Ottawa Police Credit Union Limited is responsible
for personal information under its control and shall
designate a Privacy Officer who is accountable for
Ottawa Police Credit Union Limiteds compliance
with the principles of the Code.
Purposes The purposes for which personal information
is collected shall be identified by Ottawa Police
Credit Union Limited at or before the time the information
The knowledge and consent of the member are
required for the collection, use and disclosure of
personal information, except in specific circumstances
as described within this Code.
Collection The collection of personal information
shall be limited to that which is necessary for the
purposes identified by Ottawa Police Credit Union
Limited. Information shall be collected by fair and
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 member or as required by law. Personal
information shall be retained only as long as necessary
for the fulfilment of those purposes.
Personal information shall be as accurate,
complete, and up-to-date as is necessary for the purposes
for which it is to be used.
Personal information shall be protected by
security safeguards appropriate to the sensitivity
of the information. Ottawa Police Credit Union Limited
will apply the same standard of care as it applies
to safeguard its own confidential information of a
Ottawa Police Credit Union Limited shall make
readily available to members specific, understandable
information about its policies and practices relating
to the management of personal information.
Access Upon request, a member shall be informed
of the existence, use, and disclosure of their personal
information, and shall be given access to that information.
A member is entitled to question the accuracy and
completeness of the information and have it amended
as appropriate on proof of inaccuracy.
Compliance A member shall be able to question
compliance with the above principles to the Privacy
Officer accountable for Ottawa Police Credit Union
Limiteds compliance. Ottawa Police Credit Union
Limited shall have policies and procedures to respond
to the members questions and concerns.
Ottawa Police Credit Union Limited Board of Directors
is accountable for credit union compliance with the
Code, the creation and review of all Board policies
specific to the Code and the designation of a credit
union Privacy Officer.
The Board of Directors, in consultation with the General
Manager, will designate a Privacy Officer, who has primary
day-to-day responsibility for compliance with the Code.
The Board of Directors will notify all employees, and
any affected third parties, in writing of the appointment.
Reporting and Notification
The Privacy Officer will continually review compliance
within Ottawa Police Credit Union Limited and its third
party suppliers, and will report to the Board of Directors
any matters concerning non-compliance with Ottawa Police
Credit Union Limiteds Code principles, policies
or procedures that are likely to require input from
the Board (e.g., any matter that could result in an
investigation or audit by the Office of the Privacy
Privacy Officer will prepare a Quarterly Report for
the Board that identifies key activities (e.g., a review
of third party contracts, training initiatives, review
of policies and procedures) and recommended changes
for Board consideration. The report should also include
an overview of the number of enquiries, number of access
requests, and details regarding challenges to compliance.
Board will review the steps taken to address any deficiencies
or weakness in compliance.
The Privacy Officer will prepare an annual review of
the effectiveness of the board policies to ensure compliance
with the Code and to recommend any revisions as deemed
appropriate. This report is due within four months of
the end of each calendar year.
Approval and Documentation of Purposes
The Privacy Officer will document all purposes, including
existing and new purposes, for which personal information
is collected, used or disclosed. All new purposes must
be approved by the Privacy Officer prior to collection
of information for the new purpose.
the proposed purpose is significantly different than
existing purposes or involves a new disclosure to a
third party, the proposed purpose must be approved by
the Board of Directors prior to implementation.
Ottawa Police Credit Union Limited will make reasonable
efforts to ensure that members are aware of the purpose
for which their personal information is collected, including
any disclosure of their personal information to third
parties. The primary communication method will be the
use of written or electronic statements on applications,
forms, contracts and agreements.
Ottawa Police Credit Union Limited will ensure that
all employees are aware of the purposes for which employee
information is collected, including any disclosure of
their personal information to third parties. This will
be communicated verbally and in writing at the commencement
Once member consent is obtained, further member consent
will not be required when personal information is supplied
to agents of Ottawa Police Credit Union Limited who
carry out functions such as data processing, credit
bureaus, cheque printing and cheque processing.
Police Credit Union Limited Privacy Officer must authorize
all instances where a members information is collected,
used or disclosed without the members knowledge
Express consent in writing, through the use of applications,
signed forms and contracts, will be used for obtaining
consent for the collection, use or disclosure of personal
consent will be used for marketing purposes or to disclose
nominative information to an affiliated organization.
Implied consent must never contravene the Act.
Privacy Officer must review and approve all methods
of obtaining consent.
on Consent to Information Collection
Ottawa Police Credit Union Limited 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.
additional, non-essential information for a product
or service is sought from members, this will be identified
as optional information, and collected only at the discretion
of the member.
to provide this optional information will not influence
the members consideration for a product or service.
Privacy Officer will review the personal information
requirements of all products or services to ensure that
only information required for the legitimate purpose
is collected and used.
Ottawa Police Credit Union Limited will obtain a written
request (signed and dated) from a member who seeks to
withdraw consent. The written request must acknowledge
that the member has been advised that Ottawa Police
Credit Union Limited may subsequently not be able to
provide the member with a related product, service or
information that could be of value to the member.
withdrawal of consent is subject to any legal or contractual
restrictions that Ottawa Police Credit Union Limited
may have with the member or other organizations such
as: the Income Tax Act; credit reporting; or to fulfill
other fiduciary and legal responsibilities.