Crossroads Credit Union and its employees have always been committed to delivering a high quality of service to members and customers. The Market Code that follows builds on this commitment. This Market Code identifies the market practice standards and how the Crossroads Credit Union subscribes to the standards.
Complaint Handling
Contact Privacy Officer
Privacy
Complaint Handling
What Is Our Commitment to You?
Developing and fostering long-term relationships is the foundation of our commitment to service. The credit union and our employees have always been committed to delivering a high quality of service to members and non-member customers. Our Market Code builds on this commitment by identifying the standards we embrace as an organization, the way we conduct ourselves and how we will continue to treat you as we work to maintain your trust, while living out our co-operatives values.
Naturally, we hope you are happy with the service we provide. However, we know that things can sometimes go wrong. As part of the Market Code, we have implemented a formal complaint handling process to deal with these situations. If you have a concern or a complaint about the service we provide or the product lines we offer, we want to hear from you. If we get things wrong - it is important that you tell us so we can try to make matters right. This also helps us to improve our service in the future.
How Can You Contact Us?
Please let us know if you have any questions, complaints or concerns about your dealings with the credit union. While most questions can be answered by the credit union staff, for complaints and concerns, it is preferable to follow the process outlined below:
Complaint Handling Process
Frequently Asked Questions
Complaint Form
Gather Your Facts (Step 1)
Before you call or come in with a complaint, put together any relevant paperwork. Try to pinpoint the date when the problem arose. Get the names of any staff members involved and finally, get a clear picture in your mind of what the circumstances were - and what you'd like us to do.
If the issue is complicated, it may be best to send a written complaint detailing the issue. Always document the names of people you talk to, including times, dates and outcomes of the discussions. Taking these steps will assure that your concerns are addressed in a fair, effective and prompt manner.
Start Where the Problem Started
It's easiest to check facts and make corrections at the place where the problem started - your credit union, your investment adviser, your insurance agent, your mortgage broker, etc. - wherever the issue started out, make that your first call. The credit union complaint handling process will provide fair treatment to members and ensure complaints are dealt with in a courteous and timely manner.
The sooner you contact us the sooner we can begin working on a solution.
Don't Give Up
If the employee you approach can't help you resolve things, ask to speak to the compliance officer or senior manager. They have the authority to solve most problems right away.
Crossroads Credit Union Privacy Officer
privacyofficer@crossroadscu.ca
If you're still not satisfied, get in touch with the credit union Ombudsman.
Take it to the Ombudsman (Step 2)
When all else fails, you still have options.
You can take your complaint to the Saskatchewan credit union system's Ombudsman - the SaskCentral Ombudsman. The SaskCentral Ombudsman seeks satisfactory resolution of complaints with a view to fairness and does not advocate for either the complainant or the credit union when investigating disputes. This service is free of charge to the complainant but there is no provision for the award of costs to solicitors or other professionals and recommendations are not binding on credit unions.
SaskCentral Ombudsman
P.O. Box 3030
2055 Albert Street
Regina, SK S4P 3G8
Telephone: 1-306-566-7670
Fax: 1-306-566-1372
E-mail: ombudsman@saskcentral.com
Ombudsman for Banking Services and Investments (Step 3)
Certain disputes that remain unresolved after being reviewed by the SaskCentral Ombudsman can be forwarded to the Ombudsman for Banking Services and Investments (OBSI).
The OBSI is available to settle certain complaints that cannot be settled through the internal complaints handing process. The OBSI is an independent federal organization that investigates customer complaints against financial services providers, including banks, credit unions and other deposit-taking organizations, investment dealers, mutual fund dealers and mutual fund companies. This service is also free of charge.
Ombudsman for Banking Services and Investment
PO Box 896, Station Adelaide
Toronto, Ontario M5C 2K3
Toll-free: 1-888-451-4519
Toll-free Fax: 1-888-422-2865
E-mail: ombudsman@obsi.ca
Website: www.obsi.ca
For more information on our Market Code, please call our compliance officer at 306.563.5641.
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Crossroads Credit Union Market Code
Crossroads Credit Union and its employees have always been committed to delivering a high quality of service to members and customers. The Market Code that follows builds on this commitment. This Market Code identifies the market practice standards and how the credit union subscribes to the standards.
Our Conduct and Co-operative Values
The Market Code represents the standards we embrace as an organization, the way we conduct ourselves and how we will continue to treat our existing and potential members and customers as we work to maintain your trust, while living out our co-operative values.
