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 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 based on the Canadian Standards Association (CSA) Model Code for the protection of personal Information (CAN/CSA-Q830-96) and the Federal Personal Information Protection and Electronic Documents Act (PIPEDA). Based on these models, 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

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" - means Vancouver City Savings Credit Union and the Vancity Group of Companies: Vancity Group of Companies means all subsidiaries and affiliates of Vancity from time to time including Vancity Investment Management Ltd., Vancity Enterprises Ltd., Real Assets Investment Management Inc., Vancity Insurance Services Ltd., Vancity Capital Corporation, Citizens Bank of Canada, Citizens Trust Company and Inventure Solutions Inc.;

"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.

"Member" - is any individual who uses, or applies to use, financial services with Vancity.

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

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

"Personal Information" - information about an identifiable individual that is recorded in any form; excluding the individual's name, business title, business address and business phone number.

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

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 sensitive information. However, when using e-mail or wireless communication, Vancity advises members that complete confidentiality and security are not assured.

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: protect personal information; receive and respond to complaints and inquiries; train staff regarding the policies and procedures; communicate the policies and procedures to our members.

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 for the following reasons only:

• To provide financial services;
• To understand the financial and banking needs of our members;
• To develop and manage products and services to meet the needs of our members;
• To contact our members directly for products and services that may be of interest:
• To determine the eligibility of our members for different products and services;
• To ensure a high standard of service to our members;
• To meet regulatory requirements;
• To verify a member's identity.

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.

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 3.3). Vancity, however, may collect, use or disclose personal information without the member's knowledge or consent in exceptional circumstances:

• 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 we require legal advice from a lawyer
• When we need to collect a debt from a member
• When we need to deal with an anticipated breach of law.

3.2 Consent may be given orally, in writing, or electronically. For example, depending on the sensitivity of the information, 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; when using a product or service; when indicating by means of a check-off box whether or not consent is granted.

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.

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.

5.0 Member information will only be used or disclosed for the purpose for which it was collected. 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 may periodically use member personal information to conduct member surveys in order to enhance our provision of financial services. If an outside body is employed to conduct research on behalf of Vancity, or provide other services that require access to member information, Vancity will ensure that appropriate security undertakings, such as confidentiality clauses in contractual arrangements, are employed to protect the transfer and use of personal information.

5.3 Subject to applicable law, each member of the Vancity Group of Companies may transfer information between each other.

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.

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.

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, for example, 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.

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 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.

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.

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.

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 Commissioner 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.

10.0 Members are to direct any complaints, concerns or questions regarding this privacy code in writing to the Privacy Officer. If the Privacy Officer 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.

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