Vancity Privacy Code

At Vancity, nothing is more important to us than protecting your privacy and personal information, and doing everything we can to protect you from theft and fraud. Our Privacy Code outlines our principles and procedures regarding the privacy, confidentiality and security of member personal information.

To make sure that our security meets the highest standards, our Privacy Code was created in accordance with the Federal Personal Information Protection and Electronic Documents Act (PIPEDA) and British Columbia’s Personal Information Protection Act (PIPA). Based on these standards, we adhere to nine privacy principles that offer our members the security they need and expect.

Scope
Definitions
Section 1: Accountability
Section 2: Identifying the Purposes for Collection of Personal Information
Section 3: Member Consent
Section 4: Limits for Collecting, Using, Disclosing, and Keeping Personal Information
Section 5: Accuracy
Section 6: Safeguarding Personal Information
Section 7: Availability of Policies and Procedures
Section 8: Providing Member Access to Personal Information
Section 9: Compliance and Complaints


Scope

This Code applies to Vancity. It outlines the principles and commitments we make to you, our member, to protect the privacy of your personal information.

This Code does not apply to the information collected, used or disclosed with respect to corporate or commercial entities that are members. However, Vancity exercises the same care and diligence in protecting the confidentiality of this information. Vancity’s Privacy Code applies to individuals carrying on business as sole proprietors and the personal information of signing officers on business accounts.

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Definitions

"Business Partner" – any person contracted to work on Vancity’s behalf, or provide products and services to Vancity members and/or Vancity.

"Consent" - involves voluntary agreement with what is being or may be done. Consent may be expressed or implied. Express consent can be given orally or in writing, it is unequivocal, and does not require any inference on the part of Vancity. Implied consent exists when Vancity can reasonably infer consent based upon the action or inaction of the member.

"Member" includes an individual who is or applies to be a member of Vancouver City Savings Credit Union or an individual who is or applies to be a customer of any entity in the Vancity Group.

"Personal Information" - means information about an identifiable individual, and includes information that is recorded in any form including name, address, date of birth, identification (such as a valid driver’s license, social insurance number (“SIN”) or passport), marital status, annual income, assets and liabilities, credit history and account transaction information (including payment history and account activity). Personal information generally excludes business contact information such as an individual’s name, business title, business address, business phone number and business fax number.

"Vancity" – means the Vancity Group: “Vancity Group” means Vancouver City Savings Credit Union and all subsidiaries and affiliates of Vancouver City Savings Credit Union from time to time including Vancity Investment Management Ltd., Vancity Enterprises Ltd., Vancity Life Insurance Services Limited, SCU Insurance Services Ltd., Squamish Insurance Agencies Ltd., Vancity Capital Corporation, Vancity Community Foundation, Citizens Bank of Canada, Citizens Trust Company and Inventure Solutions Inc.

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Section 1: Vancity's Accountability

1.0 Vancity is accountable for the protection of members' personal information. While senior management is ultimately accountable for the protection of personal information, the day-to-day monitoring for compliance may be delegated to other staff.

1.1 Vancity’s Chief Privacy Officer bears the overall responsibility for the protection of personal information and compliance with this Code.

1.2 Vancity is committed to ensuring that appropriate security measures are employed in the transfer of personal information. For example, Vancity’s internet banking system is designed to protect your security when banking online. Vancity recommends that members do not transmit personal information by e-mail or wireless devices. Email and wireless communications are not always secure and personal information may be intercepted.

1.3 Vancity is not accountable for any damages suffered when a member transmits personal information through e-mail or wireless communication or when Vancity transmits personal information at the request of the member.

1.4 Vancity has developed policies and procedures to:

  • protect personal information;
  • receive and respond to complaints and inquiries;
  • train staff regarding privacy policies and procedures;
  • communicate privacy policies and procedures to our members.
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Section 2: Identifying the Purposes of Personal Information

2.0 Vancity will communicate the purposes for which personal information is being collected, either orally or in writing.

2.1 Vancity may collect personal information directly from a member, from product and service arrangements you make with Vancity, from credit bureaus and other financial institutions, and any references you have provided to us.