We subscribe to the co-operative principles as endorsed by the International Co-operative Alliance and the international credit union operating principles as endorsed by the World Council of Credit Unions. We are member-owned and democratically controlled. Our goal is to provide a measurable economic and social benefit to members and communities by incorporating the following values in all that we do:
Co-operation and Accountability - Co-operatives are based on the values of self-help, self-responsibility, democracy, equality, equity and solidarity. We work together through a belief that we can accomplish more together than alone. We take into account the effect of our actions on others. In the tradition of our founders, co-operative members believe in the ethical values of honesty, openness, social responsibility and caring for others.
Communication - We communicate in an open, effective and timely manner.
Community Impact - We actively support the development of our communities locally, provincially and beyond. Our communities are stronger because of the credit union system.
Employee Satisfaction - We respect our employees and their contribution to our success. We encourage employee involvement and participation. We recognize and reward them for their creativity, teamwork and achievement. We support their development by providing training and educational opportunities. We respect their need to balance personal and professional lives.
Financial Strength - Our strong financial performance allows us to invest in our members and the community for future growth. We balance the need for financial results with the needs of our members and communities. The trust and confidence of our members is maintained through sound business practice.
Product and Service Excellence - We work with our members and communities to understand their needs, and respond with innovative, high quality products and services. Our employees provide friendly, knowledgeable and helpful service.
Professional Conduct - Members' financial affairs are conducted with integrity and in a professional manner. Our ethical principles are rooted in concern for the individual. Confidentiality is integral to the way we do business.
The Co-operative Difference
Members, in addition to accessing financial services from the credit union, are also owners and decision-makers that have a say in the credit union's actions. You elect a board of directors to provide leadership and ensure that members' views are represented.
Being an owner also means sharing in the credit union's success. The credit union's financial success is shared with its membership in accordance with the board's direction and in keeping with prudent business practices. Sharing in the credit union's success can mean we offer lower interest rates and service fees, distribute patronage dividends and contribute to community initiatives.
As a community-owned financial institution, Crossroads Credit Union is sensitive to your satisfaction with the level of service you receive. We invite you to provide us with your comments on our services.
To Whom Does the Market Code Apply?
Crossroads Credit Union has voluntarily adopted the Market Code which sets out the standards of good business practice for use to follow when dealing with consumers.
The Market Code reflects the credit union's vision, mission, values, policies and practices. Adherence to the Market Code is mandatory for all employees, directors, board-appointed committees and officers.
It is our responsibility to understand and follow the Market Code and act in accordance with the highest standards of personal and professional integrity. Similarly, we expect third parties providing credit union services to maintain high standards of business conduct and ethics. To that end, service providers also receive a copy of the Market Code.
The Market Code applies to all products and services offered by the credit union whether provided by branches, over the phone, by mail, on the Internet or through any other service delivery method.
Crossroads Credit Union is committed to supporting the Market Code by providing employees, directors, board-appointed committees and officers with orientation and information that ensures understanding, awareness and commitment. Their good judgment in applying the Market Code determines the conduct of the credit union.
We will continuously explore and adhere to standards of practice and service in the financial services industry that are in keeping with our co-operative values.
Our Key Commitments to You
We will act fairly and reasonably in all our dealings with you.
We will make sure that our advertising and promotional literature is clear and not misleading and that you are given clear information about our products and services.
When you have chosen an account or service, we will give you clear information about how it works, the terms and conditions and the fees and charges that apply to it.
We will help you use your account and services by providing regular statements (where appropriate) and we will keep you informed by providing notices of changes to the interest rates, charges or terms and conditions.
We will try to help you deal with things that go wrong.
We will have a complaint resolution process available to you, with no charge applied by the credit union, to address any complaints or concerns that may arise.
As per the credit union's Privacy Code, we will treat all your personal information as private and confidential, and operate secure and reliable banking and payments systems.
We will train our employees so they are qualified and capable of fulfilling their duties.
We will abide by our co-operative values defining our standards of business conduct and ethics.
We will publicize our Market Code, have copies available and make sure our employees are trained to put it into practice.
We will meet our commitments in the Market Code.
Principles in Action
Products and Services to Meet Your Needs
We will provide general information about your rights and obligations that arise out of our relationship with you in relation to the banking services we provide. This will be provided at account opening when the Financial Services Agreement is completed, when the rights and obligations contained in the Financial Services Agreement are revised and throughout our relationship with you when the products/services you acquire from us carry specific rights and obligations.
We will facilitate informed decisions about our banking services:
by providing disclosure of product and service information at the time of inquiry and/or at the time of acquisition. When this is not possible, information will be provided as soon as possible afterward. Relevant information will be provided along with product information to help you understand the basic financial implications of the transaction, the fees and charges associated and any terms and conditions that apply.
