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Our Commitment to Privacy
Shinhan Bank Canada is committed to protecting your privacy and maintaining the confidentiality of your personal information. The following Privacy Principles outlines our practices related to the collection, use and disclosure of personal information and is based on the privacy principles set out in the Personal Information Protection and Electronic Documents Act (“PIPEDA”).
What is “Personal Information”?
Personal information is information about an identifiable individual, but does not include the title, business address or telephone number of an employee of an organization. The personal information that we collect in the course of doing business may include your name, mailing address, date of birth, Social Insurance Number, financial information and credit records. We consider the sensitivity of personal information in deciding how it should be collected, used, disclosed and safeguarded.
Why We Collect, Use and Disclose Personal Information
We collect, use and disclose your personal information to provide certain financial and related services to you.
These include:
- opening and maintaining your account(s) with us;
- providing you with financial products and services you have requested;
- determining suitability of products and services for you;
- establishing your identity;
- providing related administrative services;
- communicating with you to provide you with information about other products and services that may be of interest to you;
- managing your relationship with us;
- understanding our customers and developing and tailoring our products and services; and
- complying with legal and regulatory requirements
How and What Personal Information We Collect
Most personal information is collected directly from you. With your consent, we may obtain personal information from other sources such as credit bureaus. We may also verify personal information through other sources in which you have provided to us. For example, we may verify information you provided regarding your employment with your employer or credit related information with a credit bureau. In certain circumstances, we may collect personal information that you had previously provided to one of our affiliates in order to facilitate the provision of products and services to you by us, including determining your creditworthiness.
All personal information is collected by fair and lawful means. Your receipt of different products and services may require the collection of different kinds of personal Information. We will not collect more personal information than we determine we need for the purposes set out above.
If you apply for a credit product, we use your financial information to assess your eligibility. Financial information may include your tax returns, net worth statements, employment income and credit information.
If you would like to open an interest-bearing or investment account with us, the Income Tax Act requires that we ask for your Social Insurance Number.
When we verify or update your personal information with a credit bureau, your Social Insurance Number is the most effective way of ensuring that we access the correct credit report. However, the provision of your Social Insurance Number for this purpose is purely voluntary. Should you choose to not provide us with this piece of personal information, we will still be able to perform credit verifications and updates with a credit bureau using other personal information for identification purpose.
Obtaining Your Consent
Your knowledge and consent are required before we may collect, use or disclose your personal information, except in particular circumstances as required or permitted by law. When you apply for one of our financial products or services, we ask for your consent to the collection, use and disclosure of your personal information. We will not use or disclose your personal information beyond the scope of the purposes for which we have obtained your consent without first obtaining your consent to such new use or disclosure.
Subject to legal and contractual requirements, you may withdraw your consent to the collection, use or disclosure of personal information at any time. We will respond to any such request in a timely manner. If accommodating your request would limit or prevent us from providing you with a product or service you have requested, we will explain the implications of your request to you at the time you refuse or withdraw your consent.
We may from time to time contact you to provide you with information about additional products and services which we feel might be of interest to you. Should you not wish to receive such communications from us, you may contact us at the information listed under “How to contact Us and OPC” of this brochure in order to refuse or withdraw your consent to the use of your personal information.
Limiting Use and Disclosure of Your Personal Information
We will not use or disclose your personal information for purposes other than those described in this Code or of which we informed you at the time of its collection, unless we obtain your prior consent to such use or disclosure or unless such use or disclosure is required or permitted by law.
As indicated above, we may disclose the personal information you have provided to us for verification purposes, including, depending on the circumstances, to your employer, to a credit bureau, or to any of our affiliated institutions, including those located in other jurisdictions.
Shinhan Bank Canada may retain carefully selected third parties to perform functions or to provide services in support of the products and services it provides. When transferring personal information to a third party service provider, we transfer only the personal information which is required in order to perform the function or service for which the third party has retained. All third parties to whom we transfer personal information to are required to protect the information in any circumstances, as set by this Code.
