Eastern Credit Management Services, a division of Eastern Collection Services Ltd. Privacy Commitment to its customers.
“Personal Information” in this model code refers to information about an identifiable individual, but does not include the name, title or business address or telephone number of an employee of an organization.
The following is an outline of the ten principles in the Canadian Standards Association Model Code for the protection of Personal Information, and how they refer to our company’s policies:
Eastern Credit Management Services is responsible for any personal information about our customers, which has been provided to us by our clients, while it is under our control. As such Eastern has designated a Privacy Officer. Our Privacy Officer is accountable for the organization’s compliance with the principles contained in the Canadian Standards Association model code for the protection of personal information. Our clients, who are collecting and using the information initially, and disclosing the information to us, must abide by the same principles as they are also subject to PIPEDA.
2. Identifying Purposes
The purposes for which Eastern collects personal information about you from our clients, and on our own includes the following:
* The collection of your overdue accounts on behalf of our clients & reporting of results back to our client.
* Providing you with accurate information about your account(s).
* Locating you to collect an overdue account, or to serve you with documentation, process serving or handling a repossession on behalf of our client.
* Credit Reporting purposes.
Eastern Credit Management Services acts as an agent and outsource office for our clients, and as such is an extension of their office. Eastern collects, uses and discloses personal information for the credit related purposes that were originally intended by our client.
Eastern Credit Management Services acting as third party on behalf of our clients, is not the original collector of personal information. Eastern has the understanding that the knowledge and consent of the individual was received during the time the information was collected by our clients, who are also subject to PIPEDA.
We assure our customers that personal information will not be forwarded or disclosed to any other third parties, affiliates or agencies, without their verbal or written consent, except for the purposes specified in our Identifying Purposes section.
4. Limiting Collection
The collection of personal information shall be limited to what is necessary for the purposes identified by our office as outlined above. We will collect enough information to ensure that we are able to identify you as the correct customer. Information will be collected by fair and lawful means.
5. Limiting Use, Disclosure and Retention
Personal information will not be used or disclosed for any purposes other than for those listed in the Identifying Purposes section, except for when the consent of the individual has been obtained (or as required by law). Personal information shall be retained only as long as necessary for the fulfillment of that purpose, except where law requires a longer retention period. Personal information which is no longer required to fulfill the identified purposes will be destroyed or purged from our collection system. Eastern Credit Management Services will retain all transactional information for a time period of up to six years. Eastern will retain all credit information for a time period of up to six years. Personal and account information may be held for a time period of up to twenty years for those accounts for which our company has obtained judgment on behalf of our clients.
Eastern Credit Management Services will keep all personal information as accurate and complete and up to date as possible and as necessary for the purposes for which it is to be used.
Eastern Credit Management Services will not routinely update your personal information unless the information needs to be updated to fulfil the purposes as noted in the Identifying Purposes section, unless otherwise requested by yourself.
Your personal information shall be protected by security safeguards, which are appropriate to the high sensitivity of the information. Eastern Credit Management Services ensures that both physical and technical measures will be in place at all times, to a security level above industry standards. Appropriate safeguards will be used for the transmission, use and disposal of your physically and electronically recorded personal information.
Eastern Credit Management Services will make available to you, the customer any specific information about our policies and practices relating to the management of your personal information. Access to these policies are available to you, upon your request by contacting our Privacy Officer. You may contact our Privacy Officer by e-mail via: email@example.com, Attention Privacy Officer, in writing to: 560 Main Street, Suite 310, Hilyard Place, Building A, Saint John, New Brunswick, E2K 1J5 or verbally at 1-800-561-4151.
9. Individual Access
Upon your request, Eastern Credit Management Services will advise you, the customer of the existence, use and disclosure of any of your personal information, and we will give you access to that information, within thirty days of the request. You have the right to challenge the accuracy and completeness of the information and to have it amended as appropriate.
Any individual requesting access to their personal information, or inquiring as to whether or not Eastern Credit Management Services holds any of their personal information will be required to provide enough personal information about themselves to allow our office to identify them as the customer.
10. Challenging Compliance
Any customer who has any concerns regarding Eastern Credit Management Services information handling practices or compliance with these ten principles may at any time contact our Privacy Officer for clarification. The Privacy Officer will investigate your concern and will attempt to resolve your complaint as quickly and as satisfactorily as possible. Should the Privacy Officer deem that the complaint is justified, Eastern Collection Services Ltd. will take the appropriate measures to rectify the issue. The Privacy Officer will advise you, if the complaint is not found to be justified.