Personal information protection
Personal Information Protection
Nothing is more important to Peoples Trust than the security of your personal information. If you have any concerns about your personal or financial information with Peoples Trust, or there has been any evidence or unusual activity to suggest you may be it at risk of fraud or identity theft, report the incident to us immediately at 1-855-286-8505.
Peoples Trust Company is committed to protecting the privacy and security of customer personal information (including persons holding securities in respect of which we act as Trustee). This policy explains the types of personal information we collect, how it is used, and the steps we take to ensure customer personal information is handled appropriately.Our policies and practices have been designed to comply with the federal Personal Information Protection and Electronic Documents Act (PIPEDA) or corresponding provincial privacy acts, as applicable (collectively “Privacy Laws”).
What is Personal Information?
Personal information is any information about an identifiable individual including unrecorded information or information recorded in any form. Personal information includes such things as residential address, age, income, date of birth, ethnic origin, medical history, credit history, payment records and credit card number. The following types of information about individuals are not considered personal information:
Business contact information (e.g. business phone and fax number, address and e-mail) (except in Quebec)
Public telephone directory information, where the subscriber can refuse to be listed
Professional and business directories available to the public
Certain public registries and court records
Certain other publicly available printed and electronic publications
Our commitment to privacy is governed by the following privacy principles:
1. We are accountable to you
Peoples Trust is responsible for all personal information in its possession or control, including any personal information that is provided to us by our agents or transferred to third parties for processing, storage or other purposes. We have a designated Privacy Officer who is accountable for compliance with this policy.
2. We tell you how we use your personal information
In most situations, the reason why we are collecting personal information and its use is obvious from the context. In other situations, Peoples Trust identifies the purpose for which your personal information is collected and its use. We do this explicitly or by implication where the purpose of using such information is reasonably apparent to you by virtue of its nature or the context in which it is being collected.
3. We obtain your consent to collect, use or disclose your personal information
Peoples Trust obtains your consent to collect, use or disclose personal information. The method of obtaining consent will be appropriate to the type of personal information being collected, used or disclosed.
Peoples Trust will obtain your express consent (verbal, written or electronic agreement) to collect, use or disclose sensitive personal information such as medical data or personal financial information.
Peoples Trust will rely on implied consent to collect use or disclose your personal information where one or more of the following apply:
A customer relationship already exists
Express consent has previously been given for the same or similar use of the personal information
Where the intended use of the information is reasonably obvious from the context in which it is obtained and you provide the information voluntarily
In some circumstances permitted by Privacy Laws, we will collect, use and disclose your personal information without your consent, including situations of urgency when it is impractical to obtain your consent, when Peoples Trust or its affiliates need to collect monies or in connection with an investigation or proceeding by Peoples Trust or a law enforcement agency.
You can change your consent to any collection, use or disclosure of your personal information at any time on reasonable written notice, subject to permitted or required exceptions under Privacy Laws (e.g. where withdrawal of consent would frustrate a legal obligation such as collecting on a loan). While Peoples Trust will make reasonable attempts to provide alternative arrangements, in some situations, withdrawal of consent may also deprive you of a benefit or service. To change your consent to collection, use or disclosure of personal information about you, refer to the “How to Contact Us” section below.
4. We limit collection of your personal information
Peoples Trust collects personal information required to provide our products and services, including collections. We will collect personal information only by reasonable and lawful means. Examples of why we collect personal information include:
Communicating with you about your loans, securities or deposits
Considering applications for credit
Processing and keeping track of transactions and reporting back to you
Protecting against theft, fraud and error
Analysis of information to determine that relevant services are offered to those who may need them
Providing products and services requested by you
Advising you of products and services that Peoples Trust believes will be of interest to you and provide value to you
To monitor security
To comply with legal and governmental requirements
5. We limit use, disclosure and retention of your personal information
Peoples Trust uses and discloses your personal information only for the purposes for which it was collected unless permitted by Privacy Laws. Peoples Trust does not sell or rent personal information to any organization or person for any reason.
We disclose personal information to third party organizations to assist in providing customers with services or to obtain services to assist us in our business. If your personal information is shared with third parties, Peoples Trust will require them to comply with this policy when dealing with your personal information.
Peoples Trust regularly receives and sends customer personal information to and from its deposit-taking agents as part of carrying on its business and to ensure proper service and accounting procedures are followed.
Peoples Trust retains your personal information only as long as it is required for our business relationship or as required by applicable laws.
6. We strive to keep your personal information current and accurate
Peoples Trust endeavours to keep your personal information up to date, accurate and relevant for its intended use. You can assist us by updating your personal information (e.g. change of address) with us.