In some situations, we may share your Personal Information with Shinhan Bank Financial Group world-wide subsidiaries and affiliates to manage your relationship with Shinhan Bank Financial Group, to prevent credit and other business risk, and to meet legal and regulatory requirements. If you prefer we do not share information within the Shinhan Bank Financial Group or you would like to withdraw consent, this can be done at any time by either orally expressing your preference at the time of signing an application for customer information, or by visiting your nearest branch to receive information on how you can withdraw consent.
To the extent that any of our Financial Group subsidiaries and affiliates, or any of the third party service providers we retain are located outside of Canada, personal information transferred to them will be subject to the laws of the foreign jurisdiction where they are located, including those laws governing disclosure of personal information.
In the event of a sale of some or all of our business, your personal information may be disclosed to an acquiring organization, either as part of due diligence and/or on completion of the transaction. If your personal information is disclosed to a third party in this context, we will require that the third party agree to treat your personal information with caution.
In certain circumstances, we may disclose your personal information without your knowledge or consents, as required or permitted by law. This may occur if we are compelled to disclose personal information to a regulatory or law enforcement authority or to a court of law. We are also permitted to disclose certain personal information in order to collect on an overdue account, or required to detect or prevent fraud.
Safeguards
We use electronic, procedural and physical safeguards to protect against unauthorized access, use, disclosure, modification, destruction, loss or theft of your Personal Information in our custody or control.
Shinhan Bank Canada’s Online Banking transmits data using SSL (Secure Socket Layer) technology that supports 128-bit key encryption.
Retaining Your Personal Information
We will retain your personal information only for the time it is required for the purposes for which it was collected and for a reasonable length of time thereafter in case we need to meet any potential obligations or legal or regulatory requirements. We have adopted a retention policy that reflects our obligations under privacy legislation and sets minimum and maximum retention periods for personal information. Once your information is no longer required, it is securely destroyed or made anonymous as appropriate.
Maintaining Accuracy of Your Personal Information
Your personal information shall be accurate, complete and up-to-date to minimize the possibility that inappropriate information may be used to make a decision about you. Therefore, we expect you to provide up-to-date information by voluntarily updating your information via our Online Banking services.
When you request for changes of personal information, we shall amend the information in the following manner:
- Before making any changes, we shall verify your identity. If you visit the branch, we may request your signature for the personal information change.
- In case of personal information change request by email, mail or phone, the information you have provided will be compared and verified with our records.
Openness and Accountability
An updated version of this Privacy Code is available on our website at shinhan.ca. Upon request, a paper version of the policy can be obtained by contacting Shinhan Bank Canada’s Privacy Officer by phone, email or regular mail.
We are accountable for the treatment of all personal information under our control. We have designated a Privacy Officer to be responsible for overseeing privacy compliance within Shinhan Bank Canada.
Accessing Your Personal Information
Upon receipt of a written request, we will provide you with reasonable access to your personal information in our possession. We will also update and/or correct your personal information as required. If you have a sensory disability, we will provide access to your personal information in a requested alternative format as required by law.
In some cases, we may not be able to provide you with access to your personal information, including the following circumstances:
- if doing so would reasonably be expected to threaten the life or security of another individual;
- if disclosure would reveal confidential information;
- if the personal information is protected by solicitor-client privilege; or
- if the information was collected during the investigation of a legal matter or for purposes related to the detection and prevention of fraud.
If we are unable to provide you with access to your personal information, we will advise you in writing of the reason(s) for the refusal, unless we are prohibited from doing so by law.
How to Contact Us and OPC
If you have any questions or concerns regarding the Privacy Policy or any of our privacy practices, please direct all privacy-related inquiries to our Privacy Officer.
5140 Yonge Street, Suite 2300
Telephone: (416) 250-3500
Email: privacy.ca@shinhan.com
All questions or complaint will receive a timely response. If your concern of complaint is justified, we will take steps to resolve it, including, if necessary, amending our Privacy Policy and related guidelines.
Office of the Privacy Commissioner of Canada (OPC)
If you are not satisfied to our response and wish to speak about issues concerned with our compliance regarding our Privacy Policy or of any of our policies and practices related to the handling of personal information, you may contact the Office of the Privacy Commissioner at:
30 Victoria Street
Gatineau, Quebec K1A 1H3
Telephone: 1-800-282-1376
Additional information can be obtained on the website of the Office of the Privacy Commissioner at www.priv.gc.ca.