SquareTwoFinancial

Privacy Policy

Introduction

Scope

This policy applies to the operations of CCL and its subsidiaries across Canada and across all business units.1

Personal information:  means any information, recorded in any form, about an identifiable individual. Personal information does not include anonymous or aggregated information. Anonymous or aggregated information is information that cannot be associated with or traced back to an identifiable individual.

CCL Financial Inc., (‘CCL’) has prepared this policy to inform you of its practices regarding the collection, use and disclosure of the personal information about identifiable individuals. We take measures to safeguard the privacy and confidentiality of personal and confidential information. Adhering to strict confidentiality and privacy guidelines as outlined in the Personal Information Protection and Documents Act (Canada) and the various Provincial Privacy Acts, is the cornerstone of our commitment to protecting the privacy of our employees, clients and their customers.

Scope

This policy applies to the operations of CCL and its subsidiaries across Canada and across all business units.

Personal information means any information, recorded in any form, about an identifiable individual. Personal information does not include anonymous or aggregated information. Anonymous or aggregated information is information that cannot be associated with or traced back to an identifiable individual.

Consent

Except where permitted or required by law, CCL will endeavor to obtain the consent of each individual and/or company providing personal information to CCL for the collection, use or disclosure of such personal information by CCL.

Corporate Responsibility

CCL is a Canadian owned and operated collection agency specializing in providing its customers with various debt collection services. CCL’s customers include major financial institutions, retailers, governments and their agencies, telecommunication firms, utilities and other firms that are in the practice of granting credit to its customers.

CCL therefore owes a duty of care to its customers and by extension to our customers’ customers. The information to which CCL is granted access to by its customers is of a highly confidential nature as is the information that is acquired during the execution of its business activities. For these reasons, CCL has developed and applied specific privacy and confidentiality policies in order to manage and safeguard this information.

Our Employees Responsibilities

Each one of our employees is responsible for maintaining the confidentiality of all personal information to which he/she is granted access. CCL employees are trained upon hiring about their duties in this regard and are required to sign a confidentiality agreement binding them to these responsibilities. In addition, all employees are required to review and acknowledge an understanding of the Personal Information Protection and Documents Act, applicable Provincial Privacy Legislation as well as other regulatory guidelines.

CCL continually coaches and trains our employees with respect to ongoing compliance as well as understanding developing issues in the realm of privacy and confidentiality. CCL employees are also required, as a condition of employment, to conform to these policies and procedures.

Privacy Principles Regarding the Collection, Use and Disclosure Activities of CCL

  • CCL gains access, through its customers, to sensitive information which information is required for CCL to provide debt collection services to its customers.
  • CCL limits the amount and type of personal information it collects. CCL will only collect information required for its business operations;
  • CCL will only use information for the reasons it was collected and will not willfully disclose this information to third parties unless duly authorized to do so or as required by law;
  • CCL will store all information in its care in a secured fashion, whether electronic or paper based. CCL will restrict access to those employees who specifically and lawfully require the information for the purposes of performing their duties;
  • CCL will maintain personal information for as long as CCL believes it is necessary to fulfill the purpose for which it was collected and as required by applicable laws. CCL will proceed to securely dispose of any information that is no longer of value to CCL in its completion of its business activities;
  • CCL will take all reasonable steps so that customer information is accurately maintained, complete and up to date as is necessary to fulfill the purposes for which this information is to be used;
  • CCL will take reasonable measures so that customer information is protected by the appropriate security safeguards as required by the sensitivity level of the information maintained;
  • CCL customers may, upon written request, have access to their personal information maintained by CCL. The written request must contain sufficient detail to enable CCL, with reasonable effort, to identify the information in respect of which the written request is made. ;
  • Customers may challenge CCL’s compliance with the privacy policy. It is at the written request of the customer that we will undertake to investigate and respond in writing to any customer complaint.
  • CCL will not sell any customer information;
  • CCL will be receptive and open to customer concerns regarding our policies and procedures that apply to the management of the customer information

Privacy Contact

CCL Financial Inc. has appointed a Chief Privacy Officer who oversees privacy governance including policy, dispute resolution, education, communications and escalation. CCL’s Privacy Officer reports to the Chief Executive Officer. The Chief Privacy Officer can be contacted at CCL Financial Inc., 1310 Kerrisdale Blv. Suite 200 Newmarket, ON L3Y 8V6, directly by phone at 905-715-7689, fax 905-715-7946 or email trossi@squaretwofinancial.com.

If you have concerns or questions regarding CCL's privacy policy, or wish to access or correct your personal information, please contact the privacy officer as set out above.

In Summary

CCL considers privacy and the protection of confidential information to be a cornerstone of its business practices. CCL will continue to develop review and monitor its policies and procedures to ensure compliance with all applicable legislation, customer requirements and general common sense and commits to treating the individuals, whose information has been entrusted to CCL with care and dignity.