PRIVACY POLICY

What is personal information?
Personal information is information that identifies you. It includes your name and address, your age and gender, your personal financial records, identification numbers such as your social insurance number, personal references, and employment records.

What personal information do we collect?
We only collect personal information from you by fair and lawful means and for legitimate and necessary reasons, which includes information:

• to identify you,
• to protect you and us from fraud and error,
• to comply with legal requirements,
• to understand your financial needs,
• to determine your eligibility for our products and services, and
• to help us better match our products and services to your needs.

The Income Tax Act requires that we ask you for your social insurance number in connection with interest bearing and registered accounts. Additionally, we collect health information when you apply for any of our life insurance products.

First West is committed not to collect more information than is needed to provide you with our products and services and is committed to inform you of the purposes for which we collect your personal information.

Why do we collect your personal information?
We collect your personal information to open accounts and administer your accounts and other financial products with us. We collect your personal information to verify your identity and creditworthiness, to consider you for employment, to establish your eligibility for special offers or discounts, and protect you and First West from fraud.

Consent
By agreeing to the privacy portion of the terms of service of your First West account and/or products and providing your personal information to us you are consenting to First West using and disclosing your personal information in the ways described in this policy. You may withdraw all or part of your consent at any time by contacting your local First West branch or notifying the Privacy Officer.

Your consent to disclose some personal information is necessary in order to provide you all the products and services that First West offers. If your consent is withdrawn, we may be limited in the products and services we can provide to you.

Your personal information will only be disclosed when required by law, or in the ways described below. If First West is interested in disclosing your personal information for any other reason we are required to receive new consent from you.

Who do we disclose your personal information to?
As part of the day-to-day management of your account and the services we provide you, we may at times disclose your personal information when required to by law or when necessary to continue providing you with products and services. We disclose your personal information with your consent to third-party suppliers of products and services, such as administration of accounts and loans, cheque printing, credit cards, and access to online banking.  First West ensures that all information provided to third-parties is given the same degree of privacy protection that we offer our members, regardless of where in the world that service provider is located. Some of our suppliers may be located outside of the province or country. When your personal information is sent to another jurisdiction for processing, your information could be accessed by the courts and law enforcement agencies of that jurisdiction.

We disclose your information to credit reporting agencies and to other financial institutions to update your credit information as needed from time to time. We disclose your information to market research firms for purposes of analysis and conducting surveys, solely on behalf of First West. We disclose your information to our affiliates and other carefully selected organizations for the purpose of enabling them to give you information about products and services that may be of interest to you.

We will disclose your information to bailiffs, collection agencies, lawyers and others when collecting a debt owed to First West, enforcing an agreement between you and First West, ensuring or otherwise protecting First West’s interests in security held by First West or, realizing on security held by First West. We disclose your information to other organizations in connection with a merger or sale of some or all of First West’s assets. We disclose your information as required or authorized by law.

When you open an account with us through our Online Membership Application, we’ll need you to provide identification information. You can verify your identity by taking a picture of yourself and your government-issued picture ID (eg. BC Drivers License) using your mobile device. A third party will be authenticating your image. Or, you can choose to skip this step, and verify your identity using your Social Insurance Number (SIN). Please visit our First West Privacy Code for information on how we safeguard and protect your information when it is in the hands of a third party.

When you use our Digital Assistant Finley, you acknowledge and provide your consent for a third party to monitor your chats and keep a record of conversations for training, development and quality assurance purposes. The digital assistant collects IP Addresses, device and location information for the purposes of improving its functionality. You also agree you will not input any personal information into the digital assistant, such as your name, address, account numbers, usernames or passwords.

Preferences
We may tell you about First West products or services through direct mail, e-mail, by phone, or by other means. If you do not wish to receive such communications, you may unsubscribe through a link on the emails, contact the branch where you do your banking or opt out from our website:

• Envision Financial
• Island Savings
• Valley First and Enderby & District Financial

If you opt-out of receiving our marketing communications related to promotional offers, financial advice, or community involvement, this will not affect your eligibility for products or services. By opting-out for one account, you’ll be opting-out for all your First West accounts including joint accounts where you are the primary account holder.

