Protecting your privacy – we’re in it together!
Protecting your personal information is critical to Peoples Group being able to provide you with great financial services. This policy sets out how we collect, protect, use and disclose your personal information. It explains:
- What kinds of personal information we collect and why we collect it
- How we collect personal information
- How we use personal information
- Who we share personal information with and why
- How we store your personal information
- How we protect your personal information
- Our communications with you
- How you can request changes to your information
- How we collect, use, and disclose non-personal information
- How to contact us
You are welcome to contact us to obtain further information about how we collect and handle your personal information. See “How to Contact Us” section below.
If you have any concerns about your personal or financial information with Peoples Group, or there has been any evidence or unusual activity to suggest you may be at risk of fraud or identity theft, report the incident to us immediately at 1-855-683-2881.
This policy is subject to change from time to time. If we make changes, we will amend the “revised” date at the bottom. Any changes will become effective when we publish the revised policy. If we make any material changes, we will notify you by mail, email, or through a notice on our Website, and will provide advance notice if that is appropriate for the nature of the change
1. What kinds of personal information we collect and why we collect it
“Personal information” is any information about you which, either on its own or in combination with other information, could be used to identify, contact or locate you, or could be linked to your personal identity.
We collect personal information to establish and manage our business relationship with you. Depending on the products and services you use, the personal information we collect can include:
- Contact information such as your name, residential address, phone number, email address – we use this to communicate with you.
- Identity information such as your date of birth, gender, social insurance number, other government identification (such as driver’s licence or passport information), employment, and information about other financial accounts (if they are used to verify your identity) – we use this to establish and verify your identity.
- Biometric information such as measurements or characteristics about your physical or behavioural traits, including but not limited to, your facial features, voice patterns, fingerprints – we use this to verify your identity or to protect your account.
- Information about your current and past employment, income, and assets – we use this to assess your suitability as a customer and eligibility for credit-related products and services.
- Information about your financial behaviour – such as your banking information, accounts, payment history, and creditworthiness – we use this to assess your suitability as a customer and your eligibility for credit-related products and services.
- Information about how you use our products and services – we use this to provide these products and services to you, to protect us and your account (by spotting unusual activity), and to notify you about changes that will impact your products and services. Examples of this type of information include: information about your purchases – such as transaction amounts; the source, amount, and destination of a payment; withdrawal, or fund transfer. We also use this to provide you with personalized products and services, to better understand your needs and preferences (including through data analytics), to personalize your experience on our websites and mobile applications, and to provide you with tailored communications and offers.
- Information about another individual – if you have a joint account or a legal guardian or personal representative, we will also collect personal information about those individuals.
2. How we collect personal information
We collect information from a variety of resources – and may be limited in our ability to provide you with certain products and services if you decline to provide us with information essential to fulfill your request.
Some of the sources we use include:
- Directly from you: We receive some of the personal information we collect about you directly from you. For example, if you apply for one of our services or communicate with us, you are providing us with your personal information.
- From third parties: In some cases, we may collect information from third parties outside Peoples Group, including:
- other lenders and financial institutions where you have accounts;
- credit bureaus, credit reporting agencies, and credit insurers;
- persons authorized to act on your behalf under a power of attorney or other legal authority;
- service providers, including technology service providers, agents, and other organizations with whom you or we conduct business;
- for products or services offered as ‘Banking as a Service’ (BaaS), we receive information such as your name, contact information, date of birth, social insurance number, information to verify your identity, other information you supply with your application, and information about your transactions and use of the financial products, from the third party we work with to offer these products and services; and/or
- government agencies, public registries, and information available from open sources (for example, an Internet search).
3. How we use your personal information
Peoples Group collects your personal information to manage our relationship with you and to consistently deliver high-quality products and services. Here are some examples of why we collect personal information and how we use it:
- to verify your identity, including to meet our ‘know your client’, anti-money laundering, and sanctions obligations;
- to evaluate and process your application for an account or credit limit, including determining your eligibility;
- to obtain your credit report;
- to communicate with you about your loans, securities, or deposits;
- to open and maintain your account in accordance with your agreement(s) with us, including to accept deposits, and to process transactions such as payments, withdrawals and transfers of funds, to log your debit and credit transactions accurately, and that a history of each transaction is available to verify your account;
- to make changes you request to your account;
- to process and keep track of transactions and report back to you;
- to detect and prevent theft, fraud and error, and to protect you, us, and others against theft, fraud and error;
- to analyze information to determine that relevant products and services are offered to you;
- to provide you with products and services, or information about products and services, that have been requested by you and/or that Peoples Group believes may be of interest to you and provide value to you;
- to inform you about new business initiatives including contacting you to obtain your views and to encourage you to express your views about them;
- to offer you the opportunity to participate in contests, giveaways or other promotions;
- to conduct research and generate statistics related to our business, products and services;
- for business purposes, such as data analysis, audits, developing new products, enhancing, improving or modifying our services, identifying usage trends, determining the effectiveness of our promotional campaigns, and operating and expanding our business activities;
- to help manage and assess our risks, operations, and relationship with you;
- to obtain and maintain insurance coverage;
- to comply with legal and governmental requirements;
- to fulfill any other purpose for which you provide it or with your consent; and
- if you hold a product that generates income, and we have your SIN, we may use it for tax reporting purposes and share income information with the relevant revenue service agencies. With consent, we may also use your SIN to match your personal information and your credit bureau information, or as an internal identification number to accurately identify customers having the same or similar names.
