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| What our customers should know about Manulife Bank’s privacy practices
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The information we collect
Personal information is information that refers to you, specifically. For any Manulife Bank product or service you obtain, we will tell you the purposes for which we need the personal information we collect.
We will use fair and lawful means to collect your personal information. We will only collect information that is pertinent and consistent with the purposes of the collection. Whenever practical, we will collect the required information directly from you, or from your authorized representative(s), in completed applications and forms, through other means of correspondence, such as the telephone, mail or the Internet and through your business dealings with us.
In some cases, and with your consent, we may need to ask an independent source to verify or provide supplemental information. These sources could include service providers we retain, other banks or financial institutions, your employer or credit reporting agencies.
If your information is being collected by telephone, the call may be recorded or monitored for the following reasons:
- To establish a record of the information you provide;
- To take or verify instructions from you;
- To maintain quality service levels;
- To assist in staff training.
If you are not comfortable with having your telephone calls recorded, you have the option of communicating with us in writing, instead. Where you have chosen to only communicate with us in writing, your written communications should request that any response to you be in writing as well.
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What we need to know and why
We collect information from you and about you, only with your consent or as required or permitted by law. In general, we will collect personal information such as your name, address, telephone number(s) or other identifying information, such as your Social Insurance Number (SIN) or date of birth.
The type of additional information we gather will depend on the type of product or service involved. For example, it would depend on whether the product or service is a request for a loan or a bank account. The information gathered may be financial, which would include such information as occupation and place of employment, annual income, assets and liabilities. It may also include information such as your date of birth or reference numbers of identification documents, such as your passport or other documents.
Generally, we collect, use and disclose your personal information to:
- Confirm your identity and to protect both you and us against errors, fraud or other misrepresentations;
- Evaluate your financial needs and determine the suitability of our banking products and services for you;
- Determine your eligibility for banking products and services;
- Properly administer the products and services we provide to you;
- Support and maintain the accuracy and integrity of the credit reporting system, which includes your past credit and repayment history as well as other financial transactions;
- Comply with a variety of legal requirements, including any tax reporting obligations under the federal Income Tax Act, or the Quebec Act respecting the Ministère du Revenu;
- Assist us to understand the current and future needs of our customers, for example, to conduct customer surveys and other forms of market research and analysis;
- Provide you with information on other products and services as described in the "Special offers and marketing promotions … it’s your choice" section.
We will only keep your personal information in our records for as long as it is needed to fulfill the identified purposes or as required or permitted by law.
Personal information that is no longer required will be destroyed, erased or made anonymous.
When we destroy personal information, we will use safeguards to prevent unauthorized access to the information during the destruction process.
Your Social Insurance Number
There are a number of reasons why we may ask for your Social Insurance Number (SIN).
Where there may be interest income or other income to be reported, your SIN is required by law, in order to meet tax-reporting requirements under the federal Income Tax Act or the Quebec Act respecting the Ministere du Revenu.
With your consent, we may also use your SIN as a unique identifier to keep your personal information separate from that of other customers, or individuals with similar names, and to help maintain the integrity and accuracy of your personal information. For example, where it is appropriate to verify your credit history, we may use your SIN to ensure that the credit information we are asking for – and receiving – is about you, rather than someone else with the same or similar name.
You may elect not to have your SIN used for purposes other than as required by law. However, as explained earlier, this may affect our ability to fully ensure the accuracy and integrity of your personal information.
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Your consent
We collect, use and share your personal information only for disclosed purposes related to the products and services we offer and only with your consent or as permitted or required by law. Your consent may be expressed in writing or it may be given verbally, electronically, or through our, or your, authorized representative(s), such as your financial services advisor.
Your consent may also be implied or inferred from certain actions. For example, if you present your driver’s licence as identification to your advisor, it is understood that you are giving your consent to your advisor to provide us with your driver’s licence reference number to be kept in our files.
In order to continue to grow our business and provide you with new innovative products and services, we may, from time to time, inform you of new uses or disclosures of your personal information. Depending on the nature or sensitivity of your personal information to be used or disclosed, your consent may be implied or in some cases, we may seek your express consent. For your implied consent, we will provide you an opportunity to ask questions or to “opt out” of the new uses or disclosures. If we do not receive any objections from you, it is understood that you agree to the new use or disclosure.
You may withhold or withdraw your consent for us to collect, use and disclose your personal information, as long as there are no legal or contractual reasons preventing you from doing so. Depending on the circumstances, however, withdrawal of your consent may impact our ability to continue to provide you with the products and services you have requested, such as your bank account or loan. For example, if you withdrew your consent for us to evaluate your credit history in relation to your existing loan, depending on the situation, we may not be able to properly monitor our credit risk and demand that you repay your loan in full.
