Personal Information Privacy Code

Windsor Family Credit Union has adapted the Credit Union Code for the Protection of Personal Information.

This Code incorporates the principles as outlined in Canada’s federal Personal Information Privacy and Electronic Documents Act.

1. Accountability

Windsor Family is responsible for personal information under its control and has designated the Executive Vice President, Operations as the credit union’s Privacy Officer to ensure compliance with this policy and such related legislation.

Each Windsor Family board and employee has signed a Code of Conduct which denotes their duties and responsibilities to keep all information concerning each member and each members’ accounts, transactions and personal information private and confidential within the bounds of the Credit Union’s operations.

2. Identifying Purposes

Windsor Family will collect and use personal information for the following purposes, at or before the time the information is collected:

• To confirm the identity of the member.

• To determine the suitability of the products and services for the member or the eligibility of the member for products and services.

• To develop, offer and manage products and services that meet the member’s needs.

• To provide ongoing service.

• To detect and prevent fraud and to help safeguard the financial interests of the Credit Union and its members.

• To meet legal and regulatory requirements.

• To meet personnel requirements.

3. Knowledge and Consent

Windsor Family obtains the knowledge and consent of members to collect, use or disclose personal information at the time the member joins the credit union through the acknowledgement and acceptance of the Member Account or Service Agreements and with the publication, distribution and acceptance of versions of the Member Account or Service Agreements as may be issued from time to time.

4. Limiting Collection

Windsor Family will only collect that personal information from members which is necessary for the purpose of being identified by the credit union using fair and lawful means.

5. Limiting 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 fulfillment of those purposes.

If member personal information is disclosed or exchanged with another party, such as a financial product or service provider, the Credit Union will ensure that such party accepts and will comply with the provisions of this Code.

Windsor Family shall maintain member personal information as long as necessary to meet the identified purpose and to comply with legislated and regulatory requirements with respect to record retention.

6. Accuracy

Personal information shall be as accurate, complete and up-to-date as is necessary for the purposes for which it is to be used.

Windsor Family relies on the member to keep certain personal information such as address information, accurate, complete and up-to-date. Information shall be sufficiently accurate to minimize the possibility that inappropriate information may be used to make a decision about the member.

7. Safeguards

Windsor Family will safeguard member personal information by security and safeguards appropriate to the sensitivity of the information.

The Credit Union applies the same standard of care as it applies to safeguard its own confidential information.

The Credit Union will protect personal information against loss or theft as well as unauthorized access, use, copying, modification, disclosure or disposal. The Credit Union will use care in the disposal or destruction of personal information to prevent unauthorized parties from gaining access to the information.

Third Parties are required to safeguard personal information disclosed to them in a manner consistent with the policy, guidelines and practises of the Credit Union.

8. Openness

Windsor Family shall make readily available to members specific information about its policies, guidelines and practises relating to the management of personal information.

9. Individual Access

Upon written request to the Privacy Officer, 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.

10. Compliance

A member may contact the Privacy Officer with questions or comments on the Credit Union's compliance with this Code by calling 1-519-974-3100 and asking for the Executive Vice President, Operations, or by sending an email to info@windsorfamily.com or by writing to the attention of the Executive Vice President Operations, Windsor Family Credit Union, 3000 Marentette Avenue, Windsor, Ontario, N8X 4G2..

The Privacy Officer is responsible for monitoring applicable legislation and ensuring that the Credit Union and this Code, guidelines and procedures remain in compliance.