Privacy Code

 Your Privacy Is Our Priority

Credit Unions have a history of respecting the privacy of their members. Your Board of Directors has adopted the Credit Union Code for the Protection of Personal Information (“Privacy Code”). We have policies and procedures in place to protect your privacy and your right to control the collection, use and disclosure of your personal information.

Why Do We Collect Your Personal Information

We use your personal information to help us provide the highest standards of financial service.

We collect this information from you directly, with your consent, and according to the terms of the Personal Membership Agreement and/or product and service agreements you have made with or through us or your ongoing relationship with us. Personal information is also obtained with your consent from credit bureaus, other financial institutions and from the references you provide to us.

Your personal information is collected for one or more of the following purposes:

  • to verify your identity;
  • to understand your needs and eligibility for products and services, using third party market research firms, focus group sessions, etc…;
  • to open, maintain and administer your accounts and provide financial services that meet your needs;to obtain credit reports, evaluate your credit rating and credit worthiness, and check references;
  • to administer and manage security and risk in relation to your accounts and the financial services provided to you;
  • to comply with legal and regulatory requirements;
  • to offer and provide you with other products and services of the credit union and of our affiliates and service suppliers;
  • to prevent or detect fraud or criminal activity, and manage or settle any loss therefrom.

What Personal Information Do We Collect?

The information we collect may include, but is not limited to your address, telephone number, email address, occupation, date of birth, gender, income, marital status, employment history, financial records, health information (if applying for certain insurance products), Social Insurance Number (SIN) or other government issued identification numbers and credit history. You also authorize any third party from whom any of the above information is requested to provide such information to us. Health information is used solely for the provision of insurance services.

Your telephone calls with us may also be recorded in order to ensure compliance with your instructions and that the highest level of customer service was provided.

The law requires us to ask for your SIN when you open an interest-bearing account or when you obtain products or services that require reporting to certain government agencies. We also may use it to identify you with credit bureaus and other financial institutions for credit matching purposes and other purposes related to your ongoing relationship with us. However, providing your SIN is not a condition of service, except to the extent required by law.

With Whom Do We Share Your Personal Information?

We only share your personal information with your consent or where we are required or permitted to do so by law. We never sell, rent or lease personal information to third parties.

We do not keep a record when personal information is disclosed through routine reporting to government agencies (for example, a T5 Statement of Investment Income and other reports to Canada Revenue Agency (CRA)) as required by legislation or regulation.

We use trusted, reputable suppliers to provide services such as, but not limited to, the following: cheque and statement printing, data processing, member research and surveys, and payment clearing services. We provide suppliers with only the information necessary to perform the required services. To ensure confidentiality, personal information is removed from market research and survey reports provided to the credit union.

We ensure our suppliers implement security standards for information handling that are equal to our own, and we require them to protect your information in a manner that is consistent with our Privacy Code. In the event our suppliers are located outside of Canada, they are subject to the laws of the foreign jurisdiction and may be required to disclose personal information in accordance with those laws.

Your information is sometimes shared with our partner organizations that include co-operative companies and/or other similar organizations, including third party insurance providers, to ensure we offer you a full range of financial products and services, and in relation to insurance policy issuance and adjudication of claims. Our partner organizations are also required to protect your information in a manner that is consistent with our Privacy Code.

Should we, or any division or part of our business, or any loan(s) including a loan portfolio, be acquired in a commercial transaction, your information may be released to a potential purchaser, provided that the potential purchaser is required to protect your information in a manner that is consistent with our Privacy Code.

Should we seek to sell, transfer, or otherwise convey to a potential purchaser any asset over which you have given us security for a loan, your information may be released by us to such potential purchaser upon their request, as part of such potential purchaser’s due diligence, including: information about such asset, the terms and conditions of the loan secured by the asset, the balance of the loan, and the status of default under the loan.

Should you hold a mortgage product with us, we may share your information with mortgage insurers as required. Any information provided to the Canada Mortgage Housing Corporation, a federally regulated insurer, is subject to federal access to information and privacy legislation.

Your information may also be shared with financial service industry databases, investigative bodies designated under the regulations of the Personal Information Protection and Electronic Documents Act (PIPEDA), or as may be required by a regulator pursuant to the Credit Union Act.

Your Right To Access And Verify Personal Information

You have the right to access, verify and update your personal information at any time. For more information on this, please contact us.

