Privacy Policy

Vancity Privacy Code

At Vancity (See definition below) we understand that privacy is a critical issue for all our members. Our privacy code outlines our principles and procedures regarding the privacy, confidentiality and security of member personal information.

This code outlines the principles Vancity applies when protecting members' privacy. We believe that ensuring the accuracy, confidentiality, and security of the information we hold about you is more than simply a legal requirement, it is an ethical obligation.

This code is 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 documents, we have tailored our own ten privacy principles to meet the specific needs and expectations of our membership.

Scope
Definitions
Section 1: Vancity's Accountability
Section 2: Identifying the Purposes of Personal Information
Section 3: Member Consent
Section 4: Limits for Collecting Personal Information
Section 5: Limits for Using, Disclosing, and Keeping Personal Information
Section 6: Accuracy
Section 7: Safeguarding Personal Information
Section 8: Availability of Policies and Procedures
Section 9: Providing Member Access to Personal Information
Section 10: 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.

Top

Definitions

"Business Partner" - any entity contracted to work on Vancity's behalf, or provide products and services to Vancity members and/or Vancity.

"Collection" - the act of gathering, acquiring, or obtaining personal information from any source, including third parties, by any means.

"Consent" - involves voluntary agreement with what is being done or proposed. 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.

"Disclosure" - the act of making personal information available to others outside of Vancity.

"Member" - is an individual who uses, or applies to use financial services with Vancity and includes members who are a shareholder/owner of Vancity as well as individuals who are customers of Vancity but not necessarily a shareholder/owner.

"Personal Information" - information about an identifiable individual that is recorded in any form including name, address, date of birth, identification (such as a valid driver's license or passport), marital status, annual income, assets and liabilities, credit history, and information about your transactions (including payment history and account activity). In general, personal information excludes business contact information such as an individual's name, business title, business address, business phone number, and business fax number.

"Third Party" - an individual or organization other than Vancity and the member.

"Use" - the treatment and handling of personal information by and within Vancity.

"Vancity" - means Vancouver City Savings Credit Union and the Vancity Group: Vancity Group means all subsidiaries and affiliates of Vancity from time to time including Vancity Investment Management Ltd., Vancity Enterprises Ltd., Inhance Investment Management Inc., Vancity Insurance Services Ltd., 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.

Top

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 The overall responsibility for the protection of personal information, and compliance with this code rests with Vancity's Privacy Officer.

1.2 Vancity is committed to ensuring that the 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 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 information at the request of the member.

1.4 Vancity has developed policies and procedures to:

Top

Section 2: Identifying the Purposes of Personal Information

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

2.1 Vancity collects member personal information, including interactions with Vancity and transactions made with or through Vancity, only to:

Top

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 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 a form online at www.vancity.com.

3.1 A member's consent can be expressed, implied, or given through an authorized representative such as a lawyer, agent or broker. A member can withdraw consent at any time; with certain exceptions (see section 3.3). Vancity, however, may collect, use or disclose personal information without the member's knowledge or consent in exceptional circumstances:

3.2 Consent may be given orally, in writing, or electronically. For example, depending on the sensitivity of the information, consent can be expressed

3.3 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.

Top

Section 4: Limits for Collecting Personal Information

4.0 Vancity will only collect personal information for the purposes identified. Vancity will use methods that are lawful and will not collect information indiscriminately.

4.1 When you access Vancity's website, Vancity may collect certain information from your computer. For example, Vancity's web servers may collect 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 at which the site was accessed. Additional information may be collected when you use Vancity's online banking system or apply for products and services.

Top

Section 5: Limits for Using, Disclosing, and Keeping Personal Information

5.0 Member information will only be used or disclosed for the purpose for which it was collected, as described in Section 2.1. Vancity will not use personal information for any additional purpose unless Vancity seeks member consent to do so.

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

5.2 Vancity provides limited information to business partners; for example, cheque printers, ATM processing companies, and loyalty programs who provide products and services to Vancity and/or Vancity members. Certain business partners may be subject to the laws and regulations of other jurisdictions or countries. Vancity's business partners are carefully selected to ensure their privacy and security standards meet Vancity's strict requirements. Vancity only provides information to business partners that is necessary to perform their specialized services. Each business partner is contractually obligated to keep information provided by Vancity confidential and to use it only for the requested services.

5.3 Subject to applicable law, each member 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.

5.4 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.

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

Top

Section 6: Accuracy

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

6.1 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.

6.2 Members may request amendments to the 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 opinion in the file.

Top

Section 7: Safeguarding Personal Information

7.0 Vancity is committed to the safekeeping of member personal information in order to prevent its loss, theft, unauthorized access, disclosure, duplication, use, or modification.

7.1 Depending on the sensitivity of the information, Vancity will employ appropriate security measures to protect the information. The measures may include the physical security of offices and data centres, and electronic security measures such as passwords, encryption, and personal identification numbers.

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

7.3 The development of Vancity's policies and procedures for the protection of personal information is an ongoing process. Changes in technology necessitate that Vancity continually develops, updates, and reviews information protection guidelines and controls to ensure ongoing information security.

Top

Section 8: Availability of Policies and Procedures

8.0 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. However, to ensure the integrity of our security procedures and business methods, Vancity may refuse to publicly disclose certain information.

8.1 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.

8.2 Vancity will make the following information available:

Top

Section 9: Providing Member Access to Personal Information

9.0 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 is being used for, and to whom it has been disclosed if applicable and within the time period for which records are available. The information will be made available in an appropriate format for members with a sensory disability.

9.1 Members may be asked to be specific about the information they would like to access and to submit their request in writing to their contact at any Vancity branch. If you require assistance with your request for information, you may contact Vancity’s Corporate Privacy Office.

9.2 Members will be required to provide personal information to identify themselves to enable Vancity to provide an account of the existence, use, and disclosure of personal information. Information that you provide to verify your identity will only be used for this purpose.

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

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 limit, the reasons for extending the time limit and of the right of the member to make a complaint to the Privacy Commissioner of British Columbia or in the case of Citizens Bank of Canada, the Privacy Commissioner of Canada regarding the extension.

9.4 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 request further direction from the member on whether or not Vancity should proceed with the request.

9.5 When reporting to members to whom their information has been disclosed, Vancity will not document 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.

9.6 If a request is refused, Vancity will notify the member in writing, documenting the reasons for refusal and resources for redress available to the member.

9.7 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 recourse available to the member. The reasons for not providing information may include that it is unreasonably costly to provide, information that would threaten the life or security of another individual, information generated in a formal dispute resolution process, information that contains references to other individuals, information that cannot be disclosed for legal, security, or commercial proprietary reasons, and information that is subject to solicitor-client or litigation privilege.

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

Top

Section 10: Compliance and Complaints

10.0 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 or in the case of Citizens Bank of Canada, the Privacy Commissioner of Canada.

10.1 Vancity will acknowledge, record and investigate each privacy complaint it receives. You will be contacted by Vancity within a reasonable time period.

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

Top