2.2 The purposes for which Vancity collects member personal information [including interactions with Vancity and transactions made with or through Vancity] include:

  • To provide financial services;
  • To understand the retail, financial and banking needs of Vancity’s members;
  • To develop and manage products and services to meet the needs of Vancity’s members;
  • To contact Vancity’s members directly for products and services that may be of interest:
  • To determine the eligibility of Vancity’s members for different products and services;
  • To ensure a high standard of service to Vancity’s members;
  • To periodically conduct surveys in order to enhance Vancity’s provision of services;
  • To meet regulatory requirements;
  • To obtain legal advice from a lawyer;
  • To help protect Vancity and its members against fraud and error;
  • To investigate complaints, fulfill access to information requests and to respond to privacy breaches; and
  • To verify a member's identity.

2.3 We are required to collect our member’s SIN for any products that earn investment income, in order to comply with the Canada Revenue Agency’s income reporting requirements. Providing a SIN for credit products is optional. If a member provides a SIN, Vancity will also use it to identify you and to keep member personal information separate from that of members with a similar name, including information Vancity obtains with the member’s consent from credit reporting agencies. Members may advise Vancity not to use their SIN as an aid to identify the member with credit reporting agencies.

2.4 For a credit card, line of credit, loan, mortgage or other credit facility, or a deposit account with overdraft protection, hold and/or withdrawal or transaction limits, Vancity will obtain information and reports about a member from credit reporting agencies and other lenders at the time of and during the application process, and on an ongoing basis to review and verify the member’s creditworthiness and/or establish credit and hold limits.

2.5 Vancity may monitor and/or record member telephone discussions with Vancity representatives for our mutual protection, to enhance customer service and for quality assurance purposes. Members who prefer not to have their calls recorded may transact business at a branch location, through online banking or through automated banking machines.

2.6 When a member accesses Vancity’s website, Vancity may collect certain information from the member’s computer. Some examples of information Vancity may collect include: information about the types of web browsers used to access the site, the levels of encryption supported by these web browsers and the date and time of access.

2.7 When a member accesses and uses Vancity’s online banking system or other online service products which require the member to sign into the service, or where the member applies for Vancity products and services online, Vancity may collect and use the personal information that the member submits to Vancity. Some examples of personal information Vancity may collect include, but are not limited to, a member’s answers to authentication questions asked for the purpose of ascertaining member identity and ensuring the security of member account information, IP addresses, log-in identification and information regarding the member’s online transactions.

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Section 3: Member Consent

3.0 Vancity will obtain member consent to collect, use or disclose any personal information except where detailed in this Code. Vancity will make reasonable efforts to ensure that members understand how their personal information will be used and disclosed. At any time, you may opt-out of receiving marketing offers from Vancity. You may also limit the personal information shared within Vancity for marketing purposes. To do so, you may visit a Vancity branch, call us at 604-877-7000 or fill in the applicable online form at www.vancity.com

3.1 A member's consent can be express, implied or given through an authorized representative such as a lawyer, agent or broker. A member can withdraw consent at anytime, with certain exceptions (see section 3.4). Vancity, however, may collect, use or disclose personal information without the member's knowledge or consent in exceptional circumstances, including:

  • When such collection, use or disclosure is permitted or required by law;
  • When use of information is for acting in an emergency that threatens an individual's life, health, or personal security;
  • When certain information is publicly available;
  • When Vancity needs to collect a debt from a member; and
  • When Vancity needs to deal with an anticipated breach of law.

3.2 Consent may be given orally, in writing or electronically. For example, consent can be expressed over the telephone when information is being collected, electronically when submitting an agreement, application, or other information, in writing when signing an agreement or application form, by using a product or service, or by indicating by means of a check-off box whether or not consent is granted.

3.3 Vancity obtains your consent to collect personal information directly from you, from product and service arrangements you make with Vancity, from credit bureaus and other financial institutions, and any references you have provided to us.

3.4 Subject to contractual or legal arrangements, members may withdraw or refuse consent provided that Vancity is given reasonable notice. Refusal or withdrawal of consent may prevent Vancity from providing a product or service to the member as in the case where a member is applying for credit and will not provide relevant credit information. Vancity will not unreasonably withhold products or services from members who refuse or withdraw consent, but if information is required by law or required to operate banking systems, Vancity may decline to deal with a member or person who will not consent to the use of such information.