7. The security of your personal information is a priority for Peoples Trust
We take steps to safeguard your personal information, regardless of the format in which it is held, including:
Physical security measures such as restricted access facilities and locked filing cabinets
Shredding of documents containing personal information
Electronic security measures for computerized personal information such as password protection, database encryption and personal identification numbers
Organizational processes such as limiting access to your personal information to a selected group of individuals
Requiring third parties given access to your personal information to protect and secure your personal information
8. We provide access to your personal information kept by Peoples Trust
You can request access to your personal information kept by Peoples Trust. Customers who wish to contact us should refer to the “How to contact us” section below. You may request any of the following:
What types of personal information we have on record or in our control, how it is used and to whom it may have been disclosed
Reasonable access to your personal information so you can review and verify its accuracy and completeness and request changes to the information. Peoples Trust reserves the right to decline to make a requested correction but will append a notation to the record of your requested alternative information
Updates to your personal information
Subject to applicable exceptions under Privacy Laws, such as where:
Your request would divulge confidential competitive business information of Peoples Trust
The information is not readily retrievable and the burden or cost of providing access is disproportionate to the nature of the request
Access could interfere with or prejudice an investigation or proceeding by Peoples Trust or law enforcement agencies
9. How you can protect your personal information
In addition to the steps we take to safeguard your personal information, we believe there are measures you should take to protect yourself as well.
We advise you to not share any personal or financial information with others unless you clearly understand the purpose of them requesting the information and that you have confirmed you are dealing with a legitimate contact. We also recommend that you not share any significant personal or financial information via email or voicemail.
10. Monitoring Telephone Calls
Peoples Trust may monitor and/or record in-bound and out-bound telephone calls as permitted by law for training and quality assurance purposes, to detect and prevent fraud or other losses, and to enforce our contracts. Any recording obtained from monitoring telephone calls is treated as confidential.
11. How to contact us
If you are uncomfortable about any information or requests you receive from Peoples Trust via phone, fax, or email, please contact us immediately at 1-800-663-0324 to confirm the information or request is legitimate or to discuss the concern with our Privacy Officer.
By calling our Privacy Officer at (604) 683 – 2881
By e-mail to: firstname.lastname@example.org
By mail to Peoples Trust:
ATTN: Privacy Officer
Peoples Trust Company
#1400, 888 Dunsmuir Street
Vancouver, British Columbia
If your questions or concerns have not been resolved to your satisfaction, you may also complain to the Privacy Commissioner within your jurisdiction, where applicable.
While the Internet is revolutionizing the way that we do business — providing convenient access to financial services from your home or office — we also recognize that it may bring legitimate concerns about Privacy and Security.
This Privacy Statement describes how your personal information is collected, used and disclosed when visiting any Peoples Trust website, including the Peoples Trust Online Banking Internet banking site or utilizing any of the online services offered by Peoples Trust. The Peoples Trust Online Banking site is the area of our website that requires you to use your Customer Number and Password to enter.
Controlled Access to your Information
To ensure that you are the only person accessing your personal information, we restrict access to your online account by requiring that you enter your Customer Number and Password to login. Only you know your password. Our employees do not have access to your password, and they will not ask you to reveal it. If someone does ask you to provide your password to them, we ask that you refuse to do so and contact us immediately.
Peoples Trust Online Banking Transactional Services
By nature, our Internet banking site has many transactional functions such as transfers between accounts. These transactions are all logged to ensure that your accounts are debited or credited appropriately, and a history of each transaction is available to verify your account. We store and use your transactional information in the same fashion as if you performed the transaction at a branch or any other service channel.
Creating a Secure Channel
Peoples Trust Online Banking Security
To create a secure channel between your browser and our server, we use 128-bit Secure Socket Layer (SSL) encryption, the highest level available. To learn more about 128-bit SSL encryption, and our security policies, please review our security information.
To provide you with a convenient method for purchasing financial services products, we may provide secure online application forms. By nature, these forms capture personally identifiable information that we use to provide you with the products and services that you have requested. This information is processed in a fashion similar to that of application forms received through our other channels. The information contained in the application may be archived or stored, as governed by existing law or policy.
Website Usage Statistics
To continually improve our site, we often collect information about how our Customers are using it. These usage statistics are only viewed in the aggregate—and are never tied to an individual.
We use this information for purposes such as improving the pages where our customers are having difficulties, and ensuring that we have the appropriate infrastructure in place to service future needs.
The information collected may include your IP address, your browser type and your operating system, as well as data that is passively generated as you browse the site, such as the number and types of pages visited, and the length of time spent per page and on the site overall.
Specifically, we use two kinds of cookies—session cookies and persistent cookies. A session cookie exists only for the length of your browsing session and is deleted when you close your browser. A persistent cookie is a cookie that stays on your computer after you close your browser. A persistent cookie may or may not expire on a given date. We use a session cookie to maintain the integrity of your Internet banking session. With each page that you visit, the cookie is passed back and forth between our server and your browser. We use the cookie to distinguish your session from the many others that may be happening at the same time. Our session cookies never store any personal information, such as your name, or date of birth, or financial information, such as your accounts and balances.
