Protecting the personal information in our control is a responsibility Source One Financial Corp. (“Source One”) takes very seriously.
What is Personal Identifiable Information?
Data or information on a person that:
- is about the individual in a personal capacity; that is, it reveals something of a personal nature about the individual, and
- it is reasonable to expect that an individual can be identified from the information (either alone or by combining it with other information) The listed examples include a person’s name when combined with other information about them, such as their address, sex, age, education, or medical history. These examples are not exhaustive and many other kinds of information may still qualify as personal information. (Source: Information and Privacy Commission of Ontario)
Personal information we collect
We collect and maintain different types of personal information in respect of individuals with whom we interact for the purposes of financing of a vehicle and may include:
- Your contact information: name, address, telephone number and e-mail address;
- Your identification information: driver’s license number, Social Insurance Number and photograph;
- Your product and service related information concerning the products and services that we provide to, or receive from, you;
- Your credit and financial information such as your banking information, payment methods and preferences, and billing and credit history;
- Your employment and business relationship information;
- Customer relationship information such as customer service requests and feed-back and information requested or provided by or from you; and
- Other information as may be required to make a suitable credit decision.
Source One may also require the same information from any spouse, partner, or co-signer. We may collect personal information directly from you, or from third parties such as credit bureaus or credit reporting agencies or your vehicle dealer, employer, bank, references, landlord or mortgage holder. We may also collect insurance information from your insurer in order to verify compliance with insurance requirements under a Conditional Sales Contract or Loan Agreement (“Contract”). If you are in default under your Contract, we may also track the location of your vehicle in accordance with the terms of that Contract.
The level of disclosure to Source One remains with the individual, however, your decision to withhold particular details may limit our ability to provide some or all credit services to you. If we are unable to accommodate your request based on the information that has been provided to us, we may ask for additional details.
In some instances, Source One may also maintain a file containing contact history that is used for customer inquiry purposes. To help us better understand our markets, we may also gather information for analytical purposes by extracting demographic information from existing files.
Where permitted or required by applicable law or regulatory requirements, we may collect information about you without your knowledge or consent and we may use the information for analytical and/or marketing purposes.
Why do we collect your personal information?
We collect your personal information so that we can communicate with you, process your application, and provide you with the services you have requested.
Source One may also collect personal information to enable us to manage and develop our business and operations, including:
- to determine, on an ongoing basis, whether or not you meet our credit and other loan requirements;
- to establish, maintain and manage our relationship with you, including to collect amounts owing;
- to provide you with, or receive from you, the products and services that have been requested or that may be of interest to you;
- to be able to comply with your requests regarding your account with us;
- to protect you and us against error, fraud, theft and damage to our goods and property;
- in the event of default under a Contract, to enable us to collect on any amounts owing and take such further enforcement steps as are outlined in the Contract;
- to enable us to comply with applicable law or regulatory requirements; and
- any other reasonable purpose to which you consent.
We may also use your personal information without your knowledge or consent where we are permitted or required by applicable law or regulatory requirements to do so.
Use of your personal information
We may share personal information with our lenders, regulatory bodies in order to meet legal, regulatory and compliance requirements, including relating to the detection and prevention of money laundering, terrorist financing, fraud and other unlawful activities.
We may disclose your personal information on an ongoing basis to credit bureaus and credit reporting agencies for the purposes of maintaining your credit history. These organizations may also verify and ensure the completeness of the information, and share the information with local, provincial and national authorities in the investigation of unlawful or improper activities in order to protect you and us from fraudulent transactions.
We may share your personal information, including contact information and information about your payment history, with your automotive dealer so that the dealer may market new products or services to you.
Further, your personal information may be disclosed:
- as permitted or required by applicable law or to comply with regulatory requirements. In such a case, we will endeavor to not disclose more personal information than is required under the circumstances;
- to comply with valid legal processes such as search warrants, subpoenas or court orders;
- to protect the rights and property of Source One, including to collect a debt that is owed to us; and
- in the event of default under Source One Contract, to the appropriate government registries for the purpose of obtaining updated demographic information.
Typically, we will seek your consent at the time that we collect the personal information. In certain circumstances, your consent may be obtained after collection but prior to our use or disclosure of your personal information. In other circumstances your consent may be implied through reasonable inferences on the part of Source One from your actions or inactions. For example, providing a name and address to receive information or providing a name and telephone number to receive a response to a question. When determining the appropriate form of consent, we take into account the sensitivity of the personal information, the reasons we are collecting it, and the reasonable expectations of the person.
You may change or withdraw your consent at any time, subject to legal or contractual obligations and reasonable notice, by contacting our Privacy Officer using the contact information set out below. In some circumstances, a change in or withdrawal of consent may severely limit our ability to provide products or services to you. All communications with respect to such withdrawal or variation of consent should be in writing and addressed to our Privacy Officer.
Safeguarding your personal information
Source One endeavours to maintain appropriate safeguards surrounding your personal information and includes physical, technical and procedural processes that are appropriate to the sensitivity of your personal information and are designed to prevent loss, unauthorized access, copying, use, modification or disclosure of your personal information.
We endeavour to limit the use, disclosure and retention of personal information to what is reasonable to fulfil the purposes for which the information was collected or for legal or business purposes.
Our security practices are monitored and reviewed on a regular basis and we endeavour to employ current technologies to protect the confidentiality and privacy of your information.
The Source One website will endeavour to use industry best practices for security and encryption when you visit the secured areas of these sites.
When you send personal identifiable information through email or text either directly or through our website, email and text are not considered a secure means of communication and the sender assumes all liability of exposure of any personal information transmitted by these means should the transmission be intercepted, misdirected or otherwise during transmission.
Accessing and amending your information
The file containing your personal information may be maintained on our servers or those of our service provider. At Source One, decisions are made based on the information we have. Therefore, it is important that your personal information is as accurate, up to date, and complete as possible. To make a change to the personal contact information contained in your file, you may call our Customer Service department at 1-877-564-8582, where one of our Customer Service agents will be available to receive your request for a change in your personal contact information.
You can ask to see the personal information that we hold about you, or to make any corrections in that information. If you want to review, verify or correct your personal information, please contact our Privacy Officer using the contact information set out below. Please note that such communication must be in writing.
When requesting an amendment in, or access to, your personal information, please note that we may request specific information from you to enable us to confirm your identity and right to amend or access, as well as to search for and provide you with the personal information that we hold about you. We may charge you a reasonable fee to access your personal information; however, we will advise you of any fee in advance. If you require assistance in preparing your request, please contact the office of our Privacy Officer.
Your right to access the personal information that we hold about you is not absolute. There are instances where applicable law or regulatory requirements allow or require us to refuse to provide some or all of the personal information that we hold about you. In addition, the personal information may have been destroyed, erased or made anonymous in accordance with our record retention obligations and practices.
In the event that we cannot provide you with access to your personal information, we will endeavour to inform you of the reasons why, subject to any legal or regulatory restrictions.
Questions, concerns and complaints
If you have questions or concerns regarding our privacy policies and practices, please call us at 1-877-564-8582
If you have a concern or complaint about privacy, confidentiality or the personal information handling practices of Source One, our employees or service suppliers, please contact:
Source One Privacy Officer
11 Victoria Street Unit B3
Barrie, Ontario L4N3A3