This policy applies to the collection, use, disclosure and management of personal information by Xdebts Debt Solutions (Xdebts).
The Director of Xdebts is accountable for compliance with these policies and procedures regarding the manner in which Xdebts collects, uses, discloses and otherwise manages personal information.
The Director is appointed as the Privacy Officer for Xdebts.
Xdebts is responsible for the personal information in its custody and control.
Xdebts collects and uses personal information to provide advice and information on personal money management issues and to provide advice, information and options for debt repayment to Xdebts clients by handling their various creditors. The personal information collected by Xdebts includes information on clients’ debts, assets, income, living expenses, employment situation, general financial status and their relations with particular creditors.
Xdebts also uses the approximate demographic information from the personal information collected to identify services and programs that may benefit the communities we serve and to target our marketing and awareness programs. No individual can be identified through this information.
Xdebts personnel are trained to explain the purposes of collecting the information to any client who asks for an explanation. The purpose for which personal information is collected and used by Xdebts personnel is communicated to each client at or prior to the time of collection.
Xdebts will not collect, use, or disclose a client’s personal information without the express consent of the client.
Xdebts personnel collect personal information about individuals only where such individual is a client or potential client of Xdebts. Our clients’ personal information is not used or disclosed for purposes other than those for which it was collected, except with the consent of the client or as required by law.
All information provided to Xdebts related to our Debt Consolidation Programs (DCPs) is kept strictly confidential and is protected in accordance with Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA). Xdebts will not release any information regarding clients’ files without obtaining their written authorization (unless required by law). This includes personal information as defined in PIPEDA.
Xdebts discloses personal information only for the purposes for which it