4. Who we share your personal information with and why
We may share your personal information in the following ways:
- With other Peoples Group companies: To assist us with offering the best services to you, we may share your personal information with our other companies and respective affiliates.
- With our employees: While performing their duties, our authorized employees may have access to personal information and other confidential information. Employees may only access personal information strictly necessary to perform their duties. All employees that are likely to have access to personal information must sign a Code of Ethics under which they commit to maintaining its confidentiality.
- With third-party product and service providers: We may disclose personal information to certain third-party product and service providers retained by us, to assist in providing you with products and services, or to perform certain specialized services to assist us in our business. These providers can include: deposit-taking agents, credit reporting agencies, marketing partners, debt collection agents, account statement providers, financial institutions, and others involved in the clearing and settlement of transactions, fraud prevention, regulatory compliance assistance, and secured data management and storage.
- If you are receiving products and services through our BaaS offering, with your BaaS provider: We receive information about you from that provider and use it in connection with those products or services. In addition, you should be aware that:
- This information is received by the BaaS Provider to allow them to carry out servicing of your account, such as identification and client verification, to communicate with you regarding your account, debit or credit your accounts appropriately, to present accurate account information to you, and to conduct such other activities as may be described in your account agreement with your BaaS provider.
- These parties are independent from us, and we do not control all manners in which they may process your personal information. In addition to servicing your account, they may also process your personal information under their own privacy policies, any consent you have provided to them, and for other products or services they provide to you. We do not control and are not responsible for their actions.
We currently offer the following BaaS products:
This section will be updated as new BaaS products are added.
- With the Canada Deposit Insurance Corporation: We may share information about eligible accounts and customers as required with the Canada Deposit Insurance Corporation to obtain insurance for eligible deposits.
- As Required by Law: In certain instances, we may be required or permitted to disclose information about you in response to a legally valid demand, inquiry, proceeding, or other order, or for the purposes of investigating a breach of an agreement or contravention of law or to detect, suppress, or prevent fraud. We reserve the right to comply with any valid third-party demand (such as Requirements to Pay and Requests for Information) issued under federal or provincial legislation, or any court or regulatory order we receive, in respect of your accounts or any information we hold about you. You agree that we will not be liable to you in any way for complying with any such third-party demands or court orders issued on or against your accounts or products. In these cases, we take steps to assess if the request is valid and we only disclose the specific information necessary to satisfy the inquiry or order.
- Transfers of Business: As we continue to grow, we may expand or sell our businesses or part of it. In such a case, the personal information we hold may be among the assets transferred.
- Additional Disclosures: We may also disclose personal information:
- with your consent;
- to a person sharing a joint account with you, about the account;
- to help us collect a debt or enforce an obligation owed to us by you;
- if required or permitted by law;
- to credit reporting agencies to maintain your credit history (note- if you fail to meet your obligations to us, we may a file a negative report, and your credit score may suffer); and
- to other lenders or financial institutions to provide you with the services.
5. How we store your personal information
As noted above, the privacy laws of those jurisdictions may or may not be as comprehensive as Canadian law. In these circumstances, the governments, courts, law enforcement, or regulatory agencies of that country may be able to obtain access to your personal information through the laws of the foreign country. Peoples Group will disclose personal information as required by law.
6. How we protect your personal information
We protect your personal information with a variety of security measures, which may vary based on the information being processed. These include:
- 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; and
- requiring third parties given access to your personal information to protect and secure your personal information.
The safeguards employed by us to protect your personal information depend on the sensitivity, amount, distribution, format, and storage of the personal information.
Although technologies can make it easier for fraud to occur, we employ around-the-clock monitoring systems and controls to help detect and prevent fraudulent activity. We also build fraud prevention measures into our due diligence processes and regularly update our fraud detection/prevention methods.
While we take precautions to help protect your personal information from loss, theft, alteration, or misuse, no system or security measure is completely secure. Any transmission of your personal information is at your own risk and we expect that you will use appropriate measures to protect your personal information as well.
