|TRANS UNION OF CANADA, INC.|
PRIVACY FACTS NOTICE
|(Last updated March 2007)|
For information about how to dispute the accuracy of your personal information in our files, including how to file a notice of dispute on-line, please visit our website.
As part of this commitment, we strive to continuously improve the measures that we have in place to safeguard your information. We actively participate in various levels of the Canadian and provincial governments to take a leadership position in helping to develop, enact, and enforce laws and regulations regarding consumer credit reporting and consumer privacy. Internally, we also strive to improve our own processes and policies, whether that means developing a new technology to increase accuracy in reporting or working closely with businesses to tailor a solution that delivers only the information that is necessary for that marketplace.
But adherence to laws and regulations is only the beginning. TransUnion also works closely with businesses in all industries to proactively develop new business practices that go above and beyond basic legal requirements for safeguarding consumer privacy. We are constantly looking to develop new safeguards and solutions that take full advantage of the latest technologies to stay one step ahead of the rapidly changing consumer marketplace.
TransUnion serves as a vital bridge between consumers and businesses. We facilitate the mutually beneficial transactions between consumers and businesses that help drive our national economy and enhance our standard of living. The only way that our role is possible is because of the vast amount of trust that consumers and businesses place in our accuracy, integrity and objectivity. As such, we take our responsibility to consumer privacy very seriously.
We are committed to protecting your privacy, and support a general policy of openness about how we collect, use and disclose the personal information of Canadian consumers.
"personal information" means any information about an identifiable individual.
"Us", "We" and "TransUnion" means Trans Union of Canada, Inc.
TransUnion is a credit information and software services company and a licensed consumer credit reporting agency operating across Canada. We serve both consumers and the business community by providing credit information, fraud and identity management services and risk management tools to help our customers make decisions.
We were formed in 1989 with the goal of offering the highest quality consumer credit-related products and services to the Canadian market. TransUnion has automated most data processing and maintenance functions and continually works with its clients to improve information business processes to enhance performance and promote speed and accuracy.
Long before the federal Personal Information Protection and Electronic Documents Act came into force in 2001, TransUnion was regulated by provincial consumer reporting legislation designed to protect the privacy of credit information and to ensure the fairness and accuracy of credit-reporting systems. Therefore, TransUnion has a long history of compliance with legislative and regulatory requirements.
An Overview of Our Business
We facilitate consumer transactions by providing consumer credit reports to our clients, which include banks, credit-card companies, finance companies and other institutions. By their nature, these consumer credit reports must include some personal information about consumers. Accordingly, we regularly collect, use and disclose personal credit information of Canadian consumers. Credit grantors and other institutions provide TransUnion with factual information about how their customers pay their bills and other debts. Credit reporting agencies, such as TransUnion, compile and assemble this information, along with public record information, into a "file" for each consumer. In return, credit grantors and authorized institutions, pursuant to the applicable provincial consumer reporting legislation, are able to obtain credit reports about consumers.
TransUnion generates millions of credit reports every year to make credit buying fast, easy and safe for qualified applicants. The availability of these reports benefits both businesses and consumers. The credit reports allow our clients to make informed credit decisions and portfolio management decisions based on reliable information, and consumers, in turn, benefit from rapid access to credit facilities in order to purchase cars, major appliances and other household items.
We also provide a suite of authentication services to assist our clients in identifying potentially fraudulent transactions. In the course of providing these services, we may use personal information contained in our credit reports to see if it matches the information that has been provided by an applicant, typically to credit granting institutions or merchants. When we provide our authentication services, we typically do not disclose credit information; instead we use the report to check the information internally. While preventing fraud is in everybody's best interest, these services may directly benefit consumers if someone is attempting to pose as the consumer by misappropriating the consumer's identity and personal credit information.
Our Collection Practices
We primarily collect your personal information from the following sources:
We limit our collection of personal information to include only what is necessary to supply our clients with the accurate and up-to-date information they need to make meaningful decisions and in order to provide our clients with the other services described in this Policy. We periodically review the data in our credit-reporting system to ensure that it only contains information relevant to the services we provide. Furthermore, we ensure that our retention policies comply with the requirements of provincial consumer reporting legislation.
If you call us, we may record and retain the recording to ensure the accuracy of our discussions and for quality control purposes.
Information We Collect
(a) What is Included in Your Credit Report
TransUnion's credit reports may contain the following personal information:
(b) Identification Requirements
We also collect other information you have provided to confirm your identity, which we maintain for quality control and authentication purposes. This information may include copies of, or information from, your driver's licence, birth certificate, passport, credit cards, signature, photograph, and copies of bills or correspondence. This information is not part of your credit report.
Information We Do Not Collect
TransUnion credit reports do not contain:
While TransUnion may furnish credit scores to its clients based on the information contained in an individual credit file, TransUnion does not maintain or update that information in the individual consumer's credit file.