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Section 4: Limits for Collecting, Using, Disclosing, and Keeping Personal Information

4.0 Member personal information will be collected, used or disclosed for the purpose for which it was collected, as described in Section 2.2, or as required or authorized by law. Vancity will not collect, use or disclose personal information for any additional purpose unless Vancity obtains member consent to do so.

4.1 If a member has a product or service where ownership or liability is shared with others (for example, a member who has a multiple party account or a guarantor on their loan), Vancity may share the member’s information with them in connection with the product or service.

4.2 Vancity will not sell member lists or personal information to third parties.

4.3 You agree that Vancity may collect personal information through product or service arrangements you make with us, from credit reporting agencies and other financial institutions, and from any references you have provided to us. You agree that Vancity may share your information with credit reporting agencies, other financial institutions, its employees and Business Partners and your representatives, but only as needed to provide the products and services requested. Our Business Partners may at times be responsible for processing or handling personal information. They are provided only the information necessary to perform the services. In addition, Vancity requires them to protect the information in a manner that is consistent with our privacy policies and security practices. You understand that certain of our Business Partners may be located in other jurisdictions and subject to the laws and regulations of other jurisdictions or countries, such that other countries’ governments, courts or law enforcement agencies may be able to obtain disclosure of your personal information. Only in exceptional circumstances will we disclose information without your consent, and only as permitted or required by law.

4.4 Subject to applicable law, each entity of the Vancity Group may transfer information between each other. This information is shared in order to manage your total relationship with Vancity, administer Vancity’s banking operations, detect fraud and money laundering, collect debts owed to Vancity and market products and services that may be of interest to you.

4.5 Vancity will not share a member’s health or medical information within Vancity, other than to administer an insurance product that the member has with us.

4.6 Vancity will retain member personal information only as long as necessary or expected to be necessary for the identified purposes, or as required by legislation.

4.7 Vancity may disclose personal information related to a financial asset or liability of Vancity along with transfer of the financial asset or liability.

4.8 From time to time, Vancity may acquire new businesses or sell some parts of its businesses or merge or amalgamate part or all of its businesses with other entities. Since personal information associated with any accounts, products or services of the business being purchased or sold or merged with will typically be included in such transactions, Vancity may use or disclose such information to other parties as part of the transaction or to determine whether they wish to proceed with the transaction. Any such disclosure will be subject to appropriate privacy and security safeguards and in compliance with privacy law.

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Section 5: Accuracy

5.0 Vancity will make reasonable efforts to ensure that member personal information is as accurate, complete and current as is required for the purposes for which it was collected. In some cases, Vancity relies on its members to ensure that certain personal information, such as the member's address or telephone number, is current, complete, and accurate.

5.1 Vancity will not routinely update information unless it is necessary to fulfill the purposes for which it was collected or if it is required to maintain an active account.

5.2 Members may request amendments to their records at Vancity in order to ensure the accuracy and completeness of their personal information. If the amendment request pertains to information that remains in dispute, Vancity will note the member's request in the file.

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Section 6: Safeguarding Personal Information

6.0 Vancity is committed to the safekeeping of member personal information in order to prevent its loss, theft and access, disclosure, duplication, use, or modification without member authorization.

6.1 Vancity will employ appropriate security measures, selected based on the sensitivity of the personal information, to protect the personal information. Some examples of physical security measures include: locks, access cards and building security personnel. Some examples of electronic security measures include: passwords, encryption, and personal identification numbers.

6.2 Vancity will use appropriate security measures when disposing of member personal information.

6.3 Access to your information is restricted to authorized employees who have a legitimate business purpose for accessing it. Each employee must sign an agreement stating that maintaining confidentiality is a condition of employment with Vancity. Also, each year, employees certify that they have reviewed our Code of Conduct and will abide by Vancity’s ethical and professional standards which include obligations of confidentiality and privacy. Unauthorized access to and/or disclosure of member information by an employee of Vancity is strictly prohibited.

6.4 Vancity engages in an ongoing process of developing its policies and procedures for protecting member personal information. Changes in technology necessitate that Vancity continually develops, updates, and reviews information protection guidelines, controls, and employee training and security measures to ensure ongoing personal information security.

