CIBC Privacy Policy
Your privacy is protected
At CIBC1, an important part of our commitment to you is respect for your right to privacy.
Across the CIBC group of companies, we have policies and procedures to protect your privacy. Keeping your information and affairs in strict confidence is a cornerstone of our business and an integral part of our commitment to service excellence.
This brochure will help you better understand how CIBC protects your personal information and the rights you have in terms of our collection, use and disclosure of your information. Copies are available in our branches and online at www.cibc.com.
CIBC may amend this brochure from time to time. Please visit cibc.com for the most up to date version.
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1 This Policy governs the Canadian Imperial Bank of Commerce ("CIBC") and its subsidiaries that currently offer deposits, loans, mutual funds, securities trading, mortgages, trust and insurance services (together the "CIBC group"). "CIBC" and "we" are used throughout this brochure to mean both CIBC and the CIBC group and references to sharing information within the "CIBC group" mean disclosure by one of them to all or some of the others.
CIBC follows ten principles when collecting, using, disclosing and protecting your personal information
- We are accountable for personal information under our control. There are designated individuals within CIBC who ensure our compliance with these principles.
- The purpose for collecting personal information is identified at or before the time it is collected.
- We obtain your consent before collecting, using or disclosing your personal information, except where legally required or permitted.
- We limit the personal information we collect to what is necessary for us to conduct business and serve you to the best of our ability. We collect information only by fair and lawful means.
- The personal information we collect is only used, disclosed or retained for its original intended purpose, unless we have your consent or the information is required to meet legal requirements. We retain it only as long as necessary for those purposes.
- We take care to ensure the information we have is accurate and up-to-date.
- We safeguard the privacy of your personal information through security measures.
- We are open with you about our policies and practices related to managing your personal information.
- Upon request, we provide you with access to your personal information. You can ask how your information is used, ensure your records are accurate and complete, and update information if necessary.
- We address your concerns. If you have questions or concerns regarding your privacy, we have steps you can follow to make sure your questions are answered to your satisfaction.
Why we need your personal information
What is personal information?
"Personal information" is information about you as an individual. This includes details such as your age, marital status, education, employment history, identification numbers, financial information and credit records. In most circumstances, personal information doesn't include most information that might appear on a business card or information that is available in public records.
When you first become a CIBC customer, and whenever you apply for more products and services, we ask for personal information about you so we can:
- establish your identity
- protect you and us from error and fraud
- understand your needs and eligibility for products and services
- recommend particular products and services to meet your needs
- provide ongoing service
- comply with legal and regulatory requirements
As you do business with CIBC, we continue to collect personal information for our mutual protection. For example, we may monitor or record your telephone conversations with our representatives to ensure service quality, security and to confirm our discussions with you. We may also review and analyze your personal information, including your account transactions, to protect accounts from unauthorized use and to offer solutions that help meet your needs.
We obtain most of your personal information directly from you. When we ask for information we will let you know how it will be used. We will also inform you of our Privacy Policy.
The information we ask for depends on the product or service requested. We ask for your name, address, birth date, occupation and identification for regulatory purposes.
Providing certain information (such as a driver's licence), although convenient for identification, is voluntary. It is up to you whether you want to provide a driver's licence or some other suitable identification, subject to any legal requirements.
Some information may be obtained from other sources with your consent (if required). For example, we may verify some of the information you give us with your employer or your references. When we obtain information from someone other than you, such as a credit bureau, we record the source of that information, unless otherwise permitted or required by law.
Different products and services require different types of information. For example:
- The Income Tax Act of Canada requires us to ask for your Social Insurance Number when opening an interest-bearing or investment account.
- Financial information is used to assess your eligibility for a credit product. This may include tax returns, net worth statements, employment income and credit information. We also may use it to assess Access to Deposited Funds limits for transaction accounts or ABM withdrawals. We will also use it to ensure the advice, products or services offered to you or the investments you purchase (such as mutual funds or brokerage investments) are appropriate for you.
- Health information is required for some insurance products to ensure you are eligible for coverage. We will not refuse you any product or service, other than insurance, on the basis of any health information you have given us. We will not share your health information within the CIBC group.
Your information is obtained, used or shared only with your consent
When you apply for a product or service, we will provide you with information about our Privacy Policy and will obtain your consent. Depending on the product or service, this allows us to:
- check your employment
- obtain a credit report and exchange information with a credit bureau
- offer you other products and services
- send you information about products and services by means of direct marketing
- share your information in confidence within the CIBC group (provided it is legally permitted)
- obtain, use or disclose your information to others that we tell you about
Except as explained in There are exceptions where we may collect, use or disclose information without consent, we don't share information about you with anyone outside of the CIBC group without your consent. In addition, if we intend to use your information in any way we didn't tell you about previously, we will obtain your consent at that time.