- by providing information in plain language.
- by answering any questions you may have.
- by explaining to you, when asked, the written information that has been provided.
If you ask us for assistance in helping you plan the management of your financial affairs, we will:
- work with you to complete a Financial Planning Relationship Agreement and provide advice through authorized and licensed staff; or
- refer you to appropriate external sources for advice; or
- recommend you seek advice from another source.
If a product supplied is acquired from a third party, we will disclose relevant relationships to you at the time of product inquiry and/or product acquisition. The credit union may receive compensation from the sale of third party products or services.
We will do our best to avoid situations where there is a conflict of interest. When there is a potential or perceived conflict of interest, we will bring this to your attention and you will be given the opportunity to cancel, postpone or continue with the transaction.
We will not discriminate against you on the basis of race, religion, age, pregnancy, marital status, gender, sexual orientation, ethnic or social origin, disability, color, ethics, belief, culture, language or birth, except to the extent that a distinction is required or justified by any law or to the extent that the factor has commercial implications or if a special product or service offering is designed for all members of a particular target market group.
Advertising and Sales Practices
We will ensure our advertising and promotional literature is not deceptive or misleading.
We will not practice tied or coercive selling.
We will not impose undue pressure or coerce you to obtain a product or service from the credit union and any of its affiliates as a condition for obtaining another product or service from the credit union. You will not be unduly pressured to buy a product or service that you do not want in order to obtain another desired product or service. The credit union may show its interest in your business or appreciation of your loyalty by offering preferential pricing or bundling of products and services with more favorable terms. These practices should not be confused with coercive tied selling.
Our requirements will be reasonable and consistent with our level of risk. The law allows us to impose reasonable requirements on consumers as a condition for granting a loan or to provide a specific service, but only to the extent necessary for us to manage our risk or our cost or to comply with the law.
We will not knowingly take advantage of anyone through manipulation, concealment, abuse of privileged information, misrepresentation of facts or any other unfair dealing or unethical activity.
We will act fairly and reasonably towards you in an ethical manner; in doing so, we will consider your conduct, our conduct and the contract between us.
In meeting our key commitments to you, we will have regard to our prudential obligations.
Access to Basic Banking
We recognize the importance of access to banking services, so we will take reasonable measures to ensure access to a basic banking account. A credit union may restrict account services to reasonably protect the credit union from credit losses from account users.
Account Statements
To help you manage your account and check activity on it, we will provide regular account statements depending on the financial services being accessed. Statements may be provided monthly, quarterly or - at a minimum - annually. A statement may not be provided if, after taking reasonable steps, we are unable to locate you.
Notice of Service Fee Changes and/or Account Structure Changes
We will provide a minimum of 30 days notice for changes in service fees and/or changes in account, product, or service structures that you are receiving.
Notice of Branch Closure
We will provide a minimum of four months notice in the event of a credit union branch closure.
Employee Training and Competency
We will ensure our employees are trained with appropriate accreditations and licensing so that they:
- acquire an appropriate level of knowledge to competently and effectively carry out their roles and responsibilities and provide the products and services they are authorized to provide; and
- meet professional ethical standards and act with a high level of honesty, integrity, fairness, due diligence and skill; and
- have an adequate knowledge of the provisions of the Market Code and comply with this code in dealing with you.
If accreditations and/or licenses are not prominently displayed, employees will identify the relevant accreditations and/or licenses they maintain at the time of product inquiry and/or product sale.
Abiding by the Law
We will ensure that all products and services comply with relevant laws and regulations.
We will comply with all applicable laws, rules and regulations of federal, provincial and local governments and other applicable public and self-regulating agencies as well as credit union policies that affect how we do our jobs.
Administration of the Market Code
Copies of the Market Code
The credit union will make copies of the Market Code available to all members and customers. The credit union will also have notices in all branches explaining that copies of the Market Code are available. Where provided, the credit union will publish the Market Code on its website.
Accountability
The credit union is responsible for adherence to the Market Code and will designate a Compliance Officer who is accountable for the credit union's compliance with the Market Code. Ultimate accountability for the credit union's compliance with the Market Code rests with the credit union's Board of Directors.
The credit union will identify the Compliance Officer responsible for the day-to-day compliance with the Market Code to its members, customers and employees.
The credit union will implement policies and procedures to give effect to the principles, including:
- procedures to receive and respond to concerns and inquiries;
- training staff to understand and follow the credit union's policies and procedures; and
- an annual review of the effectiveness of the policies and procedures to ensure compliance with the Market Code and to consider revisions.
