Your Privacy Is Protected
Effective September 1, 2013
Table of Contents
- Your Privacy Is Protected
- What We Collect and How We Collect It
- How We Use and Share Information
- Protecting Your Personal Information
- Your Privacy Choices
- How to Contact Us
Your Privacy Is Protected
- “personal information” or “information” means information about an identifiable individual such as contact information, account numbers, or details such as age, marital status, and financial information. This information can be in any form including paper, electronic, video or voice recording.
- “CIBC”, “we”, “our”, “us” or the “CIBC Group” means collectively Canadian Imperial Bank of Commerce and its Canadian affiliates that offer deposits, loans, mutual funds, securities trading, portfolio management, investment counseling, mortgages, credit cards, trust services, insurance and other products or services. When we make reference to sharing information within the CIBC Group it means sharing by one member of the group to some or all of the others in the group.
- “program partners” means companies we have carefully selected to provide benefits, products or services under, or to participate in, a CIBC partner program.
- “CIBC partner program” means a program under which CIBC clients are entitled to receive specified benefits, products or services that are provided by, or in participation with, our program partners. For example, affinity reward or loyalty programs, travel or credit insurance, purchase or credit protection programs and retailer offers or coupons.
- “permitted or required by law” or “legal and regulatory obligations” means actions that we are permitted or required to do under any laws or regulations, or any rules, codes, guidelines, expectations, or requests of any applicable regulator or self-regulatory organization, or under any codes, programs or principles publicly adopted by CIBC.
What We Collect and How We Collect It
The type of personal information we collect will depend on various factors such as the type of products or services you request or use and any applicable legal and regulatory obligations. This information includes:
Contact – information that allows us to communicate with or contact you (e.g., address, telephone number, e-mail or other electronic address, social media account name and fax number).
Identity – information that allows us to identify you or to meet tax, anti-money laundering and other “know your client” legal and regulatory obligations (e.g., name, Social Insurance Number (SIN), date of birth, occupation, and government-issued identification).
Financial – information that allows us to determine creditworthiness or eligibility for or appropriateness of products or services (e.g., employment and financial history with others, income, net worth, credit reports, investment knowledge and objectives, and details of security provided for loans).
Transactional – information about how you use different products or services or otherwise do business with us (e.g., purchase and payment history).
Relationship – information that helps us to understand more about you including how you like to do business and what types of products, services or offers you may like (e.g., language and communication preferences, location, demographics and interests).
Health – information about your health, such as information necessary to determine eligibility for, or benefits under, health-related products or services such as insurance. Due to the sensitive nature of this type of information, health information will not be used or shared for marketing or loan assessment purposes.
We collect information from a variety of sources but much of the information comes from you (e.g., applications for or use of our products or services, communications with us, and user-generated content on our social media websites such as photographs or comments you post).
We also collect information from other sources such as credit bureaus, references you have provided, program partners, government or financial institutions or from public sources such as telephone directories, newspapers, Internet sites, commercially available marketing lists or government agencies and registries or public records.
We may monitor or record communications between you and our representatives (e.g., telephone calls) in order to enhance and maintain client service quality, to protect you and CIBC, to confirm our discussions with you or for training purposes. We use surveillance, including videotaping, in and around our branches, ABMs and other locations for the safety of our clients, employees and others, to protect against illegal activity, such as theft, vandalism and fraud, or to enhance and maintain client service quality.
How We Use and Share Information
We use and share personal information for the following purposes, to:
Provide You with Products or Services
- establish your identity and determine your eligibility for products or services
- help to ensure that the advice, products or services offered to or purchased by you are appropriate for you
- set up, manage, administer and maintain your products or services
Communicate with You
- send communications by various methods including mail, e-mail, text (SMS), telephone, fax, or other telecommunication channels, or social media including communicating any benefit, feature or other details about the products or services you have with us
Provide You with Value
- review and analyze your applications, transactions and other information to understand who you are, your financial needs and activities, and what products, services, and promotions may be of interest to you, including targeting promotions based on information that we have collected
- promote and market products or services offered by the CIBC Group, by our program partners or other third parties we have carefully selected
- better manage and improve your overall relationship with the CIBC Group including monitoring, reviewing or improving client service and business processes to make it easier to do business with us
- encourage you to continue doing business with us
Manage our Business
- perform our everyday business and operations including record keeping or internal reporting (e.g., if you have provided your SIN it can be used as an internal identification number to accurately identify you from clients having the same or similar names)
- understand and better manage CIBC Group’s business and to develop products and services, including conducting market research or analyzing data we hold about you
- administer referral arrangements
- use third-party service providers to perform services on our behalf
- periodically update your information with credit bureaus as long as you have the product or service with us and for a reasonable period of time thereafter
- manage CIBC Group’s credit, business and other risks as may be required to operate as an effective, efficient and financially prudent financial institution
- meet tax or legal and regulatory obligations
- protect you and us from error and criminal activity including the prevention, detection and investigation of fraud, money laundering, cyber threats and other such risks and threats (e.g., we will review and analyze your applications, transactions and other information to help us identify various types of threats and risks such as credit, fraud, and money laundering)
Some of the specific ways we use and share your information within the CIBC Group or with third parties include:
Program Partners – We share information with our program partners to help determine your eligibility for a CIBC partner program. If you participate in a CIBC partner program, we also share information in order to administer, develop, manage and promote the CIBC partner program including accrual of points or rewards, reporting on and analyzing the program’s performance, developing new benefits, products or services, and conducting market research. If you withdraw your consent to this sharing we may not be able to provide you with the product or service (e.g., where the program is an automatic benefit of the product like a credit card with a rewards program).
