Identifying the Purposes of Collecting Personal Information
Principle #2: Identifying the Purposes of Collecting Personal Information
Scotiabank will identify the purposes for which it collects the personal information, before or when the information is collected
2.1 Except as noted below, when a customer applies for a product or service, Scotiabank will make sure the customer is made aware of:
- Why Scotiabank needs the personal information it is requesting;
- How the personal information may be used with customer consent for other purposes; and
- The fact that the customer can refuse at any time permission for Scotiabank to use personal information for these other purposes.
In some cases Scotiabank may not explain or obtain customer consent for the other purposes for which the information has been collected. See 3.4, 3.4.1, and 5.1 for details.
2.2 Scotiabank will collect and use personal information for the following purposes:
- To understand the customer's needs;
- To analyze the suitability of our products or services for the customer;
- To determine the customer's eligibility for our products and services;
- To set up, manage and offer products and services that meet the customer's needs;
- To provide ongoing service;
- To meet legal and regulatory requirements; and/or
- With regards to insurance products to investigate and adjudicate insurance claims.
2.3 Scotiabank will identify the purposes for which it intends to use the personal information, in writing, orally in person or over the telephone, electronically or by any other alternative format or means it uses to communicate with its customers. Scotiabank will use words that customers can easily understand when identifying these purposes.
Scotiabank will distinguish the purposes from other information so that customers will be made aware of them. For instance, on an application form, Scotiabank may identify the purposes using bolder type or a box, or a separate form or letter. Over the telephone, Scotiabank will identify the purposes as a distinct part of the application.
2.4 Scotiabank staff who collect personal information will be able to explain the purposes to customers. Customers will also be able to ask for information about the purposes when they phone or write to Scotiabank or visit a branch or office having possession or custody of the personal information.
2.5 Scotiabank will explain all the purposes for which personal information is collected by that member including any purposes which may not appear to be as obvious as others. The purposes for collecting a name or address are obvious and do not need to be explained, but the purposes for collecting other information may not be obvious. For example as appropriate in the circumstances, Scotiabank will tell customers that:
- References are used to verify information on an application;
- A government identification number is used where legislation requires it for the customer's income tax reporting;
- Credit information is reported to credit bureaus, credit reporting agencies, credit insurers, and other lenders, to maintain the integrity of the credit-granting process;
- Further medical information may be required in conjunction with the customer's application for insurance for the purpose of approving (or declining) the request;
- Medical information is reported to the Medical Information Bureau to maintain the integrity of the underwriting record;
- Claims and insurance history is shared with the Insurance Services Bureau to maintain data integrity in the insurance industry;
- Personal information is required for the creation of a digital certificate, Digital certificates are required with on-line services to authenticate the customer to the web site and their account information;
- Personal information, including without limitation, the customer's age, investment horizon, investment objectives, risk tolerance, investment knowledge, investment income requirements, net worth, income, employment is used to determine the appropriateness of particular investments for an individual pursuant to securities legislation;
- Information regarding the employment of the customer and his or her spouse is required to comply with 'insider' trading rules under securities legislation; and/or
- Information regarding accounts held at other investment dealers is required to comply with the requirements of self-regulatory organizations.