Your Privacy is Protected
At HLC Home Loans Canada, an important part of our commitment to provide you with service excellence is our respect for your right to privacy. (In this policy, "HLC" means HLC Home Loans Canada and "CIBC group" means CIBC and its subsidiary companies.)
Keeping our clients' information and affairs in strict confidence is a cornerstone of HLC's business. The range of products and services we offer our clients continues to expand, and the technology we use continues to change. But, no matter how our business changes, we'll always protect your privacy.
Our policies and procedures which we practice in order to protect your privacy are in place across HLC.
In the following pages we describe these policies and procedures and how we put them into practice so that you have control over how we collect, use and disclose your information.
Protecting your Privacy Means:
- we keep your information and the business you do with us in strict confidence
- your information is not sold
- you have control over how we obtain, use, and give out information about you
- you have access to the information we have about you
- we respect your privacy when we market our products and services
Our Privacy Policies Protect All of Our Clients
When you first become a HLC client and whenever you apply for more products and services, we let you know that:
- besides your name, address and telephone number, we need information to:
- establish your identification
- protect you and us from error and fraud
- understand your needs and eligibility for products and services
- recommend particular products and services to meet your needs
- provide ongoing service
- comply with legal requirements
- we may verify some of the information you give us with your employer or your references
- we may offer other products that are suitable to you
- we will not refuse you any other product or service on the basis of any health information you may have given us when applying for insurance products offered through us
We may review and analyze your use of products and services, to help protect you from unauthorized use of your accounts, to help us serve you better, and to bring other products and services to your attention which we feel will be of benefit to you. We also collect and analyze information from other sources for the same purposes.
Certain information, such as a driver's license, although convenient for identification, is voluntary. It is up to you whether you want to provide those or some other suitable identification, subject to any legal requirements.
We collect, use and disclose personal information only for purposes that a reasonable person would consider appropriate in the circumstances.
Your Information is Obtained or Used Only With Your Consent
We obtain your consent before we:
- check your employment
- obtain a credit report
- offer you other products and services
- send you information about products and services by means of direct marketing
- provided it is legally permitted, share your information in confidence within the CIBC group
- obtain, use or disclose to other persons, information about you unless we are obliged to do so by law or to protect our interests
- use your information in any way we didn't tell you about previously.
We Ask For Your Consent Before Using Your Social Insurance Number
When we obtain a report and update your information with a credit bureau, your SIN is the best way to make sure that the information actually refers to you. Wrong information could lead us to draw wrong conclusions about you. You should be aware, though, that providing us your SIN for use this way is voluntary for you. If you choose not to give us your SIN when its collection is optional, this by itself will not prevent you from getting any products or services.
Your Consent Can Be Express Or Implied
Express consent can be verbal or written. For example, when you sign a credit application you are giving your written consent for us to obtain a credit report.
You imply consent when we can reasonably conclude that you've given consent by some action you've taken, or when you decide not to take action. If we give you an opportunity to tell us you don't want direct marketing material and you don't tell us that you don't want us to send it, we can conclude that you have no objection.
We will rely on your implied consent to use and disclose identifying information about you, such as your name and address.
You Can Withdraw Your Consent After You've Given It
You can withdraw your consent any time after you've given it to us, provided there are no legal requirements to prevent this. However, in order to maintain the integrity of the credit reporting system, we do have to update your credit information with the credit bureau as long as you have credit with us. Your consent for this purpose cannot be withdrawn during this time.
If you don't consent to certain uses of information, or if you withdraw your consent, we may not be able to provide you with a particular product or service. If so, we'll explain the situation to you to help you with your decision.
We share information within the CIBC group
We may share information about you within the CIBC group for legal and regulatory purposes, to manage credit risk and other business risks, and to ensure we have correct and up to date information about you, such as your current address, date of birth, etc. You may not withdraw consent for this sharing.
We may also share your information to better manage your total relationship with the CIBC group and enable other members of the CIBC group to bring suitable products and services to your attention, such as mutual funds and brokerage accounts. CIBC will share your information within the CIBC group for these purposes unless prohibited by law or you tell us not to.
We ask for your consent before sharing information with other people.
There are some exceptions to the rules outlined in the above sections. For example, we may collect, use or disclose information without your consent if we:
If we use an outside supplier to do work for us.
At times we may use outside suppliers to do work for us involving some of your information. For example, we may use suppliers to print statements and chequebooks, conduct telemarketing, collect accounts or process transactions on our behalf. We select suppliers carefully and insist they have privacy and security standards that meet HLC's strict requirements. Similarly, your payment transactions will be processed through payment systems or networks operated by others such as Visa, the Interac Association, or the Canadian Payments Association. We may share your information with these operators on a confidential basis to process transactions, provide client service, promote the service and for other reasonable purposes.
Must disclose information for legal reasons
We may be compelled to release information by a court of law, or other legal or regulatory authority. If so, our policy is to release information only to the extent that we have to.