Joint Accounts or Representatives – Where you hold a product or service jointly with another person (e.g., joint accounts) or where someone is authorized to use or access your product or service (e.g., authorized user on a credit card), or where liability is shared with others (e.g., someone has provided a guarantee or indemnity for your obligations), we may share your information with them (or their representative) in connection with the product or service. Where someone is acting as a representative or we reasonably believe is acting with proper authorization (e.g., legal guardian, a person having power of attorney, estate representative, a lawyer, an accountant, and, for minor children, a parent or guardian) we may share information with and take instructions from them.
Protect You – Where you might be a victim of fraud, financial abuse, or other illegal activity or where we have reasonable grounds to believe your interests can best be served by taking action, we may share information with the appropriate legal or governmental authorities, your next of kin or any other appropriate person (e.g., notification of our concerns regarding potential financial abuse may be provided to a public guardian or trustee’s office). In these circumstances, we will only share information we believe is reasonably necessary to protect your interests.
Protect Us – We share information to protect our rights or interests. For example, where we are involved in judicial, administrative or regulatory proceedings, or other similar processes including enforcing our rights (e.g., to collect on a debt). Or, in order to comply with any legal and regulatory obligations including any subpoena, warrant, or any judicial, administrative orders or demands.
Business Transactions – If we enter into a business transaction involving personal information, such as selling or securitizing assets, we may share information with the other parties to the transaction (e.g., as part of due diligence or on completion of the transaction). We require that the other parties keep this information confidential and limit its use to the purposes of the transaction. Where we enter into a business transaction involving the purchase of information by us, this policy will apply to our collection, use and sharing of the purchased information. If we sell assets, the purchaser may be permitted or required by law to retain certain information for a period of time. We may also share your information with the beneficial owner of a product or service we provide you.
Protecting Your Personal Information
At CIBC we take the protection of your personal information seriously. We make every reasonable effort to prevent unauthorized use, sharing, loss or theft of information. We regularly audit our security procedures and assess that they remain effective and appropriate.
Employees who have access to your information are made aware of the importance of keeping it confidential. Depending on the nature of the information, it may be stored in the branch or office you deal with, in various computer systems, or in the record storage facilities of the CIBC Group or service providers.
Where we use service providers who might have access to information, we select them carefully and require them to have privacy and security standards that meet CIBC’s strict requirements. We use contracts and other measures with our service providers to maintain the confidentiality and security of your information and to prevent it from being used for any other purpose.
The length of time we keep your information will vary depending on the product or service and the type of the information. We keep your information for as long as we reasonably need it for customer service, legal or reasonable business purposes. For these reasons, we keep your information beyond the end of your relationship with us. When your information is no longer required, we securely destroy it or delete personally identifiable information.
Your Privacy Choices
Subject to legal, business or contractual requirements, you can withdraw your consent to our collection, use or sharing of information at any time upon giving us reasonable notice. However, withdrawing your consent may limit or prevent us from providing you with, or being able to continue to provide you with, specific products or services. For example, if you choose not to provide us with your SIN, we will not be able to provide you with any product where the collection of SIN is required under tax law (e.g., a registered product like an RRSP).
In particular, during our relationship with you, we provide you with the following privacy choices:
SIN: Including your SIN in a credit bureau request is the best way to make sure the credit bureau information accurately refers to you. However, this use of your SIN is optional and if you choose not to give your permission, this by itself will not prevent you from qualifying for products or services.
Marketing: Subject to applicable law, from time to time the CIBC Group may offer you products or services, including special promotions, which may be of interest to you. This consent is optional and you can decide to withdraw it at any time. However, this will not limit the information provided to you through discussions with a CIBC representative or through general CIBC marketing or servicing channels (e.g., posters in branches and electronic messages on ABMs or our website), or information we send you that is related to your existing products and services or is permitted or required by law.
Call Recording: If you do not wish to have your telephone calls recorded, you have the option to conduct your business with us through a CIBC branch, office or location, through the use of our ABMs, through our Internet banking services, or by writing to us.
