Winbar and With Group

Rules and Regulations
PRIVACY CODE

 
Winbar and With Group "Privacy Code" Rules and Regulations are housed under the sections stated below. Please mouse-click the relevant section for instant viewing.
 
Purpose Specification
Use Limitation
Security Safeguards
Individual Participation
Accountability
Openness
 

 

Purpose Specification
a)          
Authorised Agent collect personal information for the purposes of establishing and maintaining relationships with customers' and its interests
b)
At or before the time of data collection, Authorised Agent will advise its investor on how it will use personal information, and obtain its investor's consent to verify and supplement the personal information with external sources.
       
Use Limitation
a)
Before Authorised Agent uses personal information for purposes other than (1) those for which it was collected or (2) such others that are compatible with those purposes, it will obtain its customers' consent
b)
When personal information is no longer required for the purposes specified, it will be destroyed (erased) or given an anonymous form
c)
Authorised Agent will carefully preserve the confidentiality of customer investor/relationship. There are four circumstances under which disclosure of personal information may be made to third parties, as dictated by prudent practice and/or legal requirements:
 
Customer Consent: Except as provided elsewhere in this model privacy code, exchange of personal information with third parties, such as other credit bureau, requires customers' consent
 
Legal Obligations: When served with subpoenas, search warrants, and other court or government orders or demands from other parties empowered by legislation, banks must provide the required personal information. In doing this, however, customers' interests will be protected by ensuring that: (1) such orders or demands comply with the laws under which they are issued; (2) only the personal information legally required is produced and nothing more. Authorised Agent will not comply with casual requests for personal information from government authorities or others Unless prohibited by law, CISRAED must be notified by letter sent to their usual address or by telephone that an order for information has been received.
 
Protection of Authorised Agent's Interests: There are instances where, in the interest of the Issuer, it is necessary to disclose customers' personal information. For example, various court procedures may require that personal information on customers' accounts be introduced as evidence.
 
Public Duty: In exceptional circumstances, Authorised Agent may be under a public duty to provide information to appropriate authorities in matters of significant public interest. For instance, where Authorised Agent has reasonable and probable grounds to believe there is an attempt to use its facilities for the furtherance of criminal activity (for example, laundering of the proceeds of organised crime) a public duty to disclose may apply.
     
Security Safeguards
a)
Comprehensive security measures must be taken by Authorised Agent to protect against unauthorised access to personal information, and to protect against unauthorised use, alteration, destruction, or disclosure of this personal information;
b)
All employees are required as a condition of employment to respect the confidentiality of personal information;
c)
Authorised Agent may disclose certain personal information to business such as cheque printers, data processing service bureau, and collection agencies that provide goods and services to the Authorised Agent and/or its customers. These businesses may therefore receive, collect, or hold personal information about Authorised Agent customers for those specific purposes. Authorised Agent must require such businesses to treat any such personal information as confidential, in a manner consistent with this model privacy code, or as regulated by law; and
d)
Comprehensive procedures and/or contractual agreements or credit reporting legislation protects personal information disclosed with CISRAED/Investors' consent to third parties, such as credit grantors and credit bureau.
     
Individual Participation
a)
CISRAED/Investors have the right to obtain confirmation from Authorised Agent as to whether Authorised Agent has personal information about them. Such confirmation will be provided when CISRAED/Investors request it by following the procedures established by Authorised Agent. These procedures will ensure that Authorised Agent receives sufficiently specific information as may be reasonably be expected to enable Authorised Agent to retrieve it, if it exists.
b)
CISRAED/Investors have the right to have access to personal information about them held by their bank, except for opinions and judgements. This personal information may be obtained by following procedures established by Authorised Agent as described in subsection 8(a) above. The personal information will be extracted from the records and will be provided in intelligible form within a reasonable time and at a reasonable cost. If a request under this section is denied, CISRAED/Investors have the right to be given reasons for such denial, and to challenge such denial.
c)
CISRAED/Investors have the right to challenge personal information about them in Authorised Agent records. Incorrect or incomplete personal information will be amended and any differences as to correctness or completeness will be noted.
d)
If erroneous personal information is disclosed by Authorised Agent to third parties, which could result in investor's interests being harmed, Authorised Agent will use its efforts to convey corrections to those third parties.
e)
There will be included in the personal information referred to in subsection 8(b) above a record of disclosures of personal information to third parties. Except as noted above, Authorised Agent will record the nature of each disclosure, the date, and the identity of the party to whom each disclosure is made. This personal information will be made available to the investor as described in subsection (a) above.
     
Accountability
Ultimate responsibility for privacy protection rests with the Authorised Agent's senior management, who may assign day-to-day responsibility for the privacy protection procedures to specific staff members of the Authorised Agent.
Openness
Privacy policies, including complaint procedures, must be made known to CISRAED/Investors by Authorised Agent. If Investors have concerns about privacy of personal information, they may use the complaint resolution process. Each authorised agent or its subsidiary is required to have procedures in place to receive and deal with customers'/CISRAED/Investors' questions or concerns. If customers/CISRAED/Investors are dissatisfied with the manner in which complaints have been handled by the Authorised Agent or its subsidiary, they can contact the Office of the Area Manager of CISRAED for assistance.
       
     
 
 
 
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