Have to protect the interests of HLC
In certain circumstances, HLC may have to collect, use or release information for its protection. For example, we may do so when collecting an overdue account, when realizing on security pledged for a loan, or to detect or prevent fraud.
We may share information for business transactions
From time to time, we may sell parts of our business, sell or securitize assets, or merge or amalgamate parts of our business with other parties. Since client and account information will normally be a part of the transaction, we may disclose this information to other parties in the transaction, as part of due diligence and on completion of the transaction. We require that the other parties keep this information confidential and limit its use to the purposes of the transaction.
Information may be located outside of Canada
HLC, its outside suppliers and other third parties to whom we disclose information under this policy (such as credit bureaus) may perform activities outside of Canada. As a result, your information may be securely used, stored or accessed in other countries and may be subject to the laws of those countries. For example, information may be disclosed in response to valid demands or requests from government authorities, courts, or law enforcement in these countries.
We Protect Your Information From Error, Loss and Unauthorized Access
Our employees who have access to your information are made aware of how to keep it confidential. Each employee must sign an agreement stating that maintaining confidentiality is a condition of employment with HLC.
Our computer security specialists build security into all our computer systems.
This protects your information at all times, when it is stored in data files or handled by our employees. Our systems also protect your information when it is transmitted.
Your Information Is Destroyed When It Is No Longer Needed
We keep your information only so long as we need it for the products and services you're using, to offer you products and services when you are a client and for a reasonable time thereafter, or to meet any legal requirements. We have retention standards which meet these requirements. We destroy your information when it is no longer needed, or we remove your name from the information.
You Can See and Verify the Accuracy of Your Information
You can check your information to verify, update and correct it, and to have any obsolete information removed. We may ask you to put your request in writing.
There's no charge for verifying or correcting your information. Depending on the circumstances, there may be a charge if you want a copy of records which we have already given you. We will let you know in advance if there is a charge.
If you have a sensory disability, we will give you access to your personal information in any alternative format you request if we already have it in that format or if its conversion into that format is reasonable and necessary in order for you to be able to exercise your rights under applicable legislation.
It may not be appropriate for us to release certain information directly to you.
If we have obtained information about you from other people, upon your request, we'll let you know the person we got it from.
You Can Find Out to Whom We've Given Information About You
If you ask, we will let you know the names of outside companies or organizations we've given information to. This won't include information given to outside companies we've used to do work for us, such as cheque printers.
We Respond to Your Request Promptly
We'll deal quickly with your request to see your information, and always respond to you within 30 days. If we need to extend the time, or we have to refuse your request, we'll tell you why, subject to any legal restrictions and we'll notify you of the new deadline, the reasons for the extension, and your rights under applicable legislation respecting the extension.
We Correct Your Information
Whenever possible, we'll correct any information which we may have given to an outside organization.
If a third party, such as a credit bureau, has given us information which you tell us is wrong, we'll give you the name and address of that party so that you can correct the information.
We Protect Other People's Privacy When We Make Information Available to You
There may be files that include information about you and other clients, or that have information confidential to HLC or are the property of HLC. Because we must protect everyone's confidentiality and legal rights we cannot make these files available to persons outside of the HLC. However, we will make available to you any factual information about you contained in such files.
We Monitor Our Compliance With the HLC Privacy Policies
We have procedures in place to assist our employees in the practice of the HLC privacy policies. Our internal auditors monitor the practice of these policies on a regular basis, and report their findings to a committee of the Board of Directors of HLC.
We Are Committed to Upholding the HLC Privacy Policies
If you have any questions or complaints about our privacy policies, or about how we are living up to them, let us know right away.
Ontario – Head Office
55 Yonge Street, 7th Floor
1809 Barrington Street, Suite 1504
Halifax, Nova Scotia
1250 René-Lévesque Ouest, bureau 3035
333-11 Ave SW, Suite 800
400 Burrard Street, 5th Floor
Vancouver, British Columbia
Questions or Complaints?
At HLC Home Loans Canada we strive to assure that every one of our client's expectations is satisfied. Our mission is in place to guarantee only the highest quality of client service. If at any time you feel that you have not been satisfactorily dealt with, you may contact us to voice your concerns. We will ensure that your issues will be handled accordingly. Not only are we committed to affirm that client service is of the utmost importance to our organization, but we will also assist you in resolving your concerns with the guarantee that your questions or issues will be addressed.
To address your concerns, you can contact Info@HLC at 1-866-452-1821 or email us at Info@HLC (your email will be kept confidential). We will consult with the appropriate Regional Vice Presidents to address your concerns. If these options do not satisfy your concerns you can further direct your issues by linking to Questions or Complaints.
If the above steps fail to resolve your concern you may also contact the:
Office of the Privacy Commissioner of Canada:
Place de Ville
112 Kent Street, 3rd Floor
Call toll free at 1-800-282-1376