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BMO Privacy Code
Your Privacy is our Priority: Our Commitment to You
BMO Financial Group appreciates the opportunity to help you meet your financial needs. From the day Bank of Montreal was founded in 1817, earning and keeping your trust has been at the very core of our business. We are committed to respecting and protecting the privacy and confidentiality of the personal information you have entrusted to us. It is important for you to understand what information we will collect, how we will use it, and who may see it.
This Privacy Code outlines our commitment to you, and is designed to comply with applicable Privacy legislation in Canada, which incorporates the following ten principles:
Other important information:
1. Accountability
Each and every one of our employees is responsible for maintaining and protecting the personal information to which they have access. We have strict policies and procedures for protecting personal information and designated individuals within BMO Financial Group who are responsible for monitoring our compliance.
BMO Financial Group’s Chief Privacy Officer is a member of our executive management team and
oversees privacy governance including policy, dispute resolution, education, communications activities and reporting to our Board of Directors and Senior Management on enterprise-wide privacy matters. See the Provide Recourse principle for contact information.
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2. Identifying Purpose
When you become a BMO Financial Group customer, or apply for additional products and services, we ask you for your personal information
for the following purposes:
- to verify your identity and protect against fraud
- to understand your financial service requirements
- to determine suitability of products and services for
you
- to determine your eligibility for certain of our
products and services, or those of others, and offer them to you
- to set up and manage products and services you have
requested, and
- to comply with federal and provincial legal or
regulatory requirements
Your personal information may be verified with credit bureau, credit insurers, registries, your employer, personal references and other lenders.
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3. Obtain Consent
When you apply for a new product or service, we ask you for your consent to collect, use or disclose your personal information. You may, at any time, withdraw your consent as long as:
- you provide reasonable notice
- we are not legally required to collect, use or
disclose your information
- withdrawing your consent does not impede our ability
to fulfill your contract with us
- it does not relate to a credit product we have granted you where we are required to collect and exchange your personal information on an ongoing basis with credit bureaux, credit insurers and other lenders
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4. Limit Collection
We only collect the information we need. We may ask you to provide the following
information:
- Social Insurance Number (SIN) for tax reporting purposes as well as other income related government purposes such as when opening an income generating account or a registered retirement investment. We do this in order to comply with the Canada Revenue Agency’s income reporting requirements. We may also collect and use your SIN for administration purposes, such as to ensure an
accurate match between your personal information and your credit bureau information, or as an internal identification
number to accurately identify customers having same or similar names.
- Financial Information to ensure that the advice we give is appropriate for you and/or the investments you purchase are suitable for your circumstances.
- Health Information is required for some of our insurance products to ensure that you are eligible for coverage.
You can choose not to provide us with certain information in some situations. However, if you make this choice, we may not be able to provide you with the product, service, or information you request. We may monitor or record our telephone calls with you for our mutual
protection (e.g. to ensure that your instructions are carried out, to document that we have made required disclosures to you, and to ensure that customer service levels are maintained).
We will make certain that you are informed of the purposes listed above when you apply for any of our products or services. If a new purpose for using your personal information develops, we will ask you for your consent.
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5. Limit Use, Disclosure and Retention
BMO Financial Group will only use or disclose your personal information for the reason(s) it was collected. Under no circumstances do we
sell or give lists of our clients to other companies for their own use, and if we obtain client lists from other organizations, we require the organizations to confirm their compliance with all relevant privacy legislation.
To ensure that you benefit from our full range of products and services, we will, with your consent, share your personal information (other than health information) to the extent permitted by law, amongst BMO Financial Group.
Over time, we may buy new businesses or sell some of our businesses. Accordingly, personal information associated with any accounts,
products or services of the business being purchased or sold will be transferred as a business asset to the new business owner.
We may use other companies to provide services to you on our behalf and they will be given only the information needed to perform those services. We have contracts in place holding these companies to the same high standards of confidentiality by which we are governed.
Your information may be transferred across country borders for the purposes of data processing. We may be required to provide
information to a government agency under a lawful order made in that country.
Personal information may be released to legal authorities in cases of suspected money laundering or other criminal activity, for the detection and prevention of fraud, or when required to satisfy the legal or regulatory requirements of federal or provincial governments and/or other regulatory authorities. Other reasons for the release of personal information include when we are legally required to do so (e.g. by court order) or to protect our assets (e.g. collection of overdue accounts). If we release information for any of these reasons,
we keep a record of what, when, why and to whom such information was released.
BMO Financial Group has policies in place that govern the retention of your personal information so it will be kept only for as long as it fulfills its intended purpose or as legally required.