Our Use and Disclosure of Your Personal Information
We limit our use of consumers' personal information to those purposes which have been disclosed to consumers by our clients, or for purposes which are otherwise permitted by law. We use and disclose personal information in compliance with all applicable federal and provincial privacy legislation, and also in accordance with applicable consumer reporting legislation. Accordingly, we are working with our credit-granting and other clients to make them aware of the importance of informing consumers of the purposes for which they are providing personal information to TransUnion, or access personal information from TransUnion, at the time the information is collected from the consumer and/or prior to its use by TransUnion.
Specifically, we use and disclose personal information in the following circumstances:
In addition, we may provide anonymous information (i.e., information that does not identify individual consumers) in the form of aggregate or demographic data to our clients or service providers.
We may also generate and use anonymous information to develop, enhance or validate our products, processes or services. Personal information will necessarily be used to generate anonymous information and, when required, to research, validate and test the use of anonymous information in such processes, products, services and enhancements.
We require our clients to limit the use of personal information obtained from TransUnion to those purposes that have been disclosed to the consumer, and for which appropriate consents have been obtained, or which are otherwise permitted by law.
We do not, except where otherwise permitted by law, collect, use or disclose personal information unless the consumer is aware of the purposes for which the information will be used or disclosed, and has given his or her consent to such use or disclosure.
In almost all cases, consumers will not provide such consent directly to us, but to our clients. We work with our clients to make them aware of the importance of obtaining consumer consent prior to providing TransUnion with consumers' personal information, and prior to accessing the personal information contained in our credit reports.
We have appointed a Compliance Manager and Privacy Officer and a Chief Privacy Officer to oversee and ensure our compliance with the privacy principles established by the federal Personal Information Protection and Electronic Documents Act, and with provincial privacy and credit reporting legislation. However, protecting personal information does not begin and end there: We are committed to fostering a sense of responsibility amongst our employees for protecting the privacy and accuracy of personal information while it is in our care.
Our clients have obligations to consumers when accessing personal information from us or providing personal information to us. We seek to educate our clients to ensure they understand their responsibilities regarding personal information. We have processes in place to encourage our clients to comply with applicable law and obtain the necessary consents. Such processes include entering into binding agreements to that effect with our clients and conducting random audits of our clients' internal procedures; however, the responsibility for compliance ultimately rests with them.
Our Safeguarding Practices
We take the protection of personal information seriously. We have adopted procedures to secure storage of personal information and are committed to working with our clients to protect the security of personal information during any transfer to or from us. We have also instituted a number of safeguards to identify and prevent the fraudulent use of personal credit information. TransUnion uses firewall technology to protect its data from would-be intruders and has different processes in place to secure information such as passwords, encryption, antivirus software and physical security measures.
Fraud affects us all, which is why we co-operate, to the full extent of our ability, with law enforcement officials to identify and prevent fraud.
Access and Accuracy of Credit Reports
Consumers can always review a copy of their credit report to ensure that the information is current and accurate.
When gathering personal information, we work with our clients to increase their awareness of the importance of providing only personal information that is accurate, complete, and up-to-date. However, TransUnion cannot alter the information reported by our clients, unless the information is determined to be wrong, incomplete or otherwise inaccurate. If consumers do not agree with the accuracy of the information TransUnion has on file, we have procedures to ensure that such information is verified, and, where appropriate, amended or corrected. We also have an established complaint procedure to address consumer concerns and to ensure any inquiries and complaints are appropriately investigated and addressed.
When our clients base their credit decision about a consumer on information from us, we advise them to inform their consumers that they obtained the credit information from us. Clients are advised to provide consumers who are declined credit with our toll-free number.
Retention of Your Personal Information
TransUnion retains your personal information in our credit information database for as long as necessary to fulfill the purpose(s) for which it was collected and to comply with applicable laws. Consumer reporting legislation also imposes certain restrictions on the retention of personal credit information. In addition, TransUnion may delete personal information reported about you by a data supplier if our relationship with the data supplier comes to an end. The end of a data supplier relationship may impede our ability to maintain a current and accurate credit file and/or carry out our investigation procedures. We delete personal information in these circumstances to ensure that your credit file remains as accurate, complete and up-to-date as possible. Please review our website at www.transunion.ca for additional information.
We welcome consumers to contact us to obtain more information or if they have questions. Our Consumer Relations Centre is staffed by trained personnel who can assist consumers in obtaining and understanding their credit report.
Consumers can visit our website at www.transunion.ca.