The credit union will periodically remind employees, officers and directors of the importance of the Market Code. The credit union has adopted a Code of Conduct that sets standards for the business and ethical conduct of employees. Employees, officers and directors are required to sign a declaration stating that they review the credit union's Code of Conduct annually and commit to uphold the principles in the Market Code.
Questions about the Market Code?
Contact the credit union's Compliance Officer if you have questions about the Market Code. The name of the Compliance Officer is available by contacting the credit union. The credit union will respond to inquiries, questions or concerns within a reasonable amount of time and at no cost or at a reasonable cost to you. The requested information will be provided or made available in a form that is generally understandable.
If the Market Code is not being followed, the credit union will seek to correct the deficiency.
If your inquiry, question or concern is not resolved to your satisfaction, it will be recorded by the credit union. When you make an inquiry or lodge a complaint, you will be informed of complaint handling procedures by the credit union.
Complaint Handling
The credit union has a published complaint handling policy endorsed by the credit union's board of directors formalizing its commitment to the complaint handling process.
We will prominently post the availability and accessibility of the process for resolving complaints on our website. We will also provide you with information about the process for resolving complaints at the time they arise.
We are participants in the Ombudsman for Banking Services and Investments (OBSI) and the Centre for the Financial Services OmbudsNetwork (CFSON). The OBSI is an external organization that is available to settle financial services complaints if they cannot be settled through the financial service provider's internal complaint handling process. The CFSON provides Canadian financial services to consumers with a single-window access to high quality, independent, impartial and effective complaint resolution services in banking, life and health insurance, general insurance, securities and mutual fund industries.
The details of the credit union's three step complaint handling process are as follows:
Step 1: Crossroads Credit Union
If you have a complaint or concern, the first place to make it known is at the credit union. This process will be:
- free of charge;
- in accordance with industry complaint handling standards for an internal dispute resolution process. The standards reflect a commitment to a consumer-oriented approach to complaint handling and redress including accessibility, timeliness, courtesy, clarity, accuracy and consistency;
- available to you by contacting the credit union and asking for the Complaint Officer; and
accessible via phone, fax, e-mail, in person, or in writing.
Step 2: Provincial Credit Union Ombudsman
Consistent with industry standards, the credit union system has established the Office of the Ombudsman to help with matters that remain unresolved. If you feel your problem is unresolved after dealing with the credit union, you may contact the Office of the Ombudsman. The Ombudsman process will be:
- free of charge;
- in keeping with industry ombudservice standards for an industry level complaint handling process. The standards reflect the principles of knowledge, fairness, impartiality, confidentiality, objectivity and independence;
- administered to ensure complaints are treated fairly and consistently in a timely and courteous manner;
available to you by contacting SaskCentral and asking for the Credit Union Ombudsman; and
- accessible via phone, fax, e-mail, in person or in writing.
Step 3: Ombudsman for Banking Services and Investments
Consistent with industry standards, the credit union system has joined the Ombudsman for Banking Services and Investments (OBSI), which is an external impartial organization that helps with matters that have not been resolved to your satisfaction. If you are dissatisfied after dealing with Crossroads Credit Union and the Office of the Ombudsman, you may contact the OBSI.
This external complaint handling process will be:
-free of charge;
- reflect a commitment to a consumer-oriented approach to complaint handling including accessibility, timeliness, courtesy, clarity, accuracy and consistency;
- in accordance with the principles of knowledge, fairness and impartiality, confidentiality, objectivity and independence;
- governed by a separate board of directors whose members include a majority of independent directors; and
- available to you by contacting the Ombudsman for Banking Services and Investments or the Centre for the Financial Services OmbudsNetwork.
Definitions
Basic banking account - A basic banking account will have the following features:
- no charge for deposits;
- the use of a debit card;
- cheque-writing privileges;
- free updated account statement;
- allow at least eight debit transactions per month, at least two of which can be done in-branch; and
a maximum monthly fee of $4.00, reflecting the number of in-branch and the total number of debit transactions allowed.
Free of charge - a fee will not be charged to cover the costs incurred in dealing with a complaint. Expenses incurred by the consumer are not funded by the credit union or ombudsman and there is no provision for the award of costs to solicitors or other professionals.
