Credit Canada
A not for profit charity since 1966
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Privacy policy.
Credit Canada Privacy Policy.
Accountability
Identifying the Purposes for Collecting and Using Personal Information
Getting the Client's Consent
Limits for Collecting Personal Information
Limits for Disclosing and Retaining Personal Information
Keeping Personal Information Accurate
Safeguarding Personal Information
Individual Access to Personal Information
Handling Individual Complaints and Questions
Introduction.
This policy applies to the collection, use, disclosure and management of the personal information of clients of CC.
1. Accountability
The Executive Director of CC is accountable for compliance with these policies and procedures regarding the manner in which CC collects, uses, discloses and otherwise manages personal information.
The Executive Director is appointed as the Privacy Officer for CC.
CC is responsible for personal information in its custody and control.
2. Identifying the Purposes for Collecting and Using Personal Information
CC collects and uses personal information to provide advice and information on personal money management issues and to provide advice, information and options for debt repayment to CC clients by dealing with their various creditors. The personal information collected by CC includes information on clients' debts, income, assets, living expenses, employment situation, general financial status and their relationships with various creditors.
CC also uses the aggregate demographic information from the personal information collected to identify services and programs that may benefit the communities we serve; to target our marketing and awareness programs; and to maintain the ongoing financial support and cooperation of our stakeholders. No individual can be identified through this information.
CC personnel are trained to explain the purposes of collecting the information to any client who asks for an explanation. The purpose for which personal information is collected and used by CC personnel is communicated to each client at or prior to the time of collection.
3. Getting the Client's Consent
CC will not collect, use or disclose a client's personal information without the express consent of the client.
4. Limits for Collecting Personal Information
CC personnel collect personal information about individuals only where such individual is a client or potential client of CC. Our clients' personal information is not used or disclosed for purposes other than those for which it was collected, except with the consent of the client or as required by law.
5. Limits for Disclosing and Retaining Personal Information
CC discloses personal information only for the purposes for which it was collected. It keeps information for as long as it is required for the stated purposes.
CC retains the hardcopy client assessment files for 24 months and then proceeds to have such files shredded by a licensed and bonded third party. Debt management program file documentation is retained for a period of seven years from the date the debt management program is successfully completed and or closed, after which the files are shredded in the same manner as the client assessment files.
CC electronic file retention policy provides that electronic files regarding debt management programs are kept active until the debts under administration have been paid in full or, alternatively until there is a default in payment or a request by our client to self-administer the repayment of their debts. After this time, the electronic files remain active for a further seven years. After this time the files are permanently deleted from CC's system.
Electronic files regarding financial counselling only sessions are kept active in our system for a maximum of two years from the date of the last counselling session. The electronic files are permanently deleted on the first day of the month following the two-year period from the date of the last financial counselling session.
Personal information that is no longer required to fulfill the identified purposes or that is not required to be retained pursuant to any applicable law is destroyed, erased or made anonymous. CC reviews the personal information in its custody and control on a periodic basis in order to ensure that personal information no longer required to be retained has been destroyed, erased or made anonymous.
6. Keeping Personal Information Accurate
CC ensures, to the best of its ability, that the information it holds is accurate, complete, current and relevant to the identified purposes.
CC maintains strict confidentiality agreement with those who have access to the personal information being held by CC. Any corrections to the information can be given to those parties. CC recognizes that it is crucial that creditors of its clients have current and accurate information in order to make important decisions regarding the acceptance of our client debt management programs as well as other credit decisions.
7. Safeguarding Personal Information
CC ensures that personal information is stored in electronic and physical files that are physically secure. Security measures include storage of files in locked filing facilities when not in use; secure locks on the offices of CC and its satellite offices. Electronic files are protected by encryption software. Staff passwords to access such electronic files are controlled and employ high level encryption practices.
Distribution of personal information regarding clients is restricted to the employees of CC and any creditors for whom a debt management program is entered into in respect of CC clients.
The employees of CC sign a Confidentiality Agreement and will abide by these privacy policies and procedures.
Physical CC files containing personal information are shredded under the supervision of CC employees. Deleted electronic files will be permanently removed from the system, as discussed in section five (5).
8. Individual Access to Personal Information
Upon written request, CC will provide an individual with confirmation as to whether CC has personal information about them, what the information is, what it is being used for and to whom the information has been disclosed.
Individuals should send their written request for access, with contact information and enough information about themselves to identify them to the Executive Director of CC.
CC will respond within thirty (30) days of receiving any access request at no cost to the individual.
If the individual can provide proof of an error in the personal information held by CC, then CC will amend the information and where appropriate, send the corrected information to others who have used the incorrect information.
If CC denies the individual's request for access, it will state the reasons for denial.
9. Handling Individual Complaints and Questions
Individuals may send any complaints regarding CC's compliance with its own privacy policies and procedures to the Executive Director of CC. The Executive Director or designated staff will investigate the complaint and respond to the individual.
If the individual's complaint is justified, CC will change its policies and procedures related to the matter so that other individuals will not experience the same problem.
Credit Canada, the operating name for Credit Counselling Service of Toronto, is a not-for-profit charitable service that has assisted thousands of people with credit counselling and debt management programs since 1966. Our agency is a Charter Member of Credit Counselling Canada, the Ontario Association of Credit Counselling Services and affiliated with the National Foundation for Consumer Credit (NFCC).