Any consumers who have recently applied for credit or obtained a copy of their credit report may contact us at:
For service in French:
1 Place Laval, Suite 370,
Laval, PQ H7N 1A1
Telephone: (877) 713-3393 or (514) 335-0374
Hours of Operation: 8:30 a.m. - 5:00 p.m. ET (Monday-Thursday)
8:30 a.m. - 4:30 p.m. ET (Friday)
For service in English:
PO Box 338 LCD1,
Hamilton, ON L8L 7W2
Telephone: (800) 663-9980
Hours of operation: 8:00 a.m. - 8:00 p.m. ET
Protecting Yourself from Identity Theft
Identity theft is one of Canada's fastest growing crimes, and one which the victim may not discover until long after significant damage has been done to his or her credit report. There are a variety of ways that you could fall victim to this crime, including "phishing" (seemingly genuine, but forged, e-mails purportedly sent from a reputable company that require you to provide personal information in a linked website or risk losing certain benefits from that company), and "Dumpster diving" (where individuals sort through garbage looking for bank statements, invoices, etc., that reveal an individual's personal information).
The best way to guard against identity theft is to learn about this crime in order to identify suspicious activity. Please visit our website for tips on how to protect yourself at www.transunion.ca.
To review our Online Privacy Statement that addresses the manner in which we collect, use and disclose the personal information that we collect from you on our websites click here.
Looking to the Future
Privacy is an evolving consumer issue, and we are committed to working with federal and provincial Privacy Commissioners and ministries, and other stakeholders in the credit-reporting industry, including credit-grantors and consumers, to develop fair, efficient and effective policies and procedures for the preservation of the privacy and accuracy of personal information in our files.
Last revised March 2013.
By using our Website or related services, you consent to the collection, use and disclosure of your personal information (as defined below) in accordance with this Online Privacy Statement.
In this Online Privacy Statement, we will use the following terms:
What Personal Information We Collect Online
We may collect some or all of the following personal information through our Website or when providing our services:
How We Use Your Personal Information
We use your personal information collected through our Website, or when providing our services, to:
When We Disclose Your Personal Information
Knowledge and Consent
TransUnion collects personal information about you through the Website, and in the course of providing services, only when you voluntarily provide it. Typically, we will seek consent for the use or disclosure of your personal information at the time of collection. In certain circumstances, consent may be sought after the information has been collected, but before use (for example, when we want to use information for a purpose not previously identified).
The form of consent that we seek, including whether it is express or implied, will largely depend on the sensitivity of the personal information and the reasonable expectations of the individual in the circumstances.
We will not, as a condition of the supply of a service, require you to consent to the collection, use or disclosure of information beyond that required to fulfill the explicitly specified and legitimate purposes for which the information is being provided.
TransUnion's Website makes use of "per-session" cookies. Unlike "persistent" cookies, which are stored on a user's hard drive and can last indefinitely, per-session cookies are stored only in a browser's temporary memory and are deleted when the browser is shut down.
When users visit our Website, our web server offers the user's browser a per-session cookie. As the Website is navigated, this cookie is read back to our web server, allowing us to generate an anonymous "click trail" profile of the visit. From the aggregated information about visits, TransUnion learns how visitors interact with its Website, how the Website design and content can be improved, and how visitors' experiences can be improved.
TransUnion does not link, share or associate the contents of the per-session cookie with any other information in a way that would enable the identification of visitors to our Website. Nor do we track or link together multiple visits by any single user over time. Our per-session cookies cannot be "read" by any other web servers, so users cannot be tracked or profiled using TransUnion's cookies if they visit multiple sites on the Internet.
Some browsers can be set to reject all cookies. If a user chooses to modify a browser in this manner, some pages of our Website may not function properly.
IP Addresses and Server Logs
Unique Internet Protocol (IP) addresses are assigned to all Internet users by their Internet Service Providers (ISPs). IP addresses do not directly identify Internet users; however, through an ISP, an IP address may be linked to a particular user.
During a visit to a website, certain information about a user's traffic patterns, linked with the user's IP address, is passively and automatically collected in the normal course of establishing and maintaining a website connection. This information is logged by the web server of the website that is visited.
The following information is logged by TransUnion's web servers during visits to our Website: IP addresses, type of operating system, time and duration of visit, web pages visited and browser type. We do not link server log information to any other information in a way that would enable the identification of visitors to our Website. Server log information is analysed by us in order to improve our Website and to customize the Website for users. In addition, from time to time, server logs may be reviewed for security purposes; for example, to detect unauthorized activity on our Website. In such cases, server log data, containing IP addresses, would be shared with law enforcement bodies in order that they may identify users in connection with their investigation of the unauthorized activities.
Links to Third Party Sites
How We Protect Your Personal Information
TransUnion makes all commercially reasonable efforts to protect the personal information that is collected from you through the Website against loss and unauthorized access. This protection applies in relation to information stored in both electronic and hard copy form. Access to your personal information is restricted to selected employees or representatives. In addition, TransUnion employs generally accepted information security techniques, such as firewalls, access control procedures and cryptography, to protect personal information against loss and unauthorized access.
Correcting or Updating Your Information
Last revised March 2007.