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6. Be Accurate
We are committed to maintaining the accuracy of your personal information and ensuring that it is complete and up-to-date. If you discover inaccuracies in our data, or your personal information changes, please notify the branch or office where you do business immediately, so that we can make the necessary changes. As well, we will make our best efforts to advise others of any
important amendments to your personal information that we may have released to them. If we do not agree to make the amendments that you
request, you may challenge our decision. Recourse is described in the Provide Recourse principle.
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7. Use Appropriate Safeguards
Your personal information is secure within BMO Financial Group, regardless of the format in which it is held. We have comprehensive security controls to protect against unauthorized use, access, alteration, duplication, destruction, disclosure, loss or theft of your personal information.
We maintain physical, electronic and procedural safeguards to protect your personal information. Examples of safeguards include restricted access to our information processing and storage areas, limited access to relevant information by authorized employees only, use of passwords, PINs and pass keys, firewalls and encryption of electronically transmitted information, and the use of secure locks on filing cabinets and doors.
We have agreements and controls in place with credit bureaux, credit insurers, other lenders and third party service providers requiring that any information provided by us must be safeguarded and used only for the sole purpose of providing the service we have requested the company to perform.
Within BMO Financial Group web sites, cookies or other information-tracking technologies may be used to improve the functionality or security of web sites, or to provide you with a more customized online experience. Please note that cookies cannot
capture files or data stored on your computer.
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8. Be Open
BMO Financial Group’s Privacy Code is also available in our branches and offices as a printed brochure. Our Privacy Code outlines why we ask for your personal information, how it is used and who it may be shared or disclosed to. Contact information is also provided, so that you know who and where to address your questions or concerns.
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9. Give Individuals Access
If you want to review or verify your personal information, or find out to whom we have disclosed it, please request this by contacting the branch or office where you do business. We may need specific information from you to enable us to search for, and provide you with, the personal information we hold about you. We may charge you a nominal fee depending on the nature of your request. However, we will advise you of the fee prior to proceeding with your request. There may be instances where we are unable to provide some of the personal
information we hold about you and if we are unable, we will let you know the reason(s) why.
In most provinces you have the right to access and verify the personal information held about you by credit bureaux. We will provide you with the name and location of any credit bureau that has provided us with a report on you.
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10. Provide Recourse
The branch or office where you do business is well equipped to handle any questions you may have about our Privacy Code. However, we want to hear from you if you have any further concerns. Please contact us at one of the following offices:
President and Chief Executive Officer
Personal and Commercial Client Group
BMO Financial Group
P.O. Box 1
First Canadian Place
Toronto, ON M5X 1A1
Call: 1 800 372-5111
Or
President and Chief Executive Officer
Private Client Group
BMO Financial Group
P.O. Box 150
First Canadian Place
Toronto, ON M5X 1H3
Or
Chief Privacy Officer
BMO Financial Group
P.O. Box 150
First Canadian Place
Toronto, ON M5X 1H3
Independent Oversight
Office of the Ombudsman
BMO Financial Group
55 Bloor Street West, 8th Floor
Toronto, ON M4W 3N5
Call: 1 800 371-2541
Fax: 1 800 766-8029
Or
Office of the Privacy Commissioner of Canada
Place de Ville, Tower B, 3rd Floor
112 Kent Street
Ottawa, ON K1A 1H3
Call: 1 800 282-1376
Fax: 613 947-6850
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Respecting Your Privacy Preferences
BMO Financial Group fully respects your privacy preferences. Simply contact the branch or office
where you do business to discuss the following options that are available to you:
- Direct Marketing – If you
don’t want to receive direct marketing, request that we remove the personal
information about you from our marketing lists.
- Sharing – If you don’t want us to share personal information about you among BMO Financial Group members(see Scope section for list of members), request to opt out of this type of sharing. Please note that you cannot opt out of sharing your personal information where you have requested a product or service that is jointly offered by more than one member of BMO Financial Group.
- Social Insurance Number (SIN) – If you don’t want us to use your SIN for administration purposes as described in the Identifying Purpose principle, with the exception of income tax reporting purposes, request to opt out.
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Scope
This Code applies to the operations of BMO Financial Group in Canada, regardless of how you choose to do business with us – in our branch or office, at an ATM, online, or by telephone. Reference throughout this Code to “we”, “our” and “us” means BMO Financial Group and its members which include: Bank of Montreal, Bank of Montreal Mortgage Corporation, BMO Investments Inc., BMO Trust Company, BMO Nesbitt Burns Inc., BMO InvestorLine Inc., BMO Harris Investment Management Inc., BMO Life Insurance Company, BMO Nesbitt Burns Financial Services Inc., Jones Heward Investment Counsel Inc. and Guardian Group of Funds Ltd.
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