Home Trust Company is committed to maintaining the security and confidentiality of your personal information secure and confidential and this Privacy Code outlines the measures we take to ensure these goals. In this code, “we”, “our” and “us” mean, collectively, the companies affiliated with Home Trust Company, including its parent company, Home Capital Group Inc., and its subsidiary, Home Bank. Also, “you” and “your” mean an individual who has made an application to us, or provided a guarantee, for any product or service provided by us.
If you have concerns or questions that you feel are not addressed by this code, please contact the Home Trust Company Privacy Officer at the address listed below in the “Contact” section.
What Is Personal Information?
Personal information is information that is specific to you. We use it not only to identify you as our customer but also to understand your needs and how we can serve you better. This information includes, but is not limited to, your name, address, date of birth, identification numbers (such as your SIN), income, assets, liabilities, source of funds and references, as well as your financial and employment records. Personal information may also include whether or not credit was extended and to whom the information was disclosed.
Why Do We Collect Your Personal Information?
There are several reasons why we collect and use your personal information. Most of these relate to the day-to-day operations of the Company and facilitate the delivery of services and products we provide to you. When you apply for, or provide a guarantee in respect of, any of our personal financial products or services and while you are our customer, you agree that we may collect your information in order:
- To identify you and to understand your needs
- To determine the suitability of our products and services for you
- To determine your eligibility for our products and services
- To inform you about other products and services that may meet your needs
- To provide ongoing service
- To comply with legal requirements and regulations
You also agree that we may use information about you, including the way in which you use our products and services, to tell you about our products and services, including giving information to our affiliates where permitted by law.
We will make sure that you are aware of these purposes when you apply for any of our products or services. Self-evident purposes should be clear but if you have any questions, just ask us. If a new purpose for using your personal information should develop, we will ask you for your consent before using it.
Additionally, we will not keep any of your personal information if it is no longer required to fulfill these purposes or to comply with legal or regulatory requirements.
Applying For A Personal Credit Facility
When you apply for, accept or guarantee a loan or credit facility, as well as during the course of the loan or credit facility, we may use, give to, obtain, verify, share and exchange credit and other information about you with others including credit bureaus, mortgage insurers, creditor insurers, registries and other persons with whom you may have financial dealings, as well as any other person or entity as may be permitted or required by law. You also authorize any person whom we contact in this regard to provide such information to us.
During the term of the loan or credit facility, you may not withdraw your consent to our ongoing collection, use or disclosure of your personal information in connection with the loan or other credit arrangement you have with us or have guaranteed. We can continue to disclose your personal information to credit bureaus even after the loan or credit facility has been retired, and you may not withdraw your consent to our doing so. We do this to help maintain the accuracy, completeness and integrity of the credit reporting system.
Privacy And Your Social Insurance Number (SIN)
We request your SIN in order to comply with tax reporting requirements. When you open a deposit account with us, these accounts accrue interest. Under the law, we are obligated to report this interest.
The 10 Principles
There are 10 principles that govern our Privacy Code.
Maintaining the security and confidentiality of your personal information is the responsibility of every employee at the Company and every supplier that we work with. All employees are required to sign a confidentiality agreement, which prohibits them from disclosing or otherwise using your information without your consent. This applies even after they no longer work for the Company. In addition, employees and our suppliers are informed about, and must comply with, the policies and procedures we have in place surrounding the collection, use and storage of your information.
2. Why We Collect Your Information
We collect your personal information in order to identify you as our customer and to provide you with products and services. Your information helps us to determine your needs, what products and services would suit you and your eligibility, as well as to provide you with information on other products and services (provided by us or by our affiliates) that you might be interested in. This could involve direct marketing – e-mail, mail, telephone – or other means.
We also collect your information to comply with laws and regulations.
We will make a reasonable effort to make sure customers understand why they are providing us with personal information and what we can or will do with that information. You can express your consent to us orally (such as over the telephone), in writing (on an application) or electronically (via the internet).
You can have your name deleted from our marketing lists if you do not wish to receive our direct marketing communications.
You can refuse to provide us with personal information – or withdraw your consent if you have already provided us with information – provided the consent does not relate to a credit or deposit product. However, you must give us reasonable notice of the withdrawal of your consent and provide us with your request in writing. This withdrawal may affect our ability to provide you with certain products.
