Privacy Policy
At
Common Collection Agency Inc. (CCA), we respect the privacy of the debtors we
deal with on behalf of our clients. Your personal information, that is, any
information that identifies you, is only collected, used and disclosed by CCA in
accordance with this Privacy Policy. This policy is based on the Canadian
Standards Association Model Code for adherence to Canada’s Personal
Information Protection and Electronic Documents Act (PIPED). CCA commits to all
of the principles contained in the Model Code.
This policy also governs the behaviour of our employees and agents acting on
our behalf. All of our employees who have access to debtors’ personal
information have been thoroughly trained on the handling of such information.
Likewise, new employees receive training on privacy as a fundamental part of
their initial orientation. All employees are required to sign this policy and
commit to following it when handling a debtor’s personal information. Why do
we Collect, Use and Disclose Your Personal Information? Personal information to which this policy applies may include but is not
limited to the debtor’s: • Contact details: home and business phone numbers and addresses. • Assets, bank accounts and any other details about the debtor’s
financial situation. • Relatives, neighbours, friends and their contact details. • Living arrangements and property ownership. • Credit scores and credit history. • Employment history. CCA collects, uses and discloses your personal information for debt
collection purposes only. Your information may be used to collect an account we
are currently working on, but may also be used in the future for other debt
collection work we are engaged in on behalf of our clients. We collect
information about you from our clients as well as third party information
suppliers such as: • Credit reporting agencies and their partners. • Various public and private databases. • Other collection agencies. In order to obtain information from these and other third parties, CCA may
share a minimal amount of personal information for identification purposes only,
such as your name, address and date of birth. Employees are trained to never
release more information than is necessary to identify you to a third party. CCA
may also disclose your personal information to: • Other collection agencies that request information about you for debts
that they are attempting to collect. • Legal authorities when appropriate in order to comply with the law, for
example, if we receive a subpoena or court order. • A person who, in the reasonable judgement of CCA, is seeking the
information as an agent of the debtor. Do we Obtain your Consent? We are authorized by law to disclose your personal information to third
parties for debt collection purposes, and to collect your information to
investigate failures to pay monies owed to our clients in accordance with credit
card, loan, or other agreements. If you have signed a contract with our client,
such as a credit application or agreement, you may have provided your express
consent to having us collect and share personal information about you. We seek
your express consent to collect, use and disclose your personal information in
all other circumstances and for all other purposes. For example, if you want CCA
to deal with someone else to collect on your debt, we explicitly ask for your
consent to collect your personal information from, and disclose your information
to, this representative.
How is your Personal Information kept Safe? CCA has a number of measures in place to ensure that your information is kept
secure, whether it is stored electronically or in paper format. We are also
constantly taking steps to enhance these safeguards. Organizational security
measures include, but are not limited to, the following: • Visitors to CCA’s premises are required to sign in and out. All
visitors are informed of the sensitive and confidential nature of our records
and undertake not to attempt to view or obtain any such records without explicit
authorization. Cleaning staff and maintenance workers are asked to sign similar
undertakings. • CCA has a Clean Desk Policy in place whereby employees are required to
put all files and records containing personal information about debtors into
locked desks or filing cabinets at the end of every day. When a desk is left
unattended, employees also know not to leave such documents in plain view. • Documents containing personal information are stored in locked shredding
bins and shredded weekly on the building premises by a reliable third party. Physical security measures include, but are not limited to, the following: • CCA’s premises are alarm-monitored. • All offices, the server room, employee desks and filing cabinets are
locked after hours. Stringent controls are in place to ensure that keys are not
widely distributed. • Daily back-up tapes are stored in a secure off-site location. Technological security measures include the following: • CCA has made a substantial investment in reliable servers, database,
backup and security technologies, as well as industry standard firewalls to
protect your information. • CCA’s secure server is password-protected and employees are provided
with Guidelines for the Selection of Secure Passwords. • In order to avoid unauthorized access, employees are asked to log out of
the system when it is not in use. If an employee has not logged out, a ten
minute system time-out results in the employee being automatically logged out. • Only managers can obtain port-to-port secure remote access to the system.
Records containing personal information cannot be remotely downloaded or
printed. How Accurate is Your Personal Information? If the personal information we have about you is going to help us recover a
debt, we need to keep this information as accurate as possible. However, we are
relying on the information we receive from our clients, third parties and
yourself. Upon cross-checking our sources, if we find any information is
out-of-date, incomplete or false, we will immediately correct this information
on our records. We attempt to verify the personal information we possess prior
to using it or disclosing it for debt collection purposes. How Long do we Retain your Personal Information? Personal information that is in electronic format is maintained in our data
base for a period of seven years from the date an account is assigned or the
date of last financial activity or acknowledgement of the debt. Should the file
have been litigated and judgment obtained, electronic information is retained
for twenty years. Data is made anonymous on November 1st of year following the
expiration of the limitation statutes / requirements. Personal information that
is no longer necessary or relevant for debt collection purposes or required to
be retained by law shall be erased or made anonymous. Where personal information
has been used to take legal action against a debtor, CCA will retain the
information for as long as required by limitation statutes for appeal purposes.
Paper records containing personal information (for example, correspondence from
the debtor) are kept in locked filing cabinets for a maximum of 6 years before
they are shredded. Note that when we delete personal information from the
system, residual information may remain in back-up files temporarily. Do Third Party Information Suppliers Respect your Privacy? We share this Privacy Policy with all of our clients and third party
information suppliers. When we reveal your personal information in order to
identify you to third party suppliers, we expect that information to be
protected. We urge third parties to review and pay heed to this policy, not to
further disclose the personal information they have received from us, to keep
that information secure and to destroy it once they have provided CCA with the
information we require. We impose these obligations through contracts with third
party information suppliers whenever possible. Can you have Access to Your Personal Information? You have the right to access any personal information that we have about you,
as well as to find out about the uses and disclosures of this information. You
can also challenge the accuracy and completeness of the information and have it
amended as appropriate. In order to safeguard personal information, a debtor may
be required to provide sufficient identification to permit CCA to account for
the existence, use and disclosure of personal information and to authorize
access to the debtor’s file. Note that in certain situations, CCA may not be
able to provide access to all of the personal information it holds about a
debtor. Exceptions may include information that contains references to other
individuals that cannot be adequately severed so as to protect someone else’s
privacy; information that cannot be disclosed for legal, security or commercial
proprietary reasons; or information that is subject to solicitor-client or
litigation privilege. CCA shall provide the reasons for denying access upon
request. Who is Accountable? CCA takes full responsibility for the management and protection of the
personal information it collects. We have a dedicated Privacy Officer who is
accountable for compliance with this policy. If you feel that CCA is not abiding
by this Privacy Policy or have any concerns about CCA’s information-handling
practices, please contact:
CCA shall investigate all complaints concerning compliance with the policy.
If a complaint is found to be justified, CCA shall take appropriate measures to
resolve the complaint including, if necessary, reprimanding employees or
amending its policies and procedures. By providing you with this Privacy Policy, CCA is pledging our continued
commitment to protecting debtors’ personal information handled by the company.
We make all of our policies and practices relating to the management of personal
information readily available. We have a Privacy Team in place that regularly
reviews and assists in implementing improvements to our information-handling
practices. The Privacy Team reports to the Privacy Officer who may make changes
to this policy from time to time to reflect current practices.
Privacy Officer
Common Collection Agency Inc.
11 Progress Avenue, Suite 202
Scarborough, Ontario
M1P 4S7
PrivacyOfficer@commoncollections.com