that just received a carrier security schedule it cannot answer today, or an MGA building its compliance file ahead of Ontario's incoming licence class.
Reviewed by the Privacy Horizon team · Last reviewed
What you're protecting
The essentials a small brokerage must lock down
A six-person shop holds the same categories of sensitive client data as a hundred-person brokerage, just in fewer, busier hands with less time to spare.
One governed home for client files
Underwriting applications, claims history and payment details consolidated in the BMS with basic access rules, instead of scattered across personal drives and inboxes.
MFA on the systems that matter most
The BMS, email and any carrier portal locked behind MFA and unique credentials, because a shop this size cannot absorb one phished login exposing the whole renewal list.
A retention rule everyone follows
A simple, dated policy for how long expired policies and unconverted quotes stay in the BMS, enforced through a recurring purge rather than good intentions.
A clean-desk basic for underwriting files
A short rule for what stays locked overnight, given how often Alberta OIPC decisions trace back to unsecured physical files rather than a hacked system.
Regulatory map
Baseline obligations before your next carrier renewal
Small does not mean exempt. The statutes and carrier expectations that reach a national MGA reach a six-person brokerage on day one.
PIPEDA from the first client file
Identified purposes, consent, limited collection and safeguards apply to a three-producer shop exactly as to a national brokerage, with no small-business threshold.
RIBO's baseline confidentiality duty
The Code of Conduct Handbook applies to every RIBO-licensed brokerage regardless of size, and names cyber attacks on brokerage records as a live confidentiality risk.
Carrier outsourcing expectations
CCIR/CISRO's Fair Treatment of Customers guidance means carriers oversee intermediaries of every size, so a small brokerage still fields real outsourcing questionnaires.
FSRA's incoming MGA licence class
Even a small MGA preparing for Ontario's proposed Rule 2025-001 benefits from a documented baseline program well before the licence application actually opens.
What goes wrong
Why small brokerages are targets too
Attackers do not scale their interest to your headcount; they scale it to your data, and a small brokerage's client files are just as valuable as a large firm's.
One inbox holds the whole book
At a six-person brokerage, client files, carrier correspondence and premium instructions often sit in one or two mailboxes, so a single compromise touches everything.
Carrier renewals stall without evidence
A carrier's security schedule sized for a firm your size still asks for MFA, an incident plan and training records; a blank answer can slow or narrow binding authority.
Uninsurable answers at renewal
A cyber-insurance application answering 'no' across the board risks declined coverage exactly when the brokerage most needs proof of its own controls.
Everything rests on one or two people
When the principal broker runs compliance, IT and client service informally, any absence or departure orphans the knowledge that keeps the firm defensible.
Our mvp program for insurance brokerages & mgas
What Minimum Viable Privacy includes for a brokerage or MGA
A year-long program with defined components, each sized for a small firm rather than delivered off a generic checklist built for a larger organization.
Baseline privacy gap review
A structured assessment of how client and, at an MGA, advisor data currently moves through your BMS and carrier relationships, against what carriers and regulators expect.
Prioritized control recommendations
The moves that matter most first, typically MFA, consent practices and retention, sequenced so a small team can act without pausing client work.
Policy development
The core documents a small brokerage needs: a confidentiality policy, retention rules and vendor data-sharing basics, written to match how your office actually runs.
Readiness assessment workshops
Working sessions that pressure-test the program against real scenarios, a carrier security schedule, a client access request, before reality does.
Training for the whole team
Human-risk assessment and practical training covering the collection discipline, phishing awareness and premium-fraud recognition a small office needs.
Coaching hours through the year
Expert time for the questions a small brokerage actually hits: a carrier's data-sharing request, an odd consent situation, a licence-application question.
How the engagement runs
A year of MVP at a small brokerage or MGA
The program is paced for an office where every hour spent on compliance is an hour not quoting or servicing clients.
Step 1
Gap review first
Early weeks establish the baseline: how client data flows from intake through the BMS to carriers, and the shortest path to a defensible position.
Step 2
Controls and policies land
Priority recommendations are implemented with coaching support while the confidentiality, retention and vendor policies are drafted and adopted.
Step 3
Workshops and training
Readiness sessions and team training convert the documents into daily habits, with the human-risk assessment showing where attention is still needed.
Step 4
Year-end position
You close the term with evidence in hand: assessment, policies and training records ready for a carrier renewal, a licence application, or a step up to a VPO retainer.
What it costs
MVP pricing for a brokerage or MGA
Minimum Viable Privacy is $5,499 CAD per year, billed annually on a twelve-month term, and includes the gap review, prioritized recommendations, policy development, readiness assessment workshops, training with ten seats and twelve hours of coaching. For a small brokerage or a forming MGA, that is the cost of a real program without hiring a full-time compliance role.
Firms that outgrow the baseline, a multi-office roll-up, heavy Québec client volume, or a full MGA licence application, typically step up to the Virtual Privacy Office for ongoing officer-level support. We will tell you plainly which tier fits before you commit.
Insurance Brokerages & MGAs: MVP program questions, answered
Four things, done properly: knowing what client data you hold and where it lives in the BMS; a confidentiality policy matching RIBO's handbook expectations; MFA and access controls on the systems that matter most; and a team trained on collection discipline and phishing recognition. That is precisely the footprint the MVP program builds in a year, sized for a firm without dedicated compliance staff to run it alone.
Start with what you can document today: named privacy and security ownership, whether MFA is actually enabled on the BMS and email, and whether a written incident response plan exists even in short form. The MVP gap review is built to move quickly on exactly this kind of deadline, giving you an honest current-state picture and the priority fixes to close the most visible gaps before the questionnaire is due back.
It is a strong foundation, not a guarantee of licence approval, since the licensing process itself is FSRA's to run. MVP gives a forming MGA a documented privacy officer function, policies and training records, exactly the kind of evidence a licence application is likely to ask for. Many MGAs use the MVP year to build that file, then step up to a VPO retainer once the licence class and application requirements are finalized.
Yes. The gap review and policies are built around how your specific firm handles data, whether that is auto and property underwriting files or life and health applications with medical questionnaires. A brokerage or MGA writing both lines gets one coherent program rather than two separate efforts, with line-specific handling addressed inside the shared policy framework.
Most small brokerages either renew the MVP program as their books grow modestly, or step up to a Virtual Privacy Office if growth, acquisition or new carrier relationships have outpaced what a fixed annual program can cover. We review your position at year-end and give you a straight recommendation based on what actually changed in your business over the twelve months.
It gives you real, current answers to the questions most cyber-insurance applications ask: MFA status, backup practices, an incident response plan and staff training records. That is often the difference between a straightforward renewal and one complicated by declined coverage or added exclusions. MVP will not replace a security-specific engagement if your insurer asks for deeper technical evidence, but it covers the baseline most applications start with.
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