In addition to the steps we take to safeguard your personal information, we believe there are measures you should take to protect yourself, such as:
- Not sharing any personal or financial information with others unless you clearly understand the purpose of them requesting the information and you have confirmed you are dealing with a legitimate contact.
- Not sharing any significant personal or financial information via email or voicemail.
7. Our communications with you
Using Email to communicate with us
If you choose to communicate with us electronically, we strongly recommend that you use our Contact Us feature. This feature provides a more secure channel for sending us comments, questions or instructions than email.
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 or passwords) 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 may use it to correspond with you.
Canada’s Anti-Spam Legislation (“CASL”)
Peoples Group complies with CASL and we are committed to making sure you only receive the email communications that you want from us. Peoples Group will not send you unsolicited emails in connection with the marketing of Peoples Group, its services or products. We may occasionally contact you to notify you about updates to the Website or new products or services offered by us or to deliver targeted information that may be of interest to you, when we have your consent to do so. No matter how you join our list or provide us with your consent to receive communications, at the bottom of all our commercial emails, you will find a clear, easy way to unsubscribe.
Monitoring of telephone calls
Peoples Group 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.
Keeping your information up to date
We try to keep your personal information up to date and accurate so we can serve you better. You can assist us by updating your personal information (e.g. change of address or telephone number) when it changes by contacting us – see section below “11. How to Contact Us”.
If you are receiving products and services through our Banking as a Service offering, your can update your personal information directly with your service provider.
8. How you can request changes to your information
Access and rectification
You can request access to your personal information kept by Peoples Group at any time – see “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
- Updates or corrections to your personal information. Peoples Group reserves the right to decline to make a requested correction where the accuracy of the change is in question but will append a notation to the record of your requested alternative information.
Your request is subject to applicable exceptions under privacy laws, such as where the information requested includes the personal information of another person. For your protection, we may require you to confirm your identity before providing access to your personal information.
Your request must be made in writing and provide us with sufficient detail to enable us, with reasonable effort, to identify you and your personal information. We will inform you within thirty days what personal information we have, how we collected it, how we used it, and to whom it has been disclosed. If we need to extend the time, or we must refuse your request, we will tell you why, subject to any legal restrictions, and will notify you of the new deadline, the reason for the extension, and of your right to contact the federal or provincial privacy commissioner applicable in your jurisdiction.
Limiting or withdrawing consent
You may choose to restrict the collection or use of your personal information in the following ways:
- You may write to or email us using the contact information below to withdraw your consent to us using your personal information for direct marketing purposes.
- If you receive commercial email from us, you can also unsubscribe using the unsubscribe tool we provide in such messages.
Please note that if you seek to withdraw consent to our collecting and processing information that we must process to provide our services, we may not be able to provide those services to you. For example, you cannot withdraw consent to ongoing collection, use and disclosure of personal information needed in connection with administering a loan product you have purchased. Similarly, you cannot withdraw consent for us to collect, use or disclose information we need to carry out regulatory purposes.
General Data Protection Regulation (GDPR) – Applicable to European Economic Area (EEA) residents only
Under the GDPR, EEA residents, have certain data protection rights. As an EEA resident, you have:
- the right to access your personal information that we hold;
- the right to request the rectification of your personal information that we hold;
- the right to request the erasure of your personal information that we hold;
- the right to request to restrict the processing of your personal information;
- the right to object to the processing of your personal information by us;
- the right to request to transfer your personal information that we hold (i.e., data portability);
- the right to file a complaint to a supervisory authority in your jurisdiction; and
- the right to withdraw consent.
Peoples Group takes reasonable steps to allow you to correct, amend, delete or limit the use of your personal information. We have appointed an internal privacy officer to handle any data questions or concerns.
If you wish to be informed about what personal information we hold about you or if you want it to be removed from our systems, please contact us at [email protected] or refer to the “How to contact us” section below.
9. How we collect, use and disclose non-personal information
Non-personal information is any information that does not reveal your identity or directly relate to you as a person. Non-personal information may also include personal information we have de-identified or aggregated, to the point where it no longer identifies a particular individual.
We may anonymize, or otherwise strip any personal information or other information we collect of all personally identifying characteristics and may use or share that aggregated, anonymized data with third parties for any purposes we deem appropriate. We may also make certain aggregated non-personal information available to strategic partners and third-party service providers that work with Peoples Group, to provide or support products and services, to conduct data analysis, to develop and improve products and services, and to determine the effectiveness of promotional campaigns. We reserve the right to use and share any non-personal information with third parties for any lawful purpose.
If we ever combine non-personal information with any personal information, we will obtain your consent and treat it as personal information is treated under this Policy.
