Privacy Code
Our commitment to you
Beem Credit Union and its affiliates (collectively, “we”, “us”, “our” or “Beem”) are committed to being accountable for, and ensuring the security, confidentiality and privacy of, your personal information. This Privacy Code outlines the principles and commitments we make to protect your privacy and personal information in compliance with privacy laws, sets out our process for responding to your questions and any concerns, and describes how you can access and correct your personal information.
Beem is primarily governed by the Personal Information Protection Act (British Columbia), which provides rules for how organizations collect, use and disclose personal information, but there may be times when other provincial or federal privacy legislation or other laws apply.
Definition of personal information
In this Privacy Code, “personal information” means information that is about you and could identify you either alone or in combination with information from other sources. Personal information can include information such as your name, address, gender, education, income, financial information, medical information, date of birth, employment history and product preferences, but does not include your business contact information. Personal information can be provided by you directly or by a third party, such as a credit reporting agency, a government agency or a public registry.
Amendments to our privacy code
From time to time, we may amend this Privacy Code. When we do so, we will put up a notice on our website and we may also notify you directly by email or through notices at our branches.
Your consent
Obtaining your consent
We will obtain your consent before we collect, use or disclose your personal information, except in circumstances permitted or required by privacy laws. We will not, as a condition of providing a product or service, require you to consent to the collection, use or disclosure of personal information beyond what is necessary to provide that product or service.
Your consent can be express or implied, depending on the nature and sensitivity of the personal information. We may obtain your express consent verbally, in writing, electronically or you can give your consent through
an authorized representative such as a lawyer, agent or broker. In some circumstances, your consent may be implied (or assumed) if you voluntarily provide personal information to us for a purpose that a reasonable
person would consider to be obvious. For example, if you provide us with your telephone number and request that we call you, your consent to our collection and use of your phone number would be implied. Your consent to collection, use or disclosure of your personal information may be assumed if we provide you with a notice that we intend to collect, use or disclose your personal information for a specific purpose and give you a reasonable opportunity to decline consent and you do not decline, provided the purpose for such collection, use or disclosure is reasonable in the circumstances.
Refusing or withdrawing your consent
You may withdraw your consent to the collection, use or disclosure of certain personal information at any time, subject to legal or contractual restrictions. Your withdrawal or refusal of consent may prevent us from providing a product or service to you. If the information is required by law or is necessary to operate banking systems, we may discontinue the products and services we provide to you. You may opt out of receiving surveys, marketing or promotional offers from us at any time.
To withdraw your consent or to opt out of surveys, marketing or promotional offers, please submit a request to our Privacy Officer using the contact information set out below. We will require a reasonable period of time in order to implement your request.
When your consent is not required
In limited circumstances as permitted by privacy laws, we may collect, use or disclose personal information without your knowledge or consent, such as:
• when required or authorized by law
• when we are collecting a debt owed to us or paying a debt owed by us
• if it is reasonable to expect that obtaining your consent would compromise an investigation or legal proceeding
• when we are obtaining legal advice
• when necessary for your medical treatment and you do not have the capacity to give consent
• when necessary for the purpose of complying with a subpoena, warrant or order
Your personal information
Collecting and using your personal information
We collect and use information to manage our relationship with you, to deliver products and services to you and to comply with our legal and regulatory requirements. The information that we collect from you depends on the specific products and services you request. Most of the information we collect about you is received from you directly. For example, to provide you with products and services, we will need your name, address, date of birth, and occupation. We also need to ask you for identification and contact information, such as your phone number or email address. We may also collect personal information from you when you interact with our representatives our participate in our community events, surveys or contests.
We may also collect personal information about you from other organizations, such as:
• Government agencies, law enforcement authorities, and public records and registries
• Credit reporting agencies
• Other financial institutions
• Service providers and organizations, including payment card networks
• References provided by you
• Persons authorized to act on your behalf under a legal authority such as a power of attorney
When collecting or using your personal information, we will notify you of the purposes for collecting or using your information, either verbally or in writing (including through this Privacy Code). We will limit the collection and use of your personal information to that which is necessary to provide you with products or services and that is necessary for the purpose you consented to, except where you have consented otherwise or we are otherwise permitted or required by privacy laws.