10 Principles of the Credit Union Privacy Code

Accountability

We have designated a Privacy Officer who is accountable for our compliance with the principles of the Privacy Code. Their contact information can be found at the end of this Privacy Code.

Identifying Purposes

Before or at the time that we ask for your personal information we will identify the purposes for which it will be used or disclosed.

Consent

We require your knowledge and consent for collection, use or disclosure of your personal information. You may revoke consent to further collection, use or disclosure of information at any time by giving reasonable notice in writing to us, except as restricted by this Privacy Code.

Limiting Collection

The collection of personal information shall be limited to that which is necessary for the purpose identified by us.

Limiting Use, Disclosure and Retention

If you have provided explicit limited consent, your personal information shall not be used or disclosed for purposes other than those for which it was collected or as required by law. We will retain your information only as long as necessary to fulfill identified purposes and legal requirements, including where your relationship with us has ended.

Accuracy

We will endeavor to keep your information accurate, complete and up-to-date.

Safeguards

We will protect your personal information with appropriate security safeguards.

Openness

We will make specific, understandable information readily available to you about our personal information policies and practices in relation to the management of your personal information.

Individual Access

When you request it, we will give you access to the existence, use and disclosure of your information. You are entitled to question its accuracy and completeness and its uses. You have a right to have your information updated and amended as appropriate.

Challenging Compliance

You are entitled to inquire with the Privacy Officer about our compliance with any of these principles. The Privacy Officer will investigate and respond to your questions and concerns.

Your Consent

We collect, use and disclose your information only with your consent, unless we are obligated to disclose your personal information by law.

In most cases we will obtain your express consent in writing. However, on occasion, your consent may be implied. For example, we may possess and use personal information that we collected from you prior to implementing our Privacy Code and for which we do not have your express written consent. However, because the information was obtained in relation to products or services that you requested, or in relation to our ongoing relationship with us, your consent to our use of such information is considered implied. In all cases, your personal information may be used for the purposes described herein, including disclosure to partner organizations unless you specifically ask us, in writing, to cease such disclosure.

You can refuse to consent to our further collection, use or disclosure of your personal information at any time in the future by giving us prior written notice. This can be done by contacting our Privacy Officer by electronic or traditional mail at the addresses described at the end of this Privacy Code. However, withdrawal of your consent may limit our ability to provide products or services to you. As a result, in order to use certain of our products and services or maintain an ongoing relationship with us, you cannot refuse our collection, use and disclosure of personal information required by us and partner organizations that provide essential services to us.

Insurance Services

We may provide, obtain, and verify your information in relation to any application for insurance submitted by you to us.

Information We Collect On Our Site

You can visit all public areas of our website without providing any personal information about yourself. Our website collects only non-personal information based on a visitor’s Internet Protocol (IP) address (this is not personally identifiable). Information collected includes the date and time of visit, the type of internet browser used to access the site, and the referring address (the link a visitor uses to access the website). This data is used to create statistics on site usage and improve online services.

If you send us an email, any information provided by you will only be used for the purposes of responding to your inquiry or acting on your request. We will not use your name or email address for any other purposes without additional consent.

Links To Other Websites

Our website contains links to other websites that are part of, affiliated with, or have business relationships with NLCU. When you leave our website to visit one of these other sites, the only information transferred to the new site is the fact that you came from our website, www.nlcu.com. Transmission of this referring address allows other sites to monitor their own web traffic but does not disclose any personal information about you.

Amendment

This Privacy Code may be amended from time to time as we determine is necessary, taking into account legislative changes and other issues which may arise. The amended Privacy Code will be posted to our webpage and may also be sent to you by electronic or traditional mail.

Questions? Ask our Privacy Officer

The Privacy Officer is responsible for monitoring information collection and data security and ensures that our employees receive appropriate training on privacy issues and their responsibilities under the Privacy Code. The Privacy Officer also handles all privacy inquiries and personal information access requests under the Privacy Code. Privacy inquiries and access requests can be submitted by electronic or traditional mail at the addresses below.

Ultimate responsibility for our compliance with the Privacy Code rests with our Board of Directors.

We welcome any questions or concerns about our Privacy Code, or the practices of this website. Please contact our Privacy Officer at privacyofficer@NLCU.com or in writing at the following address:

240 Water Street,
St John’s, NL  A1C 1B7
Attention: Privacy Officer