PRIVACY POLICY
Protecting your privacy
First West Credit Union and its divisions—Valley First, Enderby & District Financial, Envision Financial, Island Savings and all subsidiaries, collectively, “First West”—are committed to the protection of your personal information. First West has established a comprehensive privacy program ingrained in our high standards of customer service to protect your personal information. This commitment to privacy includes treating you fairly and with respect and complying with the principles set out in this policy.
Policy Statement
By doing business with us or agreeing to the account opening documents of your First West account and/or products and providing your personal information to us you are consenting to First West using and disclosing your personal information in the ways described in this policy. You may withdraw all or part of your consent at any time by contacting your local First West branch or notifying the Privacy Officer.
Certain personal information is necessary to provide you with products and services that First West offers. If your consent is withdrawn or you do not wish to provide us with consent, we may be limited in the products and services we can provide to you.
Types of information we collect:
When you open an account with First West your Identification, contact details, and with your consent a credit bureau is collected.
TYPES OF INFORMATION WE COLLECT |
HOW WE USE IT
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|---|---|
| First name, last name, previous name, home address, phone numbers, email, identification numbers. | To identify and verify you, to communicate with you, to protect you and First West. |
| Date of Birth | To verify you, to assess eligibility of products and services that may be of interest. |
| Social Insurance Number | The Government of Canada requires us to collect and use your social insurance number (SIN) for income tax reporting purposes on all interest earning accounts or investment income such as GICs, Mutual Funds and RESPs.
Additional uses: We and our agents and representatives may also use your SIN to keep your records separate from other individuals with the same name and to identify you (including for credit reporting purposes, as applicable). You understand that your consent to these additional uses is optional. |
| Personal Credit Report | With your consent from any credit reporting agencies from time to time for the purposes of assessing your current and ongoing creditworthiness, to confirm and/or update your personal information, for risk assessment, and/or other legal or regulatory purposes. We may provide information about your credit history and other personal information to credit reporting agencies to update their credit information and maintain the integrity of the credit reporting. You understand that refusal to consent may mean we are unable to provide you with products or services that involve provisional credit, such as a credit product or reduced deposit hold period. |
| Biometric Information | When you open an account with us through our Online Membership Application, we’ll need you to provide identification information to verify your identity. This is completed by taking a picture of yourself and providing your government-issued picture ID (e.g. BC Drivers License) using your mobile device. A third party will be authenticating your image. Or you can choose to skip this step and verify your identity using your Social Insurance Number (SIN). |
| Tax residency and tax identification number | To comply with Canadian Law such as Common Reporting Standards (CRS), Income Tax Act and Foreign Account Tax Compliance Act (FATCA). |
| First name, last name, phone number occupation, employer name and address | To comply with anti-money laundering laws. |
| Ways you prefer to receive First West communications | To help us tailor our interactions with you through your preferred channel.
To inform you of news about our products and services, as well as special promotions, offers or events. To contact you for surveys and research. |
| Information to monitor and prevent financial crime such as profile and transactional activity in your accounts. | We are required by law to help protect our communities by detecting, preventing and investigating financial crime – such as money laundering, terrorist financing, bribery, corruption and tax evasion. This may include checking your identity against watch lists and monitoring your transactional activity.
To facilitate the collection of debts owing by you, or for which you are financially responsible to us. To protect you, the third party for whom you are acting, or us from error and fraud, such as identity theft. |
| Video Surveillance at branches and ATM’s through security cameras | To view and record images at our banking facilities to prevent robberies and investigate crimes. |
| Your interactions with us, through branch, phone and email, such as a history of branch visits and face to face meetings. Call history and call recordings to our Member Advice Centre. Any complaints you make. Advice we may have provided you. | We are required by law to retain certain records of your interactions with First West. We also retain records for staff training purposes, to understand any concerns you may have so they can be resolved and improve your experience. |
| Through digital interactions such as our websites, apps, digital assistant (Finley), SMS and social media sites we collect Cookie data, location info, IP Addresses, device data, browser history, your activity on our websites, third party websites and social media sites through online tracking, any complaints you make, and advice we may have given you. | We may collect limited information from your interactions with our digital communications, advertisement, and forms (such as whether you opened an email, clicked on a link, or submitted a form). This data helps us measure engagement, improve our content, and better understand which products or services may be relevant to you. When permitted, we may also use encrypted (hashed) versions of your contact information to build lookalike audiences, match audiences across trusted platforms, and measure the effectiveness of our advertising. |
| Statistics on how our products and services are being used | To measure how our products and services are being used and their performance. To identify opportunities for new products and services or improve existing ones. |
As part of the day-to-day management of your account and to provide you with products and services First West may at times disclose your personal information to service providers to perform business operations on our behalf.
