Coast Capital Savings Privacy Policy

This Policy applies to Coast Capital Savings (see definition below). This Policy addresses personal information about individuals and does not apply to the information collected, used or disclosed with respect to corporate or commercial entities. However, such information is protected by other Coast Capital Savings policies and practices and through contractual arrangements.

This Policy does not impose any limits on the collection, use or disclosure of the following information by Coast Capital Savings:

• your business contact information;


• publicly available information recognized under PIPA.

In this Policy:

Coast Capital Savings means Coast Capital Savings Credit Union and the Coast Capital Savings Group of Companies. The Coast Capital Savings Group of Companies means all subsidiaries, affiliates and divisions of Coast Capital Savings Credit Union from time-to-time including Coast Capital Insurance Services Ltd., Coast Capital Real Estate Ltd., Coast Capital Equipment Finance, Coast Capital Investments, U-Select Financial and Insurance Services Limited, Shoreline Projects Ltd., Pacific Coast Savings Foundation, Coast Capital Savings Foundation and Wagner, Newell & Associates Inc.

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

"consent" means voluntary agreement to the collection, use and disclosure of personal information for specified purposes. Consent may be express or implied. Express consent can be given orally or in writing, it is unequivocal and does not require any inference on the part of Coast Capital Savings. Implied consent exists when Coast Capital Savings can reasonably infer consent based upon your action or inaction.

"disclosure" means making personal information available to a third party.

"personal information" means information about an identifiable individual but does not include business contact information of an individual. Personal information does not include information that is about corporate or commercial entities. It also does not include information that cannot be associated with a specific individual.

"PIPA" means the British Columbia Personal Information Protection Act S.B.C. 2003, c.63.

"third party" means an individual or organization other than Coast Capital Savings and you.

"Privacy Officer" means an individual designated by Coast Capital Savings who is accountable for Coast Capital Savings compliance with this Policy and who can be contacted as set out at the end of this Policy.

"use" means the treatment and handling of personal information by and within Coast Capital Savings.

Coast Capital Savings is accountable and responsible for personal information under its control. Coast Capital Savings has designated a Privacy Officer who is accountable for Coast Capital Savings compliance with this Policy.

Accountability for Coast Capital Savings compliance rests with the Coast Capital Savings Credit Union Chief Executive Officer who may delegate the day-to-day accountability to the Privacy Officer. Other individuals within Coast Capital Savings may be accountable for the day-to-day collection and processing of personal information or to act on behalf of the Privacy Officer. Ultimate accountability rests with the Coast Capital Savings Credit Union Board of Directors.

Coast Capital Savings will adopt procedures to protect personal information, receive and respond to complaints and inquiries, train staff regarding policies and procedures and communicate policies and procedures to you.

When collecting information, Coast Capital Savings will state the purpose of collection and will provide, on request, contact information for the Privacy Officer who can answer questions about the collection.

Coast Capital Savings collects your personal information for the following reasons:

• to provide and administer products and services requested and to use/disclose the information for any purpose related to the operation of accounts and the provision of requested products and services;
  
• to determine your financial situation including obtaining credit reports;
  
• to provide information to third party suppliers of products and services, such as data service providers, cheque printers, card manufacturers, etc.;
  
• to provide the information to credit bureaus and other financial institutions to update credit information;
  
• to protect Coast Capital Savings, yourself and others from fraud and error and to safeguard the financial interests of Coast Capital Savings;
  
• to authenticate your identity;
  
• to provide information to anyone working with or for Coast Capital Savings as needed for the operation of an account or the provision of requested products and services;
  
• to collect debts owed to Coast Capital Savings;
  
• to manage or transfer assets or liabilities of Coast Capital Savings, such as in the case of acquisitions and mergers, loans syndications and securitizations or sales of mortgages; and
  
• to comply with legal and regulatory requirements.

Coast Capital Savings is required by law to obtain your social insurance number to report interest on deposits and dividends on shares and other investment income to Canada Customs & Revenue Agency.

The above collections, uses and disclosures are a necessary part of your relationship with Coast Capital Savings.

Other uses:

• The entities comprising the Coast Capital Savings Group of Companies may use your personal information to offer their additional or alternative services to you and may add it to client lists which they prepare and use for this purpose;
  
• Coast Capital Savings may share personal information within the Coast Capital Savings Group of Companies and with other Coast Capital Savings Credit Union authorized suppliers and agents which may offer their services to you;
  
• Coast Capital Savings may use your social insurance number as an aid to identify you with credit bureaus and other financial institutions for credit history file matching purposes;
  
• Coast Capital Savings may contact you for survey purposes.

You may instruct Coast Capital Savings to refrain from using or sharing information in the four ways described above at any time by providing written notification to the Coast Capital Savings Privacy Officer. Coast Capital Savings acknowledges that the sharing of information in the four ways described above is at your option and you will not be refused credit or services merely because you advised Coast Capital Savings to stop using or sharing information in these ways.

When personal information that has been collected is to be used for a purpose not previously identified, the new purpose shall be identified prior to use and consent for same shall be obtained from you unless the use is authorized or required by PIPA or other law.