Privacy
Code for the Protection of Personal Information
Crossroads Credit Union Adopted by Crossroads Credit Union Board of Directors this 19th day of December, 2002
Introduction
Crossroads Credit Union and its employees have always been committed to keeping our customer personal information accurate, confidential, secure and private. The Privacy Code that follows builds on this commitment. This code is based on the Credit Union Central of Canada Model Privacy Code and on the Model Code for the Protection of Personal Information (CAN/CSA-Q830-96) included as Schedule 1 of the federal Personal Information Protection and Electronic Documents Act. This Code describes how Crossroads Credit Union subscribes to the principles set out in those model codes.
Principles
Ten interrelated principles form the basis of the Crossroads Credit Union Code for the protection of Personal Information ("the Code"). Each principle must be read in conjunction with the accompanying commentary.
1. Accountability
Crossroads Credit Union is responsible for personal information under its control and will designate a Privacy Officer who is accountable for the credit union's compliance with the principles of the Code.
2. Identifying Purposes
The purposes for which personal information is collected will be identified by the credit union at or before the information is collected.
3. Consent
The knowledge and consent of the Member are required for the collection, use, or disclosure of personal information, except in specific circumstances as described within this Code.
4. Limiting Collection
The collection of personal information will be limited to that which is necessary for the purposes identified by the credit union. Information shall be collected by fair and lawful means.
5. Limiting Use, Disclosure, and Retention
Personal information will not be used or disclosed for purposes other than those for which it was collected, except with the consent of the Member or as required by law. Personal information will be retained only as long as necessary for the fulfillment of those purposes.
6. Accuracy
Personal information will be as accurate, complete, and up-to-date as is necessary for the purposes for which it is to be used.
7. Safeguards
Security safeguards appropriate to the sensitivity of the information will protect personal information.
8. Openness
The credit union will make readily available specific, understandable information about its policies and practices relating to the management of personal information.
9. Individual Access
Upon request, a Member will be informed of the existence, use, and disclosure of their personal information, and will be given access to that information. A Member is entitled to challenge the accuracy and completeness of the information and have it amended as appropriate.
10. Compliance
A Member will be able to question compliance with the above principles to the credit union's Privacy Officer. The credit union will have policies and procedures to respond to the Member's questions and concerns.
Definitions
The following definitions apply in this Code:
Collection
The act of gathering, acquiring, or obtaining personal information from any source, including Third Parties, by any means.
Consent
Voluntary agreement with what is being done or proposed. Consent can be either express or implied. Express consent is given explicitly, either orally or in writing. Express consent is unequivocal and does not require any inference on the part of Crossroads Credit Union. Implied consent arises where consent may reasonably be inferred from the action or inaction of the Member.
Disclosure
Making personal information available to others outside Crossroads Credit Union.
Organization
Includes an organization, partnership, association, business, charitable organization, club, government body, institution, professional practices and unions.
Third Party
Any person or organization other than Crossroads Credit Union or the Member.
Use
The treatment and handling of personal information within Crossroads Credit Union.
Person
Includes an individual and an entity.
Personal Information
Means information about an identifiable individual, but does not include the name, title or business address or telephone number of an employee of an organization
Member
Includes members and nonmembers that receive financial services from the credit union.
Principles
Principle 1 - Accountability
Crossroads Credit Union is responsible for personal information under its control and will designate a Privacy Officer who is accountable for Crossroads Credit Union's compliance with the principles of this Code.
1.1 Ultimate accountability for Crossroads Credit Union's compliance with the principles rests with the Crossroads Credit Union Board of Directors, who delegate day-to-day accountability to a Privacy Officer. Other persons within Crossroads Credit Union may be accountable for the day-to-day collection and processing of personal information, or to act on behalf of the Privacy Officer.
1.2 Crossroads Credit Union will identify to its employees and to other persons, where appropriate, the Privacy Officer who is responsible for the day-to-day compliance with the principles.
1.3 Crossroads Credit Union is responsible for personal information in its control. Crossroads Credit Union will use contractual or other means to provide a comparable level of protection while the information is being processed by a third party.
1.4 Crossroads Credit Union will implement policies and procedures to give effect to the principles, including:
Procedures to protect personal information;
Procedures to receive and respond to concerns and inquiries;
Training staff to understand and follow Crossroads Credit Union's policies and procedures: and
Annual review of the effectiveness of polices and procedures to ensure compliance with the Code and consideration of any revisions as deemed appropriate.
Principle 2 - Identifying Purposes
Crossroads Credit Union will identify the purposes for which personal information is collected when or before the information is collected.
2.1 Crossroads Credit Union will document the purposes for which personal information is collected prior to the information being collected.
2.2 Crossroads Credit Union will make reasonable efforts to ensure that Members are aware of the purposes for which personal information is collected, including any disclosures to third parties.