WHO WE MIGHT SHARE YOUR PERSONAL INFORMATION WITH
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WHY WE SHARE YOUR PERSONAL INFORMATION
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|---|---|
| Service Providers | To perform business operations on our behalf, such as printing, mailing, fulfillment, communication services, conduct member surveys, supply credit cards, provide access to online banking your information may be provided to cloud computing companies, web hosting companies, advertisers, research firms, and credit card suppliers, to conduct screening and ongoing monitoring as required by anti-money laundering laws. We may disclose your personal information to service providers to perform business operations, services, and transactions on your behalf or that you have requested. Some of our suppliers may be located outside of Canada and you may be subject to their jurisdictional laws. |
| Advertisers | When you interact with us online or through our digital channels, we may collect information such as your name, email address, phone number, postal address, and cookie or device identifiers. This information may be used in encrypted(hashed) form to help us show you relevant offers or communications through trusted advertising platforms like Google or social media providers.
We may also use privacy-safe tools such as Customer Match, Enhanced Conversions, and lookalike audiences to help us reach people who may be interested in our products or services. These processes do not share personal details, all matching happens securely, and any unmatched data is deleted. You can opt out of personalized ads anytime by contacting us, adjusting your ad settings on the relevant platforms, or you can unsubscribe here: |
| Partners | To provide experiences and partner offers for our members. |
| Government Agencies | We disclose your information in accordance as required by law, including complaints you make, complying with anti money laundering laws and regulations. |
| Law Enforcement Agencies and Debt Collection Agencies | We will disclose your information to bailiffs, collection agencies, lawyers and others when collecting a debt, enforcing an agreement between you and First West, ensuring or otherwise protecting First West’s interests in security or, realizing on security. |
| Other organizations | We may disclose your information to other organizations for example in connection with a sale of some or all of First West’s assets. |
How First West protects your personal information
We are required to treat all personal and financial information confidentially. Each First West employee completes annual mandatory privacy training. Policies, practices, physical and electronic systems are in place to safeguard personal information under our control and to prevent unauthorized access, collection, use, disclosure, copying, modification, or unintentional disposal of your personal information.
How can you protect your personal information?
If you use our online banking, automated telephone banking or telephone call services, or you have a MEMBER CARD® debit card, you must select personal security codes and numbers (e.g. PAC, PIN). It is your responsibility to protect this information from misuse. You should safeguard your account and credit card statements, blank cheques and your personal codes and numbers at all times. You should not send confidential information to your credit union or anyone else using e-mail that is not encrypted.
You should review your account statements carefully and contact us immediately if your address changes or you find any errors in your information.
How long does First West retain your information?
Unless otherwise stated, First West is required by law to retain your personal information for 7 years post account closure. Account statements and transactions are retained for 7 years on a rolling destruction timeline.
Preferences
We may tell you about new First West products or services through direct mail, e-mail, by phone, or by other means. If you do not wish to receive such communications through email, you may unsubscribe through a link on the emails, by contacting the branch where you bank or from our website:
To manage preferences regarding interest-based digital advertising, see our Cookie Policy.
If you opt-out of receiving our marketing communications related to promotional offers, financial advice, or community involvement, this will not affect your eligibility for products or services. By opting-out for one account, you’ll be opting-out for all your First West accounts including joint accounts where you are the primary account holder.
We may amend this Agreement from time to time to reflect changes in our personal information practices. We will post the revised Agreement on our website and make it available at our branches.
First West Privacy Code
First West commits to complying with British Columbia’s Personal Information Protection Act “BC PIPA” and the CSA Model Code for the protection of personal information, which form the backbone of our First West Privacy Code:
- Accountability: First West is responsible for personal information in our custody and control including information that has been transferred to a third party for processing. First West has designated a Privacy Officer to be accountable for our compliance with the First West Privacy Code. All employees of First West are responsible for your privacy and compliance with this Privacy Code.
- Identifying purposes: The purposes for which personal information is collected shall be identified at or before the time the information is collected.
- Consent: The knowledge and consent of the individual are required for the collection, use or disclosure of personal information, except where inappropriate e.g. for legal requirements, medical emergencies or security reasons. An individual can withdraw consent at any time by contacting the branch or office where the individual does their banking, subject to legal or contractual restrictions and reasonable notice.
- Limiting collection: The collection of personal information shall be limited to that which is necessary for the purposes identified by First West. Information shall be collected by fair and lawful means.
- Limiting use, disclosure and retention: Personal information shall not be used or disclosed for purposes other than those for which it was collected, except with the consent of the individual or as required by law. Personal information shall be retained only as long as necessary for the fulfillment of those purposes.
- Accuracy: Personal information shall be as accurate, complete and up-to-date as is necessary for the purposes for which it is to be used.
- Safeguards: Personal information shall be protected by security safeguards appropriate to the sensitivity of the information.
- Openness: First West Credit Union shall make readily available to individuals, specific information about its policies relating to the management of personal information.
- Individual Access: Upon written request to the branch or office where an individual does business, or the Privacy Officer the individual shall be informed of the existence, use and disclosure of his or her personal information and shall be given access to that information except where inappropriate. An individual shall be able to challenge the accuracy and completeness of the information and have it amended as appropriate. Access will be given no later than 30 calendar days after receipt of the request. Costs to comply with the request are at the requestor’s expense. The individual will be informed of the approximate costs in advance. Refusal to provide access for valid reasons will be explained in writing to the individual. Some possible reasons for refusal are: access would reveal information about a third party; information is protected (e.g. solicitor-client privilege); access threatens life or security of another individual; access reveals confidential commercial information; access reveals information generated in the course of a formal dispute resolution process; access reveals information gathered for reporting a breach of an agreement or contravention of a law.