Coast Capital Savings will obtain your consent to collect, use or disclose personal information except where Coast Capital Savings is authorized or required by PIPA or other law to do so without consent. For example, Coast Capital Savings may collect, use or disclose personal information without your knowledge or consent where:

• Coast Capital Savings is collecting or paying a debt; or
  
• Coast Capital Savings is obtaining legal advice; or
  
• Coast Capital Savings reasonably expects that obtaining consent would compromise an investigation or proceeding; or
  
• Coast Capital Savings is obtaining information under circumstances where a person is seriously ill or mentally incapacitated.

Your consent can be expressed, implied or given through an authorized representative such as a lawyer, agent or broker.

Consent may be provided orally, in writing, electronically, through inaction (such as when you fail to notify Coast Capital Savings that you do not wish your personal information collected/used/disclosed for optional purposes following reasonable notice of same), action, or otherwise. For example, oral consent could be expressed over the telephone when information is being collected; electronically when submitting an agreement, application or other information; or in writing when signing an agreement or application form.

You may withdraw consent at any time, subject to legal or contractual restrictions, provided that reasonable notice of withdrawal of consent is given to Coast Capital Savings. On receipt of notice of withdrawal of consent, Coast Capital Savings will inform you of the likely consequences of the withdrawal of consent, which may include the inability of Coast Capital Savings to provide certain products or services for which that information is necessary.

Coast Capital Savings will limit collection of information to that which is reasonable and necessary to provide a product or service and which is reasonable and necessary for the purposes consented to by you. Coast Capital Savings will also collect information as authorized by PIPA or other law.

Your personal information will only be used or disclosed for the purposes set out above and as authorized by PIPA and other law.

Coast Capital Savings will keep personal information used to make a decision affecting an individual for at least one year after using it to make the decision.

Coast Capital Savings will destroy, erase or make anonymous documents or other records containing personal information as soon as it is reasonable to assume that the original purpose is no longer being served by retention of the information and retention is no longer necessary for legal or business purposes.

Coast Capital Savings will take due care when destroying personal information so as to prevent unauthorized access to the information.

Coast Capital Savings will make a reasonable effort to ensure that personal information it is using or disclosing is accurate and complete. In some cases, Coast Capital Savings relies on you to ensure that certain information, such as your address or telephone number, is current, complete and accurate.

If you demonstrate the inaccuracy or incompleteness of personal information, Coast Capital Savings will amend the information as required. If appropriate, Coast Capital Savings will send the amended information to third parties to whom the information has been disclosed.

When a challenge regarding the accuracy of personal information is not resolved to your satisfaction, Coast Capital Savings will annotate the personal information under its control with a note that the correction was requested but not made.

Coast Capital Savings protects the personal information in its custody or control by making reasonable security arrangements to prevent unauthorized access, collection, use, disclosure, copying, modification, disposal or similar risks.

Coast Capital Savings will take reasonable steps, through contractual or other reasonable means, to ensure that a comparable level of personal information protection is implemented by the suppliers and agents who assist in providing services to you. Some specific safeguards include:

• physical measures such as locked filing cabinets;
  
• organizational measures such as restricting employee access to files and databases as appropriate;
  
• electronic measures such as passwords and firewalls;
  
• regular reviews of processes in place to safeguard personal information; and
  
• investigative measures where Coast Capital Savings has reasonable grounds to believe that personal information is being inappropriately collected, used or disclosed.

Confidentiality and security are not assured when information is transmitted through e-mail or other wireless communication. Coast Capital Savings will not be responsible for any loss or damage suffered as a result of a breach of security and/or confidentiality when you transmit information to Coast Capital Savings by e-mail or other wireless communication or when Coast Capital Savings transmits such information by such means at your request.

Coast Capital Savings is open about the policies and procedures it uses to protect your personal information. Information about these policies and procedures will be made available in writing and electronically. However, to ensure the integrity of our security procedures and business methods, Coast Capital Savings will not disclose sensitive information about its policies and procedures.

Coast Capital Savings will make available a description of the type of personal information held by Coast Capital Savings, and a general description of its use and disclosure.

You have a right to access your personal information held by Coast Capital Savings.

Your information, such as copies of statements, transaction slips and account agreements will be provided upon request and authentication of identity.

Upon written request and authentication of identity, Coast Capital Savings will provide you with your other personal information under its control, information about the ways in which that information is being used and a description of the individuals and organizations to whom that information has been disclosed.

Coast Capital Savings may charge a reasonable fee for providing information in response to a PIPA access request and will provide an estimate of any such fee upon receiving an access to information request. Coast Capital Savings may require a deposit for all or part of the fee.

Coast Capital Savings will make the information available within 30 days or provide written notice where additional time is required to fulfil the request.

In some situations, Coast Capital Savings may not be able to provide access to certain personal information. This may be the case where, for example, disclosure would reveal personal information about another individual, the personal information is protected by solicitor/client privilege, the information was collected for the purposes of an investigation or where disclosure of the information would reveal confidential commercial information that, if disclosed, could harm the competitive position of Coast Capital Savings. Coast Capital Savings may also be prevented by law from providing access to certain personal information.

Where an access request is refused, Coast Capital Savings will notify you in writing, document the reasons for refusal and outline further steps which are available to you.

Coast Capital Savings will, on request, provide information regarding its complaint procedures.

Any inquiries, complaints or questions regarding this Policy should be directed in writing to the Coast Capital Savings Privacy Officer.

Coast Capital Savings will give appropriate notice of any amendments to this Policy.

Contact Information:

Privacy Officer

Coast Capital Savings Credit Union

Administration Office

15117-101 Avenue

Surrey, BC

V3R 8P7