PRIVACY POLICY
ZFinancial
is dedicated to providing personalized and professional customer
Service to individual clients and businesses. We look forward to hearing
from you.
Rest
assured knowing that your personal financial information is kept
confidential at all times.
Personal Information Protection
At Zfinancial we are committed to providing our clients with
exceptional service. As providing this service involves the
collection, use and disclosure of some personal information about
our clients, protecting their personal information is one of our
highest priorities.
While we have always respected our
clients, privacy and safeguarded their personal information, we have
strengthened our commitment to protecting personal information as a
result of Ontario’s Freedom of Information and Protection of Privacy
Act (FIPPA). FIPPA, which came into effect on January 1, 1988, sets
out the ground rules for how Ontario businesses and not-for-profit
organizations may collect, use and disclose personal information.
We will inform our clients, of why and how we collect, use and
disclose their personal information, obtain their consent where
required, and only handle their personal information in a manner
that a reasonable person would consider appropriate in the
circumstances.
This Personal Information Protection Policy,
in compliance with FIPPA, outlines the principles and practices we
will follow in protecting clients’ personal information. Our privacy
commitment includes ensuring the accuracy, confidentiality, and
security of our clients’, personal information and allowing our
clients, to request access to, and correction of, their personal
information.
Scope of this
Policy
This Personal Information Protection Policy applies
to Z financial and its subsidiaries. This policy also applies to any
service providers collecting, using or disclosing personal
information on behalf of Z financial.
Definitions
Personal Information
–means information about an identifiable individual E.g., including
name, age, home address and phone number, social insurance number,
marital status, religion, income, credit history, medical
information, education, employment information]. Personal
information does not include contact information (described below).
Contact information – means
information that would enable an individual to be contacted at a
place of business and includes name, position name or title,
business telephone number, business address, business email or
business fax number. Contact information is not covered by this
policy or FIPPA.
Privacy Officer – means the individual
designated responsibility for ensuring that Z financial complies
with this policy and FIPPA.
Policy 1 – Collecting
Personal Information
1.1 Unless the purposes for collecting
personal information are obvious and the client, voluntarily
provides his or her personal information for those purposes, we will
communicate the purposes for which personal information is being
collected, either orally or in writing, before or at the time of
collection.
1.2 We will only collect client, information that is
necessary to fulfill the following purposes:
· To verify
identity;
· To verify creditworthiness;
· To identify client,
preferences;
· To understand the [financial, banking, insurance]
needs of our
clients;
· To ensure a high
standard of service to our clients;
Policy 2 – Consent
2.1 We will
obtain client, consent to collect, use or disclose personal
information (except where, as noted below, we are authorized to do
so without consent).
2.2 Consent can be provided in writing, or
it can be implied where the purpose for collecting using or
disclosing the personal information would be considered obvious and
the client, voluntarily provides personal information for that
purpose.
2.3 Consent may also be implied where a client, is
given notice and a reasonable opportunity to opt-out of his or her
personal information being used for mail-outs, and the client does
not opt-out.
2.4 Subject to certain exceptions (e.g., the
personal information is necessary to provide the service or product,
or the withdrawal of consent would frustrate the performance of a
legal obligation), clients, can withhold or withdraw their consent
for Z financial to use their personal information in certain ways. A
client’s, decision to withhold or withdraw their consent to certain
uses of personal information may restrict our ability to provide a
particular service or product. If so, we will explain the situation
to assist the client in making the decision.
2.5 We may collect,
use or disclose personal information without the client’s, knowledge
or consent in the following limited circumstances:
· When
the collection, use or disclosure of personal information is
permitted or required by law;
· In an emergency that threatens an
individual's life, health, or
personal security;
· When the personal information is available from a public source
(e.g., a telephone directory);
· When we require
legal advice from a lawyer;
· For the purposes of collecting a
debt;
· To protect ourselves from fraud;
· To investigate an
anticipated breach of an agreement or a
contravention of law
Policy 3 – Using and Disclosing
Personal Information
3.1 We will only use or disclose client,
personal information where necessary to fulfill the purposes
identified at the time of collection.
3.2 We will not use or
disclose client, personal information for any additional purpose
unless we obtain consent to do so.
3.3 We will not sell client,
lists or personal information to other parties [unless we have
consent to do so].
Policy 4
– Retaining Personal Information
4.1 If we use client,
personal information to make a decision that directly affects the
client, we will retain that personal information for at least one
year so that the client,has a reasonable opportunity to request
access to it.
4.2 Subject to policy 4.1, we will retain client,
personal information only as long as necessary to fulfill the
identified purposes or a legal or business purpose.
Policy 5 – Ensuring Accuracy of Personal Information
5.1 We
will make reasonable efforts to ensure that client, personal
information is accurate and complete where it may be used to make a
decision about the client, or disclosed to another organization.
5.2 Clients, may request correction to their personal information in
order to ensure its accuracy and completeness. A request to correct
personal information must be made in writing and provide sufficient
detail to identify the personal information and the correction being
sought.
[IF APPLICABLE: A request to correct personal
information should be forwarded to the Privacy Officer [or
designated individual].
5.3 If the personal information is
demonstrated to be inaccurate or incomplete, we will correct the
information as required and send the corrected information to any
organization to which we disclosed the personal information in the
previous year. If the correction is not made, we will note the
clients’, correction request in the file.
Policy 6 –
Securing Personal Information
6.1 We are committed to
ensuring the security of client, personal information in order to
protect it from unauthorized access, collection, use, disclosure,
copying, modification or disposal or similar risks.
6.2 The
following security measures will be followed to ensure that client,
personal information is appropriately protected:
The use of
locked filing cabinets; physically securing offices where personal
information is held; the use of user IDs, passwords, encryption,
firewalls; restricting employee access to personal information as
appropriate (i.e., only those that need to know will have access;
contractually requiring any service providers to provide comparable
security measures].
6.3 We will use appropriate security measures
when destroying client’s,personal information such as shredding
documents, deleting electronically stored information.
6.4 We
will continually review and update our security policies and
controls as technology changes to ensure ongoing personal
information security.
Policy 7 – Providing Clients,
Access to Personal Information
7.1 Clients, have a right to
access their personal information, subject to limited exceptions.
7.2 A request to access personal information must be made in
writing and provide sufficient detail to identify the personal
information being sought.
7.3 Upon request, we will also tell
clients, how we use their personal information and to whom it has
been disclosed if applicable.
7.4 We will make the requested
information available within 30 business days, or provide written
notice of an extension where additional time is required to fulfill
the request.
7.5 A minimal fee may be charged for providing
access to personal information. Where a fee may apply, we will
inform the client, of the cost and request further direction from
the client, on whether or not we should proceed with the request.
7.6 If a request is refused in full or in part, we will notify
the client, in writing, providing the reasons for refusal and the
recourse available to the client.
Policy 8 – Questions
and Complaints: The Role of the Privacy Officer or designated
individual
8.1 The Privacy Officer is responsible for
ensuring Z financial compliance with this policy and the Personal
Information Protection Act.
8.2 Clients, should direct any
complaints, concerns or questions regarding Z financial compliance
in writing to the Privacy Officer.
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