In certain circumstances your consent cannot be withdrawn. For example, you may not withdraw your consent where our collection, use or sharing is permitted or required by law, is required to ensure we have correct and up to date information about you (e.g., current address), or is necessary to manage our business including the sharing of information when we assign our rights to others for business transactions. In order to maintain the integrity of the credit reporting system, we may periodically update your information with credit bureaus as long as you have a credit product or service with us and for a reasonable period of time afterwards. Your consent to the exchange of information cannot be withdrawn during this time.
Keeping Your Information Updated
We take care to keep the information in our records as accurate, complete and up to date as necessary for the purposes for which it is used. However, we also rely on you to tell us when your information changes. Keeping your information accurate and up-to-date allows us to continue to offer you the highest quality service.
Accessing Your Information
You have the right to access personal information we hold about you. Much of your information is available to you through your account statements or bankbook updates, by visiting the branch or office you deal with, by accessing your account online, or through telephone banking. If you require other information please see the “How To Contact Us” section below.
Addressing Any Privacy Concerns
The following process applies to CIBC banking clients. For other CIBC clients (e.g., clients of CIBC Private Investment Counsel and CIBC Wood Gundy), refer to the complaint process provided to you when you opened your account, contact the branch or office where your account is administered, or speak to your CIBC representative.
Step 1: Talk to Us
In most cases, a complaint, question or concern is resolved simply by talking to us about it. You should be able to get swift results by talking to a CIBC representative where you do business. You can speak with us in-branch or by calling Telephone Banking at 1-800-465-CIBC (2422).
Step 2: Call the CIBC Client Care Centre
If your complaint, question or concern is not resolved to your satisfaction, you can contact the CIBC Client Care Centre:
Telephone: 1-800-465-CALL (2255)
Write to: CIBC Client Care
PO Box 15, Station A
Toronto, ON M5W 1A2
Be sure to include your name and contact information where you prefer to be reached, the nature of your complaint, question or concern, details relevant to the matter and with whom you have already discussed the issue.
Step 3: The CIBC Ombudsman
If your complaint, question or concern has still not been resolved to your satisfaction by Client Care, feel free to contact the CIBC Ombudsman:
Telephone: 1-800-308-6859 or (416) 861-3313 in Toronto
Fax: 1-800-308-6861 or (416) 980-3754 in Toronto
Write to: CIBC Ombudsman
P.O. Box 342
Toronto, ON M5L 1G2
Step 4 – Escalate
If you are not satisfied with the decision of the CIBC Ombudsman you can ask how your matter can be further escalated.
If the above steps fail to resolve your concern you may also contact the Office of the Privacy Commissioner of Canada.
How to Contact Us
If You Want to update or correct any personal information we hold about you: You Should Contact the branch or office where your account is held or talk to your CIBC representative. If you are a CIBC banking client, call us at 1-800-465-CIBC (2422) or sign on to CIBC Online Banking and (where available) edit your information under Customer Services. If you tell us that we have information about you that is obsolete or incorrect, we will update our records as necessary. When appropriate, we’ll correct any information which we may have given to a third party.
If You Do not wish to receive marketing communications from the CIBC Group: You Should Contact the branch or office where your account is held or talk to your CIBC representative or if you are a CIBC banking client, call us at 1-800-465-CIBC (2422). When you withdraw your consent for marketing, we will update your file as quickly as possible. It may take some time for our records to reflect your choice as many records can only be changed during regular file updates and your choice may not be captured for a promotion already in progress.
If You Do not wish us to use your SIN as an aid to identify you in credit bureau requests: You Should Contact the branch or office where your account is held or talk to your CIBC representative.
If You Want access to the personal information we hold about you: You Should Contact the branch or office where your account is held or talk to your CIBC representative. We will require you to put your request in writing (we can give you a form) and that you provide us with enough specific details in order to help us understand your request and conduct our search for your information. We will need you to verify your identity before searching for or providing you with access to your information. We will let you know in advance if there will be a fee to provide access to your information. If you have a sensory disability you may request your information to be made available in an alternative format. There may be limits on your right to access your information. If we have obtained information about you from others, you can ask us for the source of that information. On request and where legally permitted, we will provide you with the names of third parties to whom we have given or may have given your information. However, this will not include service providers we have used to do work for us. It will also not include reports to the Canada Revenue Agency or information that has been provided for legal and regulatory obligations. If you wish to request access to a credit report we obtained about you from a credit bureau, we will give you a copy if we still have it on file. We will provide you with the name and address of the credit bureau we used as they will have the most current information and can provide you with information on how to read the report. You have the right to access and correct the credit bureau report directly with the credit bureau.
If You Want written or more details about our privacy policies and practices (including with respect to service providers outside of Canada): You Should Refer to our CIBC Privacy Principles, Online Privacy Statement, or Privacy FAQ or see the “Addressing Any Privacy Concerns” section above.
For more information on client privacy
talk to a CIBC representative
visit your nearest branch
call 1-800-465-CIBC (2422)