Your privacy: respected and assured.
At Libro, we take your privacy seriously. We adhere to strict regulations for maintaining the privacy and confidentiality of your personal information, and we’re accountable, by law and to Libro Owners, for respecting and safeguarding private data. If you have privacy concerns, please discuss them with your Libro Coach or Branch Manager.
Libro’s Privacy Officer may be contacted with questions, suggestions or opinions regarding Libro’s compliance with our policy and relevant legislation.By mail:217 York St., 4th Floor,
London ON, N6A 5P9
Attn: Privacy Officer
By phone at 1-800-265-5935
- Libro recognizes the importance of privacy protection for our Owners personal information.
- Libro understands the need for transparency with Owners regarding their privacy and personal information.
- Upholds the principles outlined by the Personal Information Protection and Electronic Documents Act (PIPEDA) for an individual's right to privacy with the need of organizations to collect, use or disclose personal information for legitimate business purposes.
- Ensure transparent and accountable practices are in place with staff members regarding privacy and protecting Owner information.
- Meet and exceed regulatory privacy requirements.
- Owners entrust Libro with their personal information.
- Privacy issues handled quickly and effectively.
FORMAL POLICY STATEMENTS
DUTIES AND RESPONSIBILITIES
Libro upholds the following principles associated with PIPEDA that are based on the e Canadian Standards Association (CSA) Model Code for the Protection of Personal Information,
a) The Board of Directors appoints the Vice President, Corporate and Advisory Services as the designated Libro Privacy Officer
b) The Privacy Officer ensures compliance with principles and the Act. In addition, other individuals within Libro may be delegated to act on behalf of the Privacy Officer from time to time
2. Identifying Purposes
a) Personal information provided by Owners will be used for the following purposes:
i. Confirm identity of the Owner
ii. Determine Owner’s qualifications for selected services
iii. Fulfill legal reporting requirements
iv. Protect both Owner and Libro from losses due to error or fraud
v. Understand Owner better through proactive financial statuses, goals, needs and wants
vi. Share with third parties, subject to this or similar privacy policies, in order to provide service to Owners who buy and sell selected portfolios of deposits, loans or other products
a) Libro obtains consent from new Owners to collect, store, use and exchange or disclose personal information for the above stated purposes
b) Consent is obtained through acknowledgement and acceptance of the Service Agreement
c) Owners agree to the publication, distribution and acceptance of new versions of the Service Agreement as published time to time
4. Collection of Information
a) Libro collects only personal information that is necessary to achieve purposes stated above, through open, fair and lawful means
5. Use, Disclosure and Retention of Information
a) If information is used for a purpose other than one stated above, then separate explicit consent is required from the Owner
b) If an Owner’s personal information is disclosed or exchanged with another party Libro will ensure that such party accepts and complies with this policy
c) Libro retains Owner’s personal information for as long as necessary, to achieve stated purposes and to comply with legislation and regulations
d) When information is no longer needed Libro will destroy paper and electronic files in a secure way that eliminates the possibility of information contained in such files from being accessed
a) Libro will use best efforts to maintain the accuracy and up to date Owner information
b) Libro will update Owner personal information when advised by the Owner or when Libro learns of a change
a) Libro is committed to protecting all personal information from unauthorized access, disclosure, copying, use or modification; regardless of the format in which it is held
b) Annually Libro staff, Owner Representatives and Directors sign a Business Code of Conduct
a) This policy is publicly posted and accessible via Libro’s website and paper copies are available on request
b) Libro will outline and explain specific practices and details upon Owner request
9. Individual Access
a) During business hours Owners may view their paper and electronic files
b) Owners may review information contained in such files and comment on its accuracy, correctness and suggestions for revision
10. Provide Recourse
a) Owners may contact the Privacy Officer with questions, suggestions or opinions regarding compliance with this policy
b) The Privacy Officer may be contacted at 217 York St., 4th Floor, London ON, N6A 5P9 Attn: Privacy Officer or at 1-800-265-5935
c) The Privacy Officer is responsible for monitoring applicable legislation and taking steps to ensure policies, procedures and safeguards remain in compliance
SPECIFIC AUTHORITIES AND DELEGATIONS
- The Audit and Risk Committee is responsible for oversight of this policy
- The Privacy Officer is authorized to respond to requests for personal information and amendments thereto: complaints, questions and challenges regarding this policy and Libro’s practices and procedures for the collection, use, disclosure, retention and destruction of personal information
RESOLVING AND REPORTING PRIVACY ISSUES
- Minor privacy issues are, if possible, initially handled and resolved with Owners at branch level
- Unresolved and significant privacy issues are reported promptly to the Privacy Officer and/or Deputy Privacy Officer and/or other GROW Team members
- The Privacy Officer and/or designated support staff determine the severity and complexity of the issue and organize resources to initiate a quick response and resolution with input and assistance from other Libro staff
- The Privacy Officer ensures significant privacy issues are resolved with the Owners concerned and reported to the Audit and Risk Committee, immediately in the case of a breach of privacy, at their next meeting otherwise and summarized within quarterly reporting to the Committee