The Ottawa Community Loan Fund (“OCLF” or “we” or “us”) values our clients, including you (“you”) and we recognize the importance of your personal information. We drafted this privacy policy (the “Policy”) to provide you with a good understanding of why we collect and use your personal information, how your information is shared, retained and protected, and how you can exercise your personal choices. We will also explain how you can find out what personal information we hold about you. 

By voluntarily providing us with personal information, you are consenting to its collection, use, and disclosure in accordance with this Policy. 

What is personal information? 

Personal information is information that identifies you or can be used to identify you. Examples of personal information include: first and last name, mother’s maiden name, mailing address, telephone number (including mobile), email address, date of birth, social insurance number (SIN), government- issued identification, credit history, information about your employment and education, annual income, assets and liabilities, and financial transactions. 

Why we collect and use personal information 

We collect and use personal information to establish and manage our relationship with you. This includes providing OCLF programs such as small business or professional development loans and educational services, confirming your identity, and complying with legal and regulatory requirements. We will give you some examples to explain each one of these purposes. 

To establish and manage our relationship: With your consent, we collect and use personal information to open your file, to report to our funders the services you may use, and to facilitate loan applications or partner services that you have requested. 

We need to confirm who you are and verify the information you have provided to us: We will ask for your name, address, telephone numbers (including mobile), email address, and date of birth, and may ask for other forms of identification. If you are applying for a loan, we may ask you for your SIN or permanent residence card to confirm your identity. Providing either of these for identity verification purposes is optional. To withdraw your consent for the use of your SIN or permanent residence card for identity verification purposes, you may contact us under “How to refuse or withdraw your consent” as set out below. Note that if you withdraw your consent, then certain loan services may not be possible. For corporate clients applying for a loan, we need to collect the signing officers’ names and other personal details. 

We need to assess your eligibility and suitability for our programs: When you apply for a small business or professional development loan we may ask about your credit and payment history, education, employment, annual income, assets and liabilities. We may need information about how you intend to use the loan and the source of any incoming funds or assets. 

We need to communicate with you: We may communicate with you by phone, fax, mail, email or other electronic means to provide you with information about our services, to collect on a debt owed to us, or for other related purposes. 

We may need information about related parties: In some circumstances, we may need information about your spouse, legal guardian, beneficiaries or personal representatives to establish and manage our lending relationship with you. 

We collect and use personal information to manage our business: 

• Operating and managing our business and business relationships. 
• Reporting to funders. 
• Preventing and detecting fraud and criminal activity. 
• Collecting debts, enforcing obligations and to manage and assess risk. 

We are also required to collect and use personal information to meet legal and regulatory requirements. We collect and use personal information that may be required for anti-money laundering and other applicable legal or regulatory requirements. 

Why we share your personal information 

We may share your personal information with third parties for the purposes described below. 

If you apply for a personal, professional development, or small business loan, we may share information with our loan service providers and funding agencies including Alterna Savings and Credit Union Ltd., Futurepreneur Canada, Desjardins Group, or the Government of Canada. 

If you register for services with our partner agencies we may share your information with our funding agencies including the Government of Canada and our partner agencies including World Skills, Lebanese and Arab Social Services Agency, Ottawa Community Immigrant Services Organization, Desjardins, Alterna Savings & Credit Union. 

When personal information is provided to our loan service providers or our partner agencies we will require them to protect the information in a manner that is consistent with our privacy and security policies, practices and standards. 

We may share information to meet legal requirements or where we are required or permitted to do so by applicable law. This may be: 

• to other organizations for the purposes of investigating a breach of an agreement or contravention of law or to detect, suppress or prevent fraud; 
• to establish, exercise or defend legal claims; 
• to protect the rights, property and safety of OCLF and others; 
• to courts, law enforcement and regulatory authorities in the jurisdictions in which we or our service providers operate, including to respond to a local or foreign court order, search warrant or other demand or request which we believe to be valid; 
• to comply with the rules of production of a local court; and 
• to satisfy legal and regulatory requirements that we believe are applicable to us. 

We may share information in accordance with your requests or as you otherwise consent. 

How we protect and retain personal information 

We have implemented reasonable measures designed to safeguard the personal information in our custody and control against theft, loss and unauthorized access, use, and disclosure. 

We restrict access to personal information to employees and authorized service providers who require access to fulfil their job requirements. 

We may keep and use information about you in our records for as long as it is needed for the purposes described above, or to otherwise meet our legal obligations, even if you are no longer a client. 

How we maintain accurate personal information 

We require accurate, complete and up-to-date records to provide our services, and we have implemented processes to help ensure this. 

We also rely on you to provide us with information that is true and complete. If any personal information changes or becomes inaccurate or out of date, please advise us using the contact information set out below so we can update our records. 

How to refuse or withdraw your consent 

You can refuse to consent to our collection, use or disclosure of personal information, or you may withdraw your consent to our further collection, use or disclosure of your personal information at any time by giving us reasonable notice, subject to limited exceptions. This includes withdrawing your consent for OCLF to use your SIN or government issued identification to confirm your identity. 

If you wish to withdraw consent, you may do so at any time by contacting us. 

Depending on the circumstances, your withdrawal of consent may prevent us from providing you, or continuing to provide you, with some services, the ability to access certain services, or information that may be of value to you. 

In addition, we may have legal, regulatory or contractual obligations to collect, use or disclose certain of your personal information, in which case you may not withdraw your consent. For example, during the term of a loan, you may not withdraw your consent to our ongoing collection, use or disclosure of your personal information in connection with the loan you have with us. 

We will act on your instructions as quickly as possible but there may be certain uses of your information that we may not be able to stop immediately. 

What about links to other websites 

This Policy only discusses the privacy practices for our website and services. However, our website contains links to other sites. This Policy does not cover the information practices of those websites, nor do we control or endorse their content or privacy policies. Once you follow a link to another website, you are subject to the privacy and security policies of the new website. We encourage you to read the privacy policies of all websites you visit, before you share any personal information on a website. 

How to access or update your personal information 

You can request to access or update the personal information we hold about you. Please send request in writing to the contact information included at the end of this Policy. 

To process your request, we may ask you for information to validate your identity and confirm the scope of your request. 

We may not be able to provide you with access to your personal information in certain circumstances, such as where your request includes personal information about a third party that cannot be removed, or when the information you are requesting is protected by legal privilege. 

How we notify you of changes to this Policy 

If this Policy changes in the future, we will post an updated version on our website (www.oclf.org). We recommend that you check our website periodically in order to review our current Policy. You can tell if this Policy has changed by checking the date that appears at the bottom of this Policy. Depending on the circumstances, we may also decide to send you a notice in other ways in our discretion, such as via email or other contact information you have provided that the Policy was changed. 

How to contact us 

If you wish to review or verify the personal information in your file, or if you have any questions about our privacy practices, you may do so by writing to our Executive Director at the following address: 

OCLF 2211 Riverside Drive Unit 308 Ottawa, ON K1H 7X5 Attention: Executive Director 

Or you can contact us by email at: privacy@oclf.org 

Last Updated: November 15, 2019