2.3 The identified purposes should be specified to the person from whom the personal information is being collected. This can be done orally, electronically or in writing. An application form with the purposes highlighted, for example, may give notice of the purposes.
2.4 When personal information that has been collected is to be used for a purpose not previously identified, the new purpose will be identified prior to use. Unless law requires the new purpose, the consent of the Member is required before information can be used for that purpose.
2.5 Identifying the purposes for which personal information is being collected at or before the time of collection also defines the information needed to fulfill these purposes. Crossroads Credit Union will collect personal information for the following purposes:
- Understand Members needs and eligibility for products and services
- Open, maintain and administer Member accounts and provide financial services that meet Member needs;
- Administer and manage security and risk in relation to Member accounts and the financial services provided to Members;
- Comply with legal and regulatory requirements;
- Assist in dispute resolution;
- Offer and provide Members with the other products and services of the Credit Union and of its affiliates and service suppliers.
- Meet personnel requirements
Principle 3 - Consent
The knowledge and consent of the Member are required for the collection, use, or disclosure of personal information, except in specific circumstances as described within this Code.
Note: In certain circumstances personal information may be collected, used, or disclosed without the knowledge or consent of the Member. These circumstances include, but are not limited to:
- Where clearly in the interests of the Member and consent cannot be obtained in a timely way;
- To avoid compromising information availability or accuracy and if reasonable to investigate a breach of an agreement or a contravention of the laws of Canada or a province;
- Where the information is considered by law to be publicly available;
- To act in respect of an emergency that threatens the life, health or security of a Member;
- To investigate an offence under the laws of Canada, a threat to Canada's security, to comply with a subpoena, warrant or court order, or rules of court relating to the production of records, or otherwise as required by law.
3.1 Consent is required for the collection of personal information and the subsequent use or disclosure of this information. In certain circumstances, consent may be sought after the information has been collected but before use (for example, when existing information is to be used for a purpose not previously identified). Crossroads Credit Union may be required to collect, use, or disclose personal information without a Member's consent for certain purposes, including the collection of overdue accounts, legal or security reasons.
3.2 The principle requires "knowledge and consent". Crossroads Credit Union will make a reasonable effort to ensure that Members are aware of the purposes for which the information will be used. To make the consent meaningful, the purposes must be stated in such a manner that the Member can reasonably understand how the information will be used or disclosed.
3.3 Crossroads Credit Union will not, as a condition of the supply of a product or service, require a Member to consent to the collection, use, or disclosure of information beyond that required to fulfill explicitly specified and legitimate purposes.
3.4 In determining the form of consent to use, Crossroads Credit Union will take into account the sensitivity of the information. Although some information (for example, medical and financial records) is almost always considered to be sensitive, any information can be sensitive depending on the context.
3.5 In obtaining consent, the reasonable expectations of the Member are relevant. For example, a credit union, its clients or other Members dealing with Crossroads Credit Union should reasonably expect Crossroads Credit Union to periodically supply information on credit union developments, products and services, and to provide ongoing services. Similarly, further consent will not be required when personal information is transferred to agents of Crossroads Credit Union to carry out functions such as data processing. In this case, Crossroads Credit Union can assume that the Member's request constitutes consent for specifically related purposes. On the other hand, a Member would not reasonably expect that personal information given to Crossroads Credit Union would be given to a third party company selling insurance products, unless consent was obtained. Consent will not be obtained through deception.
3.6 The way in which Crossroads Credit Union seeks consent may vary, depending on the circumstances and the type of information collected. Crossroads Credit Union will seek express consent when the information is likely to be considered sensitive. Implied consent would generally be appropriate when the information is less sensitive.
3.7 Members can give consent:
- In writing, such as when completing and signing an application;
- Through inaction, such as failing to check a box indicating that they do not wish their names and addresses to be used for optional purposes;
- Orally, such as when information is collected over the telephone or in person;
- At the time they use a product or service; and
- Through an authorized representative (such as a legal guardian or a person having power of attorney).
3.8 A Member may withdraw consent at any time, subject to legal or contractual restrictions, provided that:
- Reasonable notice of withdrawal of consent is given to Crossroads Credit Union;
- Consent does not relate to a credit product requiring the collection and reporting of information after credit has been granted; and
- The withdrawal of consent is in writing and includes understanding by the Member that withdrawal of consent could mean that Crossroads Credit Union cannot provide the Member with a related product, service or information of value.
Crossroads Credit Union will inform the Member of the implications of such withdrawal.