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Section 7: Availability of Policies and Procedures

7.0 Vancity is open about the policies and procedures it uses to protect member personal information. Information about these policies and procedures will be made available to members either electronically or in written format in plain language within a reasonable time following a member’s request. To ensure the integrity and effectiveness of our security procedures and business methods, Vancity may refuse to disclose certain information.

7.1 This version of Vancity’s Privacy Code was approved by Vancity’s Board of Directors. Vancity will notify you of any substantial changes to this document.

7.2 Vancity will make the following information available:

  • The name, title and address of the person accountable for the policies and procedures and to whom complaints or inquiries can be forwarded;

  • A description of the type of personal information held by Vancity, including a general account of its use;

  • A copy of any brochures or other information that explain the policies and procedures; and

  • An explanation of what personal information is made available to related organizations such as affiliated companies.

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Section 8: Providing Member Access to Personal Information

8.0 Members have a right to access their personal information held by Vancity. Upon request, Vancity will, within a reasonable time period, tell the member what personal information it has, what it has been used for, and to whom it has been disclosed, if applicable. The information will be made available in an appropriate format for members with a sensory disability.

8.1 Vancity may request that members specify the type of information they would like to access and submit a written request to their contact at any Vancity branch. If you require additional assistance with your request for information, you may contact Vancity’s Corporate Privacy Office.

8.2 Vancity requires that members provide personal information to identify themselves to enable Vancity to provide details regarding the existence, use, and disclosure of personal information. Information that you provide to verify your identity will only be used for this purpose.

8.3 Vancity will make the information available within a 30 day time frame, or provide written notice of extension, where additional time is required to fulfill the request.

8.4 When information is not provided within 30 days of the request, Vancity will, no later than 30 days after the date of the request, send a notice of extension to the member, advising of the new time frame, the reasons for extending the time frame and of the right of the member to make a complaint to the Privacy Commissioner of British Columbia regarding the extension.

8.5 The information will be made available at a cost that will vary with the type and amount of information requested. Where a cost will be incurred by the member, Vancity will inform the member of the cost and ask the member whether Vancity should proceed with the request.

8.6 When advising members of the details of Vancity’s prior disclosure of the member’s personal information to third parties, Vancity will not provide details regarding information transfers necessary for the daily provision of products and services to members. For example, transfers to organizations that process debit card purchases, cheque clearing, credit card transactions, and automated banking transactions will not be documented. Upon request, Vancity will provide a list of organizations where member personal information may have been sent.

8.7 If a request is refused, in whole or in part, Vancity will provide written notification to the member of its refusal, reasons for refusal and resources for redress available to the member.

8.8 In certain situations, Vancity may not be able to provide access to any or all personal information about a member. In such cases, Vancity will explain the reasons it will not provide the requested information and identify resources for redress available to the member. Vancity’s reasons for refusing to provide a member with access to their personal information may be that:

  • The personal information is unreasonably costly to provide;
  • The disclosure of the personal information to the member would threaten the life, health or security of another individual;
  • The personal information was generated in a formal dispute resolution process;
  • The personal information discloses the personal information of other individuals;
  • The personal information cannot be disclosed for legal, security or commercial proprietary reasons; or
  • The personal information is subject to solicitor client or litigation privilege.

8.9 If the information is demonstrated to be inaccurate or incomplete, Vancity will amend the information as requested by the member. Where appropriate, Vancity will transmit the amended information to third parties having access to the information in question.

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Section 9: Compliance and Complaints

9.0 Members are to direct any complaints, concerns or questions regarding this Privacy Code in writing to the Corporate Privacy Office. If the Corporate Privacy Office is unable to address the member's concerns, the issue can be referred to the office of the CEO. At any point in this process the member may also write to the Privacy Commissioner of British Columbia.

9.1 Vancity will acknowledge, record and investigate each privacy complaint it receives. Members who submit a written privacy complaint to Vancity, at the address specified in section 9.2, will receive a response from Vancity within a reasonable time period.

9.2 Contact Information:
Vancouver City Savings Credit Union
Corporate Privacy Office
183 Terminal Avenue
Vancouver, B.C.
V6A 4G2

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