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Who has access to your information
Generally, the disclosure of your personal information will be restricted to those who have a need for, and the right to, the information. Your personal information will only be provided to, or be accessible by:
- Our employees, agents and representatives, who need the information in the performance of their duties for us;
- Our affiliates, to:
- resolve your concerns about any related products and services with us,
- assist in other required investigations;
- Service providers who need the information in the performance of their duties for us, and to satisfy their obligations to us;
- Credit grantors with whom you have dealings or credit bureaus and personal information agents with respect to your credit or financial history;
- Any person or organization to whom you gave consent; and,
- Anyone who is otherwise authorized by law, for example regulators, law and enforcement agencies and other government agencies.
In some cases, your personal information may be provided to these people, organizations and service providers in other provinces or jurisdictions outside Canada and would, therefore, be subject to the laws of those provinces or jurisdictions.
Service Providers
We may use service providers to provide us with various services such as debit and credit card services, printing , mail distribution, information technology, data storage, insurance services, administration and marketing (which would include market research and promotional services). Where personal information is provided to our service providers, we will require them to protect the information in a manner that is consistent with our privacy policies and practices.
Affiliates
At Manulife Bank, we offer various loan products that enable you to purchase investment products offered by our affiliates. If you have a question or concern about these related products, we may need to confer with our affiliates, to ensure that we address your questions or concerns properly and in a timely manner.
Our affiliates may also have access to your personal information, when providing us with certain services, such as information technology services or other services, as described in the Service Providers section, above.
Since all Manulife Financial companies abide by common privacy principles and practices, our customers have the assurance that the same commitment to privacy is maintained in their dealings with any of Manulife Financial's group of companies.
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Accessing and amending your information
We will make all reasonable efforts to ensure that any personal information we collect and keep is as accurate, complete and as up-to-date as required for the identified purposes. To do so, we will rely to a large extent on you to provide us with accurate information and to inform us of changes, such as changes in your contact information. You have the right to access and verify your personal information maintained in our files and to request that any factually inaccurate personal information be corrected, if appropriate. Depending on the circumstances, we may not always be able to give you access to all information or there may be a minimal charge for personal information that you request. Should this happen, we will let you know.
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We are committed to protecting your information
We are committed to protecting your personal information from unauthorized access or use by ensuring that the necessary physical, organizational and technological safeguards are in place that are appropriate to the sensitivity of the information. Essentially, this means that personal information is protected:
- Physically, by building security measures and physical barriers;
- Organizationally, by our policies, procedures and access levels; and,
- Technologically by, for example, where appropriate, the use of passwords, encryption, firewalls, anti-virus and anonymizing software.
All of our employees, representatives, agents and service providers, who act on our behalf, are required to abide by our privacy policies and practices.
If we receive a request to release your personal information, we will only do so upon satisfactory identification and proof of entitlement of the requestor or as required or permitted by law.
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Special offers and marketing promotions … it’s your choice
From time to time, we may offer or promote other financial products and services, or those of our affiliates and select third parties, that we believe may be of interest to you.
We will share personal information with our affiliates for these purposes, only if the law permits it.
Please note that we do NOT give your personal information, without your consent, to any organization outside of our member companies, for the purpose of that organization marketing their own products or services directly to you.
If you do not wish to receive our marketing offers or special promotions, you may choose to “opt out” by simply contacting us, and we will remove your name from our mailing lists. This means you will not be eligible to receive addressed, direct mail offerings. This opt-out will not extend to:
- Information included in or with monthly statements which relate to any Manulife Bank product or service that you currently have with, or receive from, us; or
- General product and service information and updates included in, or with, client statements.
To remove your name from any special mailing list that we maintain, please contact us by telephone or mail. Please note: when you contact us to remove your name and address from our marketing mailing lists, we will use all reasonable efforts to do so in a timely fashion. If you are applying for a new product or service, we will process your request immediately. Otherwise, if you have an existing product or service with us, we will generally require a reasonable period of time, which may vary depending upon the product or service, to process your request.
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Who we are
In this Statement of Privacy Principles and Practices, we, us and our mean Manulife Bank of Canada. Affiliate(s) means The Manufacturers Life Insurance Company (“Manulife Financial”) – Canadian Division Operations, Manulife Canada Ltd., MFC Insurance Company Limited, Manulife Securities International Ltd., Elliott & Page Limited and First North American Insurance Company. You and your mean individuals whose personal information we are collecting, using and disclosing.
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Contact us
If you have any questions or concerns about our privacy policies and practices, or if you want to know more about the process for accessing and/or correcting your personal information or opting-out of marketing offers, please contact us:
Mail:
Privacy Officer
Manulife Bank of Canada
500 King Street North
P.O. Box 1602
Del Stn 500-MA
Waterloo, Ontario N2J 4C6
Telephone:
1-877-765-2265
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