We can collect, use or disclose personal information without your knowledge and consent in a limited number of instances, in order to:
- Detect and/or prevent criminal activity
- Collect overdue accounts
- Comply with legal requirements
- Carry out routine banking functions like data processing or the printing of credit cards
4. Limits On Collecting Information
We collect your personal information directly from you for the purposes listed above. We may also collect information from external sources such as credit bureaus, employers and other lenders. We ask for your consent for this external collection and for the ongoing reporting of your information to credit bureaus in order to maintain the integrity of the credit-granting system and the accuracy and completeness of information held by credit bureaus.
5. How We Use, Disclose And Store Your Information
Customer files, or their electronic equivalents, are located at our Ontario office. We will use or disclose your personal information only for the reasons it was collected – as mentioned above in this code. Disclosure involves providing specific information about you from our records to a third party. When you apply for credit from the Company you are expressing your consent to the terms outlined on the application and the disclosure document outlining the uses of your information. If a new purpose is developed in the future, we will notify you and request your consent prior to using your information for this new purpose.
For account servicing purposes, we may provide your personal information, in limited form and only as necessary, to our service providers without your consent. Those service providers are required to safeguard the information in a manner that meets the standards of our privacy and security policies. In some cases, our service providers may be located in a foreign jurisdiction and may disclose information in response to lawful requests from governments, courts, regulators or law enforcement in that country.
We will keep personal information as long as necessary for the identified purposes, even if you cease to be a customer.
6. Keeping Your Information Accurate
The Company seeks to maintain the accuracy, completeness and relevance of your personal information. However, it is your responsibility to notify us if there is any change to your personal information so we may update your files.
You may challenge the accuracy and completeness of your personal information and we will make any necessary amendments that we feel are appropriate. If the information has been provided to third parties with your consent, we will convey any corrected information to them as necessary.
7. Keeping Your Information Secure
We ensure the physical, organizational and electronic security of your personal information. For that reason, we contract with key suppliers that have a proven track record. For greater certainty, we conduct periodic reviews of all our key suppliers to ensure their compliance.
Physical access to areas where information is collected, stored or processed is restricted to authorized employees and agents only. Also, controls exist over computer systems and data processing procedures that are reviewed on an ongoing basis to ensure compliance with our Privacy Code.
We destroy, erase or make anonymous any personal information that is no longer required to meet legal requirements or serve our stated purposes.
We make information about our policies and procedures available to customers. This information is made available in a manner that uses simple language and is easy to understand. Through our documentation you will be able to find out:
- The title and office address of the person at the Company who is responsible for responding to your requests about the privacy of your information
- How to access information under our control
- What type of information is under our control, and what it is used for
For any inquiries regarding our policies and procedures, please contact the Company’s Privacy Officer at the address listed in the contacts section below.
9. Your Access To Your Information
When you request it, we will tell you what personal information we have, what it is being used for, from whom it was collected and to whom it has been disclosed (where permitted by law). This is your right. We will provide the personal information in a timely manner, and for a reasonable cost. We will also provide you with access, upon request, to your own personal information, except in certain situations. We will explain the reason for this lack of access when you make your request.
We will not provide the personal information if it:
- Is too costly to retrieve
- Contains references to other persons
- Is subject to solicitor-client or litigation privilege
- Contains our own “proprietary information.” For example, we may use a scoring formula, form an assessment of risk or make a collection recommendation that is confidential to us
- Cannot be disclosed for legal reasons
- Is used for the detection and prevention of criminal activity and dealings in proceeds of crime
We will not record in your individual files when personal information was disclosed to third parties for routine purposes, like:
- Reporting to the Canada Revenue Agency (T5 and other reports)
- Regular updating of credit information to credit bureaus
- Indicating to third parties when payments are returned NSF (not sufficient funds)
If we deny your request for access to personal information, we will tell you why. You may then challenge our decision. See Principle 10.
You may also challenge the reasonableness of the cost of providing personal information.
10. Dealing With Your Concerns And Questions
The Company has policies and procedures to receive, investigate and respond to customers’ complaints and questions. We will deal with your questions and concerns as quickly and as comprehensively as possible. All inquiries should be sent to the Company’s Privacy Officer at the address supplied in the contact section below.
The security and confidentiality of your personal information is a high priority for the Company. If you have any concerns regarding this Privacy Code or have any further questions, you may bring them to our attention as follows:
Chief Privacy Officer
145 King St. W., Suite 2300
Toronto, Ontario M5H 1J8
Telephone: 1-877-903-2133 ext. 5075
(in Toronto 416-775-5075)
If the Company is unable to answer your questions or satisfy your concerns regarding this privacy code, you may refer to our Customer Complaint Procedures (available in branches or on our website) for further guidance.