First West commits to complying with British Columbia’s Personal Information Protection Act “BC PIPA” and the CSA Model Code for the protection of personal information, which form the backbone of our First West Privacy Code:

1. Accountability: First West is responsible for personal information in our custody and control including information that has been transferred to a third party for processing. First West has designated a Privacy Officer to be accountable for our compliance with the First West Privacy Code. All employees of First West are responsible for your privacy and compliance with this Privacy Code.
2. Identifying purposes: The purposes for which personal information is collected shall be identified at or before the time the information is collected.
3. Consent: The knowledge and consent of the individual are required for the collection, use or disclosure of personal information, except where inappropriate e.g. for legal requirements, medical emergencies or security reasons. An individual can withdraw consent at any time by contacting the branch or office where the individual does their banking, subject to legal or contractual restrictions and reasonable notice.
4. Limiting collection: The collection of personal information shall be limited to that which is necessary for the purposes identified by First West. Information shall be collected by 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 individual or as required by law. Personal information shall be retained only as long as necessary for the fulfillment of those purposes.
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.
7. Safeguards: Personal information shall be protected by security safeguards appropriate to the sensitivity of the information.
8. Openness: First West Credit Union shall make readily available to individuals, specific information about its policies relating to the management of personal information.
9. Individual Access: Upon written request to the branch or office where an individual does business, or the Privacy Officer the individual shall be informed of the existence, use and disclosure of his or her personal information and shall be given access to that information except where inappropriate. An individual shall be able to challenge the accuracy and completeness of the information and have it amended as appropriate. Access will be given no later than 30 calendar days after receipt of the request. Costs to comply with the request are at the requestor’s expense. The individual will be informed of the approximate costs in advance. Refusal to provide access for valid reasons will be explained in writing to the individual. Some possible reasons for refusal are: access would reveal information about a third party; information is protected (e.g. solicitor-client privilege); access threatens life or security of another individual; access reveals confidential commercial information; access reveals information generated in the course of a formal dispute resolution process; access reveals information gathered for reporting a breach of an agreement or contravention of a law.
10. Challenging compliance: An individual shall be able to address a challenge concerning compliance with the above principles to the designated individual or individuals accountable for First West’s compliance (refer to Principle 1 Accountability above).

Right to access your information
You have the right to access the personal information maintained about you in First West’s records. You may also submit documentation to correct inaccuracies or provide written comments in disagreement with any material contained in your personal file. To view your personal records, address your request, in writing, to HRdirect@firstwestcu.ca or Privacyofficer@firstwestcu.ca

This information page describes in general terms how your personal information is collected and used within the online banking section of our site. The online banking area of the site is the area of our website that requires you to use your Member ID and Personal Access Code (PAC) to enter.

Controlled access to your information
To ensure that you are the only person accessing your personal financial information, we restrict access to the online banking section of the site by requiring that you enter your Member ID and PAC to login. Only you know your PAC. Our employees do not have access to your PAC, and they will not ask you to reveal it. If someone does ask you to provide your PAC to them, we ask that you refuse to do so and contact us immediately.

Transactional services
By nature, our Internet banking site has many transactional functions such as transfers between accounts and bill payment functions. These transactions are all logged to ensure that your accounts are debited or credited appropriately, and a history of each transaction is available to verify your account information. We store and use your transactional information in the same fashion as if you performed the transaction at a branch or through any other service channel.

We may also use transactional information for servicing your account — for example, billing you for the particular transactions that you perform, or for the services that you use.

Creating a secure channel
We create a secure channel between your browser and our server to protect your information when you use the site. First West implements a number of measures to provide secure online and mobile banking, including:

• Automatic session timeouts—To prevent certain forms of session hijackings, online and mobile banking sessions automatically end if inactive for 15 minutes.
• Temporarily disabling online accounts—To prevent against brute force password guessing attempts, online accounts are temporarily disabled if too many failed attempts to login are recorded.
• Data encryption—Our online and mobile banking services ensure that any information in transit between your PC or mobile device and our banking environment cannot be read or altered.
• Communication standards—We will never ask you to provide your passwords in email or any other communication method.