While the digital age is enabling 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.
To access your Peoples Group online account, including through the Online Banking site, you need to use your personal customer number and password.
a. Controlled Access to your Information
You should be the only person accessing your personal information through the Online Banking site, and so we restrict access to your online account by requiring that you enter your customer number and password to log in. Only you should know your password- do not provide it to anyone else. Our employees 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.
b. Online Banking Transactional Services
Our Online Banking site has many transactional functions, such as transfers between accounts. These transactions are all logged so that your accounts are debited or credited appropriately, and a history of each transaction is available. 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.
c. Online Banking Security
To create a secure channel between your browser and our server, we use banking-grade industry-standard encryption. To learn more about our security policies, please review our security information.
Despite these measures, our systems could be compromised by parties seeking unauthorized access to our data or users’ data, by a technological malfunction, or in error by an employee, vendor, or contractor. Also, the transmission of information via the Internet or mobile data networks could be intercepted by third parties. As a result, our efforts to protect our data and users’ data from unauthorized access may be unsuccessful and we cannot assure you that the security measures we have adopted will provide absolute certainty. Any transmission by you is at your own risk. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us – see “How to Contact Us” section below. If we learn of a security systems breach, we will inform you and the appropriate authorities of the occurrence of the breach as required by applicable law.
d. Website, Mobile App and Online Banking Usage Statistics
To continually improve our Website, Mobile App and Online Banking 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, having the appropriate infrastructure in place to service future needs, managing, assessing risk, and protecting against theft, fraud, and error.
The information collected may include your general region location as determined by your IP address, your browser type, and your operating system, as well as data that is passively generated as you browse, such as the number and types of pages visited, and the length of time spent per page and on the Website or Online Banking site overall.
When you use our Mobile App for Online Banking, we may also collect certain personal information about the device you use and your location, if you have enabled location-based and other services on your device.
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 or mobile device 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 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.
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 Group Website or the 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.
f. Memorized Accounts Feature
We may use a persistent cookie to store information to help you personalize your online accounts and to make them easier to use. For example, we allow you to make the 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. You should only use the Memorized Accounts feature on devices to which you control access- you should not use it on public or shared devices.
g. Logout Button
To help prevent unauthorized people from accessing your personal information, always exit your 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.
h. Online Banking Automatic Session Time-outs
If you leave your computer without logging out, the 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.
i. Links to Other Sites
Peoples Group websites, including the 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 certain web browsers [https://www.peoplestrust.com/en/legal/browser-requirements/] to assist you in upgrading your internet browser. However, Peoples Group 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. Sachez que les pages qui ne figurent pas sur le site Web du Groupe Peoples ou certains autres sites pourraient n’être disponibles qu’en anglais ou dans d’autres langues.
11. How to contact us
If you have any questions, concerns or complaints about our privacy policies or are uncomfortable with any information or requests you receive from Peoples Group via phone, fax or email, we encourage you to contact us immediately at 1-855-683-2881. In most cases, any questions or concerns that you have can be resolved by discussing them with us or our Privacy Officer.
You may contact our Privacy Officer:
- By e-mail: [email protected]
- By mail to:
ATTN: Privacy Officer
Suite 1400- 888 Dunsmuir Street
Vancouver, British Columbia
- By phone: via our customer service number at (604) 683 – 2881 (note that this line auto forwards to Deposits)
If you are not satisfied with how we have attempted to resolve your questions, concerns or complaints, please consult the federal or provincial privacy commissioner in your jurisdiction whose information can be found online at the below sites.
British Columbia www.oipc.bc.ca
In this Policy:
“Banking as a Service (BaaS)” means those financial products and services which we offer in association with a third-party provider, such as a financial technology company. Such products and services are branded and offered by the third party; however, Peoples Group enters the financial agreement with you and processes your personal information to carry out that agreement and meet our legal requirements. You have a separate relationship with the third party, which we do not control.
“Online Banking” means the portions of the Website relating to online banking transactions or account access and/or the mobile application software.
“Peoples Group”, “We”, “we”, “Our”, “our” and “us” means Peoples Trust Company and all of its subsidiaries and business operations, including Peoples Bank of Canada (Peoples Bank).
“personal information” means any information, recorded or unrecorded, which, either on its own or in combination with other information, could be used to identify, contact or locate a specific individual.
“PIPEDA” means the Personal Information Protection and Electronic Documents Act.
“Privacy Law(s)” means PIPEDA and any privacy law applicable to the private sector in Canada.
“Website” means the Peoples Group website, including the content, information and services provided on or through the Website and by e-mail, including all online tools, applications, calculators and e-mail alerts.
Last revised December 7, 2022
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