We collect and use your personal information for the following purposes:
• To verify your identity
• To provide products and services to you
• To manage your accounts, transactions and statements
• To determine your eligibility and suitability for products and services
• To communicate with you regarding your account, services and membership
• To contact you regarding new products and services, offers and events
• To determine your eligibility for health insurance products
• To assess the suitability of products and services offered to you
• To provide you with information and materials related to your accounts, services and membership
• 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 manage and assess our operations and risks
• To conduct market research and generate data analytics regarding our business, products, services and membership
• To comply with our legal and regulatory requirements
• To investigate and help protect against fraud and criminal activity
• To understand your retail, financial and banking needs and to develop and manage products and services to meet those needs
• To conduct contests, surveys and promotions
• To provide a personalized web experience (please see our Website Term and Conditions of Use for more information regarding our collection of information from you, your computer or your mobile device and our use of cookies and similar technologies)
Disclosing and sharing your personal information
We will not disclose your personal information for purposes other than those for which it was collected, except with your consent or as required or authorized by privacy laws. When disclosing your personal information we will take all reasonable steps to protect your interests.
Subject to privacy laws, we may share personal information with our affiliates and carefully selected third party service providers. We may also share your personal information with credit reporting agencies, other financial institutions, Canada Revenue Agency, financial industry regulators and your authorized representatives. Under no circumstances do we sell your personal information to third parties. Personal information will be shared only as needed to provide the products and services requested, for the purposes
described in this privacy code or when authorized or required by law.
If we share personal information with third party service providers, we will ensure there is an agreement in place that confirms that they understand and follow privacy laws. Our third party service providers may be located outside of Canada and subject to the laws of the countries in which they are located. Consequently, your personal information may be processed and stored in other jurisdictions, including the United States. The laws of these jurisdictions may permit governments, law enforcement agencies, courts or regulators to access your personal information, or have less stringent privacy laws than those of Canada.
The following are examples of circumstances when we may disclose or share your personal information:
• With your consent
• To payment card networks and Interac Corp. to support operation of their payment systems and services to you
• To merchants with whom you have set up pre-authorized bill payments
• Joint account holders will be able to access account information, such as the transaction history and balances
• If you have a product or service where ownership or liability is shared with other persons, to such other persons in connection with the product or service
• To legal guardians, powers of attorney, executors, committees, trustees or other legal representatives, where applicable
• To credit reporting agencies and other financial institutions or lending institutions in connection with credit related products and services or to help us collect a debt or enforce an obligation
• Within our organization, including with our affiliates, so that we can manage risk, comply with applicable legal requirements
• Within our organization, including with our affiliates, to conduct market research and offer products and services to better serve you
• in relation to an investigation or legal proceeding to investigate and protect you, other members and ourselves from error, risk, fraud and criminal activity
• In connection with a transaction to sell, merge or amalgamate our business or a part of our business to or with another entity, and to insure, sell or securitize assets
• In connection with the transfer of a financial asset or liability, with respect to any personal information related to that financial asset or liability
• To government and law enforcement agencies or other financial institutions to meet compliance, regulatory or financial crime risk management obligations
• To regulators and self-regulatory organizations in order to meet our legal and regulatory obligations
• When required or permitted by law, for example, in the connection with a court order, subpoena or search warrant or to collect a debt owed to us
Accessing your personal information
Right to access
You have a right to request access to personal information about you that is under our control. You may submit a written request for such personal information by contacting the Privacy Officer at the contact information below. Upon such request, we will provide you with the personal information under our control, information about the ways in which such personal information has been and is being used and the names of individuals and organizations to whom such personal information has been disclosed. We may request that you specify the type of personal information you would like to access.
We will require you to verify your identity in connection with any request for access to personal information.
Assistance
When you contact our Privacy Officer, we will assist you in completing an access to information request to ensure that the information you want or need is provided accurately, completely and promptly. You may be required to provide sufficient information to permit us to determine the existence, use and disclosure of personal information under our control. Any such additional information provided will only be used for this purpose.
We will make all reasonable efforts to provide the information to you in a way that is accessible to you.
Fulfilling your request
There may be a minimal fee for fulfilling an access request, depending on the type and amount of information requested. When there is a fee, we will inform you of the estimated fee and ask you whether we should proceed with the request. We may require a deposit for all or part of the fee.
If we are unable to fulfill the access request within 30 days, we will provide you with a written notice of a time extension within 30 days of the request. The notice of extension will advise of the new time frame, the reason(s) for extending the time frame and of your right to make a complaint to the Office of the Information and Privacy Commissioner for British Columbia regarding the extension.
