The Effort Trust Company (the "Corporation") has strict guidelines related to the collection, use, storage, and disclosure of confidential information of its clients. Through the course of business, we may request your permission to collect credit, financial, and personal information from you, other businesses and institutions, and from references provided by you. This information will be used for internal business decision making purposes only and will not be shared with third-parties unless permitted or required by law.
The Corporation has always been and will continue to be committed to maintaining the accuracy, confidentiality, and security of personal and financial information. As part of this commitment, we have established Ten Privacy Principles to govern our actions as they relate to the use of customer information. The Corporation invites you to review our principles, which have been built upon the values set by the Canadian Standards Association's Model Code for the Protection of Personal Information and Canada's Personal Information Protection and Electronic Documents Act.
Principle 1 – Accountability
The Corporation is responsible for maintaining and protecting the customer information under its control. In fulfilling this mandate, the Corporation is required to designate an individual or individuals who is/are accountable for the Corporation's compliance with the Ten Privacy Principles.
The Corporation is accountable for all personal information in its possession or custody, including any personal information disclosed to third parties for processing or other administrative functions. The Corporation has established policies and procedures to comply with this code, and has designated the Chief Compliance Officer to be accountable for compliance.
Principle 2 - Identifying Purposes
The purposes for which customer information is collected will be identified before or at the time the information is collected.
Principle 3 – Consent
The knowledge and consent of the customer are required for the collection, use or disclosure of customer information except where required or permitted by law.
The Corporation will make a reasonable effort to ensure customers understand how their personal information will be used by the Corporation. The Corporation will obtain consent from its customers before or when it collects or uses the personal information. The Corporation will not attempt to deceive a customer into giving consent.
A customer's consent can be express, implied, or given through an authorized representative. A customer can withdraw consent at any time, with certain exceptions. The Corporation, however, may collect, use or disclose personal information without the customer's knowledge or consent in exceptional circumstances where such collection, use or disclosure is permitted or as required by law.
Principle 4 - Limiting Collection
The customer information collected must be limited to those details necessary for the purposes identified by the Corporation. Information must be collected by fair and lawful means.
The Corporation limits the amount and type of personal information it collects. The Corporation will collect personal information for the purposes it identifies to the customer. The Corporation collects personal information using policies and procedures which are fair and lawful.
Principle 5 - Limiting Use, Disclosure and Retention
Customer information may only be used or disclosed for the purpose for which it was collected unless the customer has otherwise consented, or when it is required or permitted by law. Customer information may only be retained for the period of time required to fulfill the identified purpose for which it was collected.
Under certain exceptional circumstances, the Corporation has a legal duty or right to disclose personal information without customer knowledge or consent to protect matters which include the Corporation's or the public interest.
Principle 6 – Accuracy
Customer information must be maintained in as accurate, complete and up-to-date form as is necessary to fulfill the purposes for which it is to be used.
Customers may, in writing, challenge the accuracy and completeness of their personal information and request that it be amended as appropriate.
Principle 7 - Safeguarding Customer Information
Customer information must be protected by security safeguards that are appropriate to the sensitivity level of the information.
Principle 8 – Openness
The Corporation is required to make information available to customers concerning the policies and practices that apply to the management of their information. The information will be made available in a manner that is generally easy to understand.
Principle 9 - Customer Access
Upon request, a customer will be informed of the existence, use and disclosure of their information, and will be given access to it. Customers may verify the accuracy and completeness of their information, and may request that it be amended, if appropriate.
When customers request it in writing, the Corporation will give them access to their personal information. The Corporation will respond to the written request in a timely fashion. In certain situations, however, The Corporation may not be able to give customers access to all their personal information. The Corporation will explain the reasons for this lack of access and any recourse the customer may have, except where prohibited by law.
Principle 10 - Handling Customer Complaints and Suggestions
Customers may challenge the Corporation's compliance with this code. The Corporation has policies and procedures to receive, investigate, and respond to customer's complaints and questions. Customers may direct any questions or inquiries with respect to the privacy principles outlined above or about our practices by contacting the designated person accountable for privacy in the Corporation.
Please direct your inquiry in writing to:
Ms. Veronica M. Cocco, Chief Compliance Officer
THE EFFORT TRUST COMPANY
The Effort Trust Building, 242 Main St East,
Hamilton, ON L8N 1H5