Most recent browser versions allow the user to set some level of control over which cookies are accepted and how your browser uses them. Many browsers will allow you to accept cookies from only known, reliable sites that you select such as the Peoples Trust website or the Peoples Trust Online Banking site. If you are concerned about cookies, we encourage you to upgrade your browser to a recent version and review the Help section of your browser to learn more about its specific control features.
Memorized Accounts Feature
We may use a persistent cookie to store information to help you personalize your Peoples Trust online accounts and to make it easier to use. For example, we allow you to make the Peoples Trust Online Banking login easier by remembering your Customer Number and Branch within our Memorized Accounts feature. Since the Memorized Accounts feature is optional, this cookie only contains information that you have entered into it.
To ensure that someone cannot access your personal information, always exit your Peoples Trust online account using the logout button located at the top of every page. When you exit using the logout button, we delete your session cookie so that your session cannot be resumed unless your Customer Number and password are re-entered.
Peoples Trust Online Banking Enhanced Security Feature
On the login screen, our Enhanced Security feature provides you even greater control over your Privacy.
When you click on the Enhanced Security checkbox, the Peoples Trust Online Banking site will prevent your browser from caching (storing in the computer’s memory) those pages that you have viewed. Should you click on the Back button to view a previous page during a session, the page will be recalled directly from our server. Therefore, when you logout, no one will be able to view your information by clicking on the Back button, or by viewing the browser’s History.
Use this function if you are accessing your accounts from a publicly available computer such as in a library or airport. You may also want to consider using the feature if you are using a computer at work, or a friend’s computer, to access your accounts.
Once again, it is important to remind you to always logout of the Peoples Trust Online Banking site using the logout button.
Peoples Trust Online Banking Automatic Session Time-outs
In the event that you leave your computer without logging out, the Peoples Trust Online Banking site has been designed to end your session automatically if our system detects that you haven’t provided any instructions or used the browser buttons to navigate for several minutes. To restart the session, you will need to provide your password again.
If you choose to communicate with us electronically, we strongly recommend that you use our Contact Us feature. This feature provides a secure channel for sending us comments, questions or instructions.
General email is not secure since it passes through many points on its route from you to us. If you are using general email to communicate with us, we strongly recommend that you do not include personal financial information (such as account numbers) within the email as we cannot guarantee its confidentiality en route to us.
When you email us your comments, questions or instructions, you provide us your email address and we use it to correspond with you.
We will not provide your email address to anyone outside of the Peoples Trust. We may use your email address to send you information about financial products or services that we think may be of interest to you. If you do not want us to contact you with product information by email, you may tell us so at any time by using the contact us feature. We will discontinue the practice.
If you have asked us to provide you with information on a regular basis, or if we email you information about our products or services, you may ask us to remove you from the list at any time. We intend to include instructions to unsubscribe from the list in every mailing, and on the site where you originally subscribed to the list.
Peoples Trust often uses external service partners and suppliers to assist us. In performing their duties, these service partners may handle components of your personal information on our behalf. We ensure through our contracts with these partners that they handle your information with the same standard of care that you have come to expect from us. Our suppliers, like our employees, are bound to maintain your confidentiality and may not use the information for unauthorized purposes.
Some of our partners require that you first register with their service to permit us to tie their functionality into the services provided by Peoples Trust. Registration for these external services will always be at your discretion. We may append personally identifiable data to this registration for the Partner to use to compare and validate the registration. You will always be notified of such an action during the registration process.
In the event our service provider is located in a foreign jurisdiction they are bound by the laws of the jurisdiction in which they are located and may disclose personal information in accordance with those laws.
Links to Other Sites
The Peoples Trust Online Banking site may also contain links to other websites or Internet resources. As an example, from time-to-time we may provide links to Microsoft or Netscape to assist you in upgrading your Internet browser. However, Peoples Trust Company has no responsibility or liability for or control over these other websites or Internet resources or their collection, use and disclosure of your personal information. Always review the Privacy Statements of the sites that you are viewing.
You should be aware that off-site pages or other sites might be available only in English or in other languages. Vous doivent être conscients que les renseignements offerts dans ces sites autres que le site web de PTC puissent n’être consultés qu’en Anglais ou dans toute autre langue.
Protecting Your Privacy—We’re in it together
As we continue to expand our online banking service to serve you better, and as new Internet technologies become available, we may need to amend this Privacy Statement at anytime, with or without notice to reflect changes in functionality and practice. Please check this Privacy Statement regularly for changes.
Revised August 13, 2013