There are many ways you can give your consent
Your express consent may be given in writing, verbally or through electronic means. Alternatively, where permitted by law, your consent may be implied through an action you've taken or when you continue to use a product or service after we've notified you of a change.
Examples of express consent:
Written - Signing an application.
Example: If you sign an application that states "I agree to the Terms on the reverse."
Verbal - Responding to a direct question from a telephone banking associate.
Example: A telephone banking representative asks, "To process your application, we need your credit bureau information. Do you agree?"
Electronic - Clicking on the "I agree" button online.
Example: If you apply for a product online, you may be asked to electronically acknowledge that you will be bound by legal terms or agree to certain statements. Clicking "I AGREE" is your electronic consent.
Example of implied consent:
Action you've taken - Use of products or services.
Example: If we offer you a VISA* card with attached conditions and we inform you of those conditions, we can conclude that you agree to those conditions if you choose to use the VISA card.
We ask for your consent before using your Social Insurance Number
When we obtain a report and update your information with a credit bureau, your Social Insurance Number (SIN) is the best way to make sure that the information actually refers to you. Wrong information could lead us to draw wrong conclusions about you.
You should be aware, though, that permitting us to use your SIN this way is voluntary for you. While the law requires us to ask for your SIN when you open an account that earns income, we need your consent to use your SIN in any other way. If you choose not to give us your SIN, or later withdraw consent for its use for other than tax reporting, this by itself will not prevent you from getting credit or any other service.
There are exceptions where we may collect, use or disclose information without consent.
If we use an outside supplier to do work for us.
At times we may use the expertise of outside suppliers to do work for us involving some of your information. For example, to print chequebooks, conduct telemarketing, collect accounts or process transactions on our behalf. We select the company carefully and confirm that it uses privacy and security standards that meet CIBC's strict requirements. Similarly, your payment transactions will be processed through payment associations such as Visa Canada/International, the Interac Association, or the Canadian Payments Association. We may need to disclose some of your information to them on a confidential basis to process payments, provide customer service, promote the service and for other reasonable purposes.If we are required or permitted by law.
We may be compelled to release information by a court of law or other legal or regulatory authority. If so, our policy is to release information only to the extent that we have to. We may also collect, use or disclose information without consent where permitted by law. For example, we may collect and use publicly available information like information in the telephone book for marketing or customer service purposes. Further, for other legal, medical or other security reasons, it may be impossible or impractical to seek or obtain your consent.If we have to protect the interests of CIBC.
In certain circumstances, CIBC may have to collect, use or release information without consent for its protection. For example, we may do so when returning a cheque for the reason "Not Sufficient Funds," when collecting an overdue account, when realizing on security pledged for a loan, or to detect or prevent fraud.
We may exchange information with credit bureaus
When you apply for certain products, we obtain your consent to exchange information about you with credit bureaus. In order to maintain the integrity of the credit reporting system, we may have to periodically update your information with credit bureaus as long as you have the product with us and for a period of time following repayment. Your consent to the exchange of information cannot be withdrawn during this time.
We protect your privacy when sharing information for business transactions
From time to time, we may sell parts of our business, sell or securitize assets, or merge or amalgamate part or all of our business with other entities. Since customer and account information will normally be a part of such transactions, we may use or disclose such information to other parties included in the transaction, as part of due diligence and/or on completion of the transaction.
You can withdraw your consent
Subject to legal and contractual requirements, you may change or withdraw your consent at any time.
To change or withdraw your consent:
- contact the branch where your account is held,
- talk to your personal banker or financial adviser, or
- call us at 1 800 465-CIBC (2422).
Withdrawing your consent will generally not affect your eligibility for CIBC offers. However, if you don't consent or if you withdraw your consent, we may not be able to provide you with a particular product or service. We'll explain the impact on you, to help you with your decision. For example, if you apply for a product with an affinity program such as Aeroplan®, you may not opt out of sharing information with the affinity program partner. The nature of information shared and the purpose for the sharing will be explained to you when you are enrolled in the affinity program.
When you change or withdraw your consent, we will do our best to make sure that our files are updated as quickly as possible. It may take some time for our records to reflect your changes as many records can only be changed during regular file updates.
You can choose not to receive direct marketing
We may ask for your consent to tell you about products and services through direct mail, telephone or other means. If you withdraw your consent to be sent direct marketing, this will not limit regulatory or product-related account information that we may send to you with your account statement or discussions with your CIBC adviser.
You can tell us you don't want us to share information within the CIBC group for secondary marketing purposes
Sharing your information within the CIBC group enables us to bring suitable products and services of other members of the CIBC group to your attention, such as mutual funds and RRSPs ("secondary marketing purposes"). CIBC will share your information within the CIBC group for secondary marketing purposes unless prohibited by law or you advise us otherwise.