Principle 4- Limiting Collection
The collection of personal information will be limited to that which is necessary for the purposes identified by Crossroads Credit Union. Information will be collected by fair and lawful means.
4.1 Crossroads Credit Union will not collect personal information indiscriminately. Crossroads Credit Union will specify both the amount and the type of information collected, limited to that which is necessary to fulfill the purposes identified, in accordance with Crossroads Credit Union's policies and procedures.
4.2 Crossroads Credit Union will collect personal information by fair and lawful means, and not by misleading or deceiving Members about the purpose for which information is being collected.
Principle 5 - Limiting Use, Disclosure, and Retention
Personal information will not be used or disclosed for purposes other than those for which it was collected, except with the consent of the Member or as required by law. Personal information will be retained only as long as necessary for the fulfillment of those purposes.
5.1 When Crossroads Credit Union uses personal information for a new purpose, the purpose will be documented.
5.2 Crossroads Credit Union will maintain guidelines and procedures with respect to the retention of personal information. These guidelines include minimum and maximum retention periods. Personal information that has been used to make a decision about a Member will be retained long enough to allow the Member access to the information after the decision has been made. Crossroads Credit Union may be subject to legislative requirements with respect to retention of records.
5.3 Subject to any requirement to retain records, personal information that is no longer required to fulfill the identified purposes will be destroyed, erased, or made anonymous. Crossroads Credit Union will develop guidelines and implement procedures to govern the destruction of personal information.
5.4 Crossroads Credit Union will protect the interests of Members by taking reasonable steps to ensure that:
- Orders or demands comply with the laws under which they were issued;
- Only the personal information that is legally required is disclosed and nothing more; and
- Casual requests for personal information are denied.
Crossroads Credit Union will make reasonable efforts to notify Members that an order has been received, if not contrary to the security of Crossroads Credit Union and if the law allows it. Notification may be by telephone, or by letter to a Member's usual address.
5.5 A Member's health records at Crossroads Credit Union may be used for employment purposes, credit applications and related insurance purposes. A Member's health records will not be collected from, or disclosed to, any other organization.
Principle 6 - Accuracy
Personal information will be as accurate, complete and up-to-date as is necessary for the purposes for which it is to be used.
6.1 The extent to which personal information will be accurate, complete, and up-to-date will depend upon the uses of the information, taking into account the interests of the Member. Crossroads Credit Union relies on Members to keep certain personal information, such as address information, accurate, complete and up-to-date. Information will be sufficiently accurate, complete, and up-to-date to minimize the possibility that inappropriate information may be used to make a decision about a Member.
6.2 Crossroads Credit Union will not routinely update personal information, unless such a process is necessary to fulfill the purposes for which the information was collected.
6.3 Personal information that is used on an on-going basis, including information that is disclosed to third parties, will generally be accurate and up-to-date unless limits to the requirement for accuracy are clearly set out.
Principle 7- Safeguards
Security safeguards appropriate to the sensitivity of the information will protect personal information. Crossroads Credit Union will apply the same standard of care as it applies to safeguard its own confidential information of a similar nature.
7.1 The security safeguards will protect personal information against loss or theft, as well as unauthorized access, use, copying, modification, disclosure or disposal. Crossroads Credit Union will protect personal information regardless of the format in which it is held.
7.2 The nature of the safeguards will vary depending on the sensitivity, amount, distribution and format of the information, and the method of storage. A higher level of protection will safeguard more sensitive information.
7.3 The methods of protection will include:
- Physical measures, for example, locked filing cabinets and restricted access to offices;
- Organizational measures, for example, controlling entry to data centres and limiting access to information to a "need-to-know" basis;
- Technological measures, for example, the use of passwords and encryption; and
- Investigative measures, in cases where Crossroads Credit Union has reasonable grounds to believe that personal information is being inappropriately collected, used or disclosed.
7.4 Crossroads Credit Union will periodically remind employees, officers and directors of the importance of maintaining the confidentiality of personal information. Employees, officers and directors are required to sign a declaration stating that they review Crossroads Credit Union's Code of Conduct annually, including a commitment to keep all personal information in strict confidence.
7.5 Care will be taken in the disposal or destruction of personal information, to prevent unauthorized parties from gaining access to the information.
7.6 Third parties will be required to safeguard personal information disclosed to them in a manner consistent with the policies of Crossroads Credit Union. Examples include cheque printing, data processing, credit collection, credit bureaus and card production.
Principle 8 - Openness
Crossroads Credit Union will make readily available specific, understandable information about its policies and procedures relating to the management of personal information.