Application forms
To provide you with a convenient method for applying for loans and mortgages, or for purchasing other financial services products such as Registered Savings Plans, we may provide secure online application forms. These forms capture personal information that we use to provide you with the products and services you request. This information is processed in a similar way to application forms received through our other channels.

Website usage statistics
To continually improve our site, we often collect statistics about how our members are using it. These usage statistics are only viewed in the aggregate and are not associated with you as an individual. We use this information for purposes such as improving the pages where our members are having difficulties.

The information collected may include your IP address, your browser type and your operating system, as well as data such as the number and types of pages visited, and the length of time spent per page and on the site overall.

Our use of cookies
We also use a key web technology called cookies. A cookie is a small information token that sits on your computer. As you use this site, cookies are passed back and forth between our server and your browser.

Specifically, we use two kinds of cookies — session cookies and persistent cookies. A session cookie exists only for the length of your browsing session and is deleted when you close your browser. A persistent cookie is a cookie that stays on your computer after you close your browser. A persistent cookie may or may not expire on a given date.

We use a session cookie to maintain the integrity of your online banking session. With each page that you visit, the cookie is passed back and forth between our server and your browser. We use the cookie to distinguish your session from the many others that may be happening at the same time. Our session cookies never store any personal information, such as your name, or date of birth, or financial information, such as your accounts and balances.

Most recent browser versions allow you to set some level of control over which cookies are accepted and how your browser uses them. For example, it may be set to notify you when it is receiving a cookie so that you accept cookies from only known, reliable sites such as this one. If you are concerned about cookies, we encourage you to upgrade your browser to a recent version and review the Help section of your browser to learn more about its specific control features.

Third-party cookies
From time to time, we work with third-party companies such as digital media agencies, which assist us in advertising our products and services. These third-party companies use “cookies” to do so. Typically, these “cookies” expire once you are finished with your visit to our website. These “cookies” are solely used for advertising purposes and are not used to collect your personal information or to track you in any other way.

Memorized accounts feature
We use a persistent cookie to store information to help you personalize the site and to make it easier to use. For example, we allow you to make the login easier by remembering your login information within our Memorized Accounts feature. Since the Memorized Accounts feature is optional, this cookie only contains information that you have entered into it. We never store your Personal Access Code (PAC) in a cookie.

Logout button
To ensure that no-one else can access your personal information, always use the logout button to end an online banking session. It is located at the top of every page. When you exit using the logout button, we delete your session cookie so that your session cannot be resumed unless your Member ID and PAC are re-entered.

Automatic session time-outs
In the event that you leave your computer without logging out, the online banking feature of this site has been designed to end your session automatically if our system detects that you haven’t provided any instructions or used the browser buttons to navigate for several minutes. To restart the session, you will need to provide your PAC again.

Email
To communicate with us electronically, we strongly recommend that you use our Contact Us feature. This feature provides a secure channel for sending us comments, questions or instructions.

General email is not secure since it passes through many points on its route from you to us. If you are using general email to communicate with us, we strongly recommend that you do not include personal financial information (such as account numbers) within the email as we cannot guarantee its confidentiality en route to us.

When you email us your comments, questions or instructions, you provide us your email address and we use it to correspond with you. We then store your email and our replies to you in case we correspond further.

Links to other sites
Our site may also contain links to other websites or Internet resources. As an example, from time-to-time we may provide links to Microsoft or Netscape to assist you in upgrading your Internet browser. However, we have no control over these other websites or Internet resources and do not control their collection, use and disclosure of your personal information. Always review the Privacy Statements of the sites that you are viewing.

Contact us
We welcome any questions or concerns about your privacy relating to use of our website. Please use the contact us form to submit your questions or comments.

As we continue to expand our online banking service to serve you better, and as new Internet technologies become available, we may update the information on this page at any time, to reflect changes.