Limitations on access
Privacy laws provide certain circumstances under which we are not required or are prohibited from providing certain information to you. For example, we are prohibited by law from providing you with your personal information if to do so would reveal personal information about another individual. If we refuse access to personal information, we will provide written notification of the reasons for refusal, what other options you may have and provide the name, position, title, address and telephone number of one of our employees who can answer your questions about the refusal. We may refuse to confirm or deny the existence of personal information collected as part of an investigation.
Accuracy of and corrections to your personal information
Accuracy
We will make reasonable arrangements to ensure that personal information we are collecting, using or disclosing is accurate and complete. You should proactively update us of any changes to your personal information. In many cases, we rely on you to ensure that certain personal information, such as your address, telephone number and tax residency, is accurate. Keeping your personal information up to date lowers your fraud risk, avoids your statements being mailed to an incorrect address and ensures accurate reporting on our part.
Corrections
You may request that we correct any errors or omissions in your personal information under our control by contacting our Privacy Officer at the contact information set out below. If appropriate, we will correct the information and send the amended information to third parties to whom the inaccurate or incomplete information has been disclosed. If we are not satisfied that the request for correction is reasonable, we will annotate the information, noting that correction was requested but not made.
Protecting your personal information
Protection
We will protect your personal information in our custody or control by making reasonable security arrangements to prevent unauthorized access, collection, use, disclosure, copying, modification or disposal and similar risks, including by employing electronic and physical security safeguards appropriate to the sensitivity level of your personal information. Such arrangements may include restricted access controls, passwords and encryption. We will take reasonable steps, through contractual or other reasonable means, to ensure that a comparable level of personal information protection is implemented by the third party service providers who assist us in providing services to you.
Retention
We will keep personal information used to make a decision that affects you for at least one year after using it to make the decision. After that period, we will, in accordance with our retention schedule, destroy, erase or make anonymous documents containing personal information, as soon as it is reasonable to assume that the original purpose is no longer being served by retention of the information and retention is no longer necessary for legal or business purposes.
We may retain personal information about you with your consent in order to assist in the provision of future products and services and for marketing purposes, such as sending information about products and services that may be of interest and may update the information as necessary to provide products and services applied for.
Options regarding your personal information
Social insurance number
We are legally required to collect and use your Social Insurance Number (“SIN”) if any of the products or services we provide to you earn interest, in order for us to comply with Canada Revenue Agency’s reporting requirements.
We may also collect and use your SIN for other purposes such as to identify you or to conduct credit checks, but providing your SIN for these purposes is optional. If you wish to opt out, we will use other means to distinguish your identity from others or to identify you with credit reporting agencies. You may opt-out by contacting our Privacy Officer at the contact information below.
Marketing communications
We send information by various means including phone, email, text message and mail about contests, special offers, and promotions and to conduct market research. If you do not want us to use your personal information to contact you for these purposes, you may opt-out by contacting our Privacy Officer at the contact information below.
Communication recording and video surveillance
When you communicate to our representatives by telephone, email, internet live chat, text or social media message, we may monitor or record your conversations for quality assurance, record keeping, investigation
or training purposes. To protect our customers and ourselves from criminal activity, we use security cameras at our branches and ATMs. If you prefer not to be recorded by audio and/or video, many but not all transactions can be conducted using our online banking and mobile app services.
When you access our website, online banking, mobile app or apply for products and services online, we may
collect information from you, your computer or your mobile device. Our websites, including www.beemcreditunion.ca, www.gulfandfraser.com, www.interiorsavings.com and www.npscu.ca use cookies and similar technologies to help provide our members with the best experience we can. For more information, please see our Website Term and Conditions of Use.
Questions and complaints
You should direct any questions, concerns, or complaints regarding your privacy or this Privacy Code to our Privacy Officer at the contact information provided below. Our Privacy Officer will ensure that inquiries, concerns and complaints regarding personal information receive prompt attention and are resolved in a timely manner. Where appropriate, members and other individuals will be informed of their right to file a complaint with the Office of the Information and Privacy Commissioner for British Columbia and will be provided contact information.
Privacy Officer
Our Privacy Officer may be contacted as follows:
Mail: Beem Credit Union
Attention: Privacy Officer
300 – 678 Bernard Avenue,
Kelowna, BC V1Y 6P3
Email: privacyofficer@beemcreditunion.ca
Contact Member Connect:
Lower Mainland & Fraser Valley
Canada & US: 1-866-736-4334
Local & International: 604-419-8888
Interior, Peace & Northern Rockies
Canada & US: 1-855-220-2580
Local & International: 250-469-7014