8.1 Crossroads Credit Union will be open about privacy policies and procedures with respect to the management of personal information and will make them readily available in a form that is generally understandable.
8.2 The information made available will include:
- The name or title, and the address of the Privacy Officer who is accountable for compliance with Crossroads Credit Union's policies and procedures and to whom inquiries or complaints can be forwarded;
- The means of gaining access to personal information held by Crossroads Credit Union;
- A description of the type of personal information held by Crossroads Credit Union, including a general account of its uses;
- A copy of any brochures or other information that explains Crossroads Credit Union's policies, procedures, standards or codes; and
- The types of personal information made available to related organizations such as subsidiaries or other suppliers of services.
8.3 Crossroads Credit Union may make information on its policies and procedures available in a variety of ways. The method chosen depends on the nature of its business and other considerations. For example, Crossroads Credit Union may choose to make brochures available in its place of business, mail information to Members, provide on-line access, or establish a toll-free telephone number.
Principle 9- Individual Access
Upon request, a Member will be informed of the existence, use, and disclosure of their personal information, and will be given access to that information. A Member is entitled to challenge the accuracy and completeness of the information and have it amended as appropriate.
Note: In certain situations, Crossroads Credit Union may not be able to provide access to all the personal information it holds about a Member. Exceptions to the access requirement will be limited and specific. The reasons for denying access include, but are not limited to the following:
- Providing access would likely reveal personal information about a third party, unless such information can be severed from the record or the third party consents to the disclosure, or the information is needed due to a threat to life, health or security;
- The personal information has been requested by a government institution for the purposes of enforcing any law of Canada, a province or a foreign jurisdiction, carrying out any investigation related to the enforcement of any law, the administration of any law, the protection of national security, the defense of Canada or the conduct of international affairs;
- The information is protected by solicitor-client privilege;
- Providing access would reveal confidential commercial information, provided this information cannot be severed from the file containing other information requested by the Member;
- Providing access could reasonably be expected to threaten the life or security of another person, provided this information cannot be severed from the file containing other information requested by the Member;
- The information was collected without the knowledge or consent of the Member for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province;
- The information was generated in the course of a formal dispute resolution process.
9.1 Upon request, Crossroads Credit Union will inform a Member of the existence, use, disclosure, and source of personal information about the Member held by Crossroads Credit Union, and will allow the Member access to this information. However, Crossroads Credit Union may choose to make sensitive medical information available through a medical practitioner.
9.2 For Crossroads Credit Union to provide an account of the existence, use, and disclosure of personal information held by Crossroads Credit Union, a Member may be asked to provide sufficient information to aid in the search. The additional information provided will only be used for this purpose.
9.3 In providing an account of third parties to which it has, or may have, disclosed personal information about a Member, Crossroads Credit Union will be as specific as possible, including a list of third parties.
9.4 Crossroads Credit Union will respond to a Member's request within a reasonable time and at no cost, or reasonable cost, to the Member. The requested information will be provided or made available in a form that is generally understandable. For example, if Crossroads Credit Union uses abbreviations or codes to record information, an explanation will be provided.
9.5 When a Member successfully demonstrates the inaccuracy or incompleteness of personal information, Crossroads Credit Union will amend the information as required. Depending upon the nature of the information challenged, amendment involves the correction, deletion, or addition of information. Where appropriate, the amended information will be transmitted to third parties having access to the information in question.
9.6 When a challenge has not been resolved to the satisfaction of a Member, the substance of the unresolved challenge is to be recorded by Crossroads Credit Union. When appropriate, the existence of the unresolved challenge will be transmitted to third parties having access to the information in question.
Principle 10- Challenging Compliance
A Member will be able to question compliance with the above principles to Crossroads Credit Union's Privacy Officer. Crossroads Credit Union will have policies and procedures to respond to a Member's questions and concerns.
10.1 All staff are to know the identity of the Privacy Officer. Information on how to contact the Privacy Officer will be identified to other Members periodically.
10.2 Crossroads Credit Union will maintain procedures to receive and respond to inquiries or complaints about their policies and procedures relating to the handling of personal information. The complaint procedures will be easily accessible and simple to use.
10.3 Members who make inquiries or lodge complaints will be informed by Crossroads Credit Union of the existence of relevant complaint procedures. Crossroads Credit Union will also inform Members of their right to file a complaint with the Privacy Commissioner of Canada.
10.4 Crossroads Credit Union will investigate all complaints. If a complaint is deemed justified, Crossroads Credit Union will take appropriate measures, including revision of the personal information and, if necessary, amending Crossroads Credit Union's policies and procedures.
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