- Challenging compliance: An individual shall be able to address a challenge concerning compliance with the above principles to the designated individual or individuals accountable for First West’s compliance (refer to Principle 1 Accountability above).
First West Online Privacy Policy
This information page describes in general terms how your personal information is collected and used within the online banking section of our site. The online banking area of the site is the area of our website that requires you to use your Member ID and Personal Access Code (PAC) to enter.
Controlled access to your information
To ensure that you are the only person accessing your personal financial information, we restrict access to the online banking section of the site by requiring that you enter your Member ID and PAC to login. Only you know your PAC. Our employees do not have access to your PAC, and they will not ask you to reveal it. If someone does ask you to provide your PAC to them, we ask that you refuse to do so and contact us immediately.
Transactional services
By nature, our Internet banking site has many transactional functions such as transfers between accounts and bill payment functions. 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 information. We store and use your transactional information in the same fashion as if you performed the transaction at a branch or through any other service channel.
We may also use transactional information for servicing your account — for example, billing you for the particular transactions that you perform, or for the services that you use.
Creating a secure channel
We create a secure channel between your browser and our server to protect your information when you use the site. First West implements a number of measures to provide secure online and mobile banking, including:
- Automatic session timeouts—To prevent certain forms of session hijackings, online and mobile banking sessions automatically end if inactive for 15 minutes.
- Temporarily disabling online accounts—To prevent against brute force password guessing attempts, online accounts are temporarily disabled if too many failed attempts to login are recorded.
- Data encryption—Our online and mobile banking services ensure that any information in transit between your PC or mobile device and our banking environment cannot be read or altered.
- Communication standards—We will never ask you to provide your passwords in email or any other communication method.
Application forms
To provide you with a convenient method for applying for loans and mortgages, or for purchasing other financial services products such as Registered Savings Plans, we may provide secure online application forms. These forms capture personal information that we use to provide you with the products and services you request. This information is processed in a similar way to application forms received through our other channels.
Website usage statistics
To continually improve our site, we often collect statistics about how our members are using it. These usage statistics are only viewed in the aggregate and are not associated with you as an individual. We use this information for purposes such as improving the pages where our members are having difficulties.
The information collected may include your IP address, your browser type and your operating system, as well as data such as the number and types of pages visited, and the length of time spent per page and on the site overall.
Our use of cookies
We also use a key web technology called cookies. A cookie is a small information token that sits on your computer. As you use this site, cookies are passed back and forth between our server and your browser.
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 online 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 you to set some level of control over which cookies are accepted and how your browser uses them. For example, it may be set to notify you when it is receiving a cookie so that you accept cookies from only known, reliable sites such as this one. 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.
Third-party cookies
From time to time, we work with third-party companies such as digital media agencies, which assist us in advertising our products and services. These third-party companies use “cookies” to do so. Typically, these “cookies” expire once you are finished with your visit to our website. These “cookies” are solely used for advertising purposes and are not used to collect your personal information or to track you in any other way.
Memorized accounts feature
We use a persistent cookie to store information to help you personalize the site and to make it easier to use. For example, we allow you to make the login easier by remembering your login information within our Memorized Accounts feature. Since the Memorized Accounts feature is optional, this cookie only contains information that you have entered into it. We never store your Personal Access Code (PAC) in a cookie.
Logout button
To ensure that no-one else can access your personal information, always use the logout button to end an online banking session. It is 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 Member ID and PAC are re-entered.
Automatic session time-outs
In the event that you leave your computer without logging out, the online banking feature of this 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 PAC again.
Email
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 then store your email and our replies to you in case we correspond further.
Links to other sites
Our 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, we have no control over these other websites or Internet resources and do not control their collection, use and disclosure of your personal information. Always review the Privacy Statements of the sites that you are viewing.
Contact us
We welcome any questions or concerns about your privacy relating to use of our website. Please use the contact us form to submit your questions or comments.
As we continue to expand our online banking service to serve you better, and as new Internet technologies become available, we may update the information on this page at any time, to reflect changes.
RIGHT TO ACCESS YOUR INFORMATION
You have the right to access the personal information maintained about you in First West’s records. You may also submit documentation to correct errors or omissions in personal information maintained about you in First West’s records. To view or submit corrections to your personal information records, please contact the branch where you do your banking. You may also address your request, in writing, to our Privacy Officer at the contact information below.
Questions or concerns about privacy
If you have any questions or concerns about First West’s Privacy Code or practices, please contact the branch or office where you do your banking. You may also address your request, in writing, to our Privacy Officer at the contact information below.
A copy of our complaint handling procedures can be requested in branch and is published on our website.
CONTACT INFORMATION
Privacy Officer
First West Credit Union
3rd Floor 184 Main Street
Penticton, BC V2A 8G7
Phone: 250-490-2735
Toll-Free: 1-833-215-9192
E-mail: privacyofficer@firstwestcu.ca