We will share information about you within the CIBC group for regulatory purposes, to manage credit risk and other business risks, and to ensure we have correct and up to date information about you, such as your current address, date of birth, etc. You may not withdraw consent for this sharing.
We protect your information from loss and unauthorized access
We limit access to your personal information and store it securely in a variety of locations. Depending on the nature of the information, it may be stored in the branch you deal with, in various secure computer systems, or in archives in various locations in Canada or in other countries and may be subject to the laws of those countries.
Access to your personal information is only given to those who require it to provide CIBC's products or services.
Employees who have access to your information are made aware of how to keep it confidential. Each employee must sign an agreement stating that maintaining confidentiality is a condition of employment with CIBC.
Outside suppliers are required to sign contracts to maintain confidentiality and security of your personal information and not to use it for any unauthorized purpose.
We use a combination of security measures to protect your personal information
In addition to the physical and electronic security devices we use to protect your information, we have security standards to protect our computer systems and your information from unauthorized use or access.
This protects your information at all times, when it is stored in data files or handled by our employees. Our systems also protect your information when it is electronically transmitted, for example, between our data processing centres and a branch or banking machine when you use your credit or debit card.
We regularly audit our information security procedures and continually assess that they remain effective and appropriate.
Your information is destroyed when it is no longer needed
The length of time we keep your information varies depending on the product or service and the nature of the personal information.
We have retention standards that meet customer service, legal and regulatory needs. When your information is no longer required, we securely destroy it or convert it to an anonymous form. For legal reasons, we may keep information beyond the end of your relationship with us.
We monitor our compliance with the CIBC Privacy Policy
We have procedures in place to assist our employees in the application of the CIBC Privacy Policy. We monitor the practice of these policies and report our findings to our Chief Privacy Officer.
We comply with the Personal Information Protection and Electronic Documents Act (PIPEDA), as well as applicable provincial privacy legislation. The Privacy Office at CIBC and our Chief Privacy Officer are accountable for overseeing compliance.
We work with you to keep your information accurate
We make every effort to ensure the information in our records is correct and up to date. However, we also rely on you to tell us when your personal information changes.
It is important to ensure your personal information at CIBC is accurate and complete. This allows us to continue to offer the highest quality service and to suggest products and services that best meet your needs.
To update your address and other personal information:
- contact the branch where your account is held,
- talk to your personal banker or financial adviser,
- sign on to CIBC Online Banking and edit your information under Customer Services, or
- call us at 1 800 465-CIBC (2422).
You can easily check and update your information
You have the right to access, verify, rectify and update your personal information.
Much of your personal information is available to you where you normally bank inbranch or through Telephone Banking. A CIBC adviser can help you check your information, update it and remove any obsolete information. You can also look at and update your contact information through the Customer Services section of CIBC Online Banking.
Depending on the nature of the information you are requesting and complexity of your request, we may ask you to put your request in writing.
There's no charge for verifying or correcting your information. Depending on the circumstances, there may be a charge if you want a copy of records that we have already given you - for example, a bank statement or particulars of a cheque you've written. We will let you know in advance if there is a charge.
If you have a sensory disability, we will give you access to your personal information in any alternative format you request if we already have it in that format or if its conversion into that format is reasonable and necessary in order for you to be able to exercise your rights under applicable legislation.
You can find out the source of information we've collected
If we have obtained information about you from other people, you can ask us for the source of that information. If we obtained a credit report on you, you may have access to that information; it would have come from Equifax Canada or Trans Union Canada. You may contact them directly for a current credit report; their contact information is available on request.
You can find out to whom we've given information about you
On request, and where legally permitted, we'll provide you with the names of outside companies or organizations to whom we've given your personal information. This won't include outside suppliers we've used to do work for us, such as cheque printers or companies that process information for us. This also won't include reports to the Canada Revenue Agency, particulars of cheques returned for the reason "Not Sufficient Funds" or information that has been provided for legal or regulatory reasons.
We respond to your request promptly
Some of the information you request may not be immediately available. If this is the case, we will ask you to put your request in writing and will typically respond to you within 30 days.
If for some reason you are refused access to information held in your file, we'll explain why, subject to any legal restrictions. If you wish to challenge our decision, we will tell you how to escalate your request.
We correct your information
If we discover we have information about you that is obsolete or incorrect, we will update our records accordingly. Whenever possible, we'll correct any information which we may have given to an outside organization.
If a third party, such as a credit bureau, has given us information which you tell us is wrong, we'll give you the name and address of that party so that you can correct the information with them.
We protect other people's privacy when we make information available to you
It may not be appropriate for us to release certain information directly to you. There may be records that include information about you and other customers, or that have information confidential to CIBC or are the property of CIBC. Because we must protect everyone's confidentiality and legal rights, we cannot make these records available to persons outside of the CIBC group. We will, however, make available to you any factual information about you contained in such records.
If we are unable to disclose information to you, we will explain to you why we cannot fulfill your request.
What you can do to safeguard your privacy
Notify a CIBC branch or CIBC Telephone Banking at 1 800 465-CIBC (2422) immediately if:
- your Convenience Card®1 or VISA card is lost, stolen or retained by a bank machine
- you believe someone has obtained your card number and PIN or password
- you believe someone is impersonating a CIBC representative
- you believe your personal or financial information has been compromised
- you believe you have been the victim of identity theft, or that someone is using your personal information fraudulently
There are some simple yet very important steps you should take to protect your privacy.
Protect your Convenience Card, VISA card, PIN and passwords
Your PIN (Personal Identification Number) and passwords for online and telephone banking are the keys to your accounts. You are the only person who should know them. Never disclose your PIN or passwords to anyone or you could be liable for losses. No CIBC employee or agent will ever ask you verbally for your PIN or Online Banking password. When using Telephone Banking, we may ask for a predetermined security word to identify you.
To protect your PIN, use your hand or body to shield your PIN from onlookers when you are conducting transactions at a bank machine or at a point-of-sale.
Regularly monitor your account activities
Promptly check your statements or passbook to verify all transactions have been properly recorded. If entries do not accurately reflect transaction activities (e.g. if there are missing or additional transactions), contact CIBC immediately.
Reduce your risk of identity theft:
- don't give out personal information to unsolicited callers
- shred documents that contain personal or financial information before you throw them out
- request a copy of your credit bureau report periodically
- visit www.safecanada.ca and look for more identity theft information under the "Financial Safety" section
Make sure your contact information is up-to-date
Making sure that CIBC has your most up-to-date address or contact information will help protect your personal information from being misdirected. The We work with you to keep your information accurate section of this brochure explains how to check and update your personal information.
Protect your privacy online
To protect your privacy when banking online, a few steps you can take include clearing your browser's cache, using a firewall and protecting your computer from viruses and monitoring for spyware.
As online privacy measures continue to evolve, we update the information on our web site. The Privacy & Security section of www.cibc.com can be reached through a link at the bottom of any CIBC web page. You'll find answers to some of the most common questions you may have about online offers and surveys, online fraud ("phishing"), web site activity (including cookies) and steps you can take to protect your privacy online.
If you receive a suspicious phone call, email or letter, contact us.
If you think someone is impersonating CIBC, or believe you have been the victim of a fraud or attempted fraud through telephone, mail or email, call CIBC Telephone Banking at 1 800 465-CIBC (2422) or email .
Resolving your concerns is important to us
CIBC is committed to treating you with the greatest respect and consideration and providing the highest level of service. Even so, from time to time something may go wrong. There may be a misunderstanding or you may feel you have been dealt with unjustly. Whatever the circumstances, our primary concern is ensuring your concerns are addressed and your problem is resolved.
How to resolve concerns and complaints at CIBC
We are committed to upholding the CIBC Privacy Policy. If you have any questions or complaints about our Privacy Policy or about how we are living up to the Policy, let us know right away.
Step 1: Talk to us
In most cases, a complaint or concern is resolved simply by talking to us about it. You should be able to get swift results by talking to our employees or Manager where you do business with us. You can speak with us inbranch or by calling Telephone Banking at 1 800 465-CIBC (2422).
Step 2: Call the CIBC Customer Care Centre
If the problem is not resolved to your satisfaction, you can contact the CIBC Customer Care Centre:
| Telephone: | 1 800 465-CALL (2255) |
| Fax: | 1 877 861-7801 or (416) 218-9440 in Toronto |
| Email: |
Be sure to include:
- your name
- your address/email address where you prefer to be reached
- if you prefer, fax number with area code
- the nature of your complaint
- details relevant to the matter and with whom you have already discussed the issue
Step 3: The CIBC Ombudsman acts on your behalf
If your concerns have still not been resolved to your satisfaction, 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 |
| Email: | |
| Write to: |
CIBC Ombudsman |
The CIBC Ombudsman's Office will acknowledge your complaint. Then, providing legal action has not been taken on the matter, the CIBC Ombudsman immediately goes to work. In most cases, you will receive a response within ten working days.
If you are not satisfied with the decision of CIBC's Ombudsman regarding your complaint
Should you not be able to accept the conclusion of CIBC's Ombudsman, you can ask how your complaint 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:
Place de Ville
112 Kent Street, 3rd Floor
Ottawa, ON
K1A 1H3
Call toll free at 1 800 282-1376. www.privcom.gc.ca
Copyright® 2006 Canadian Imperial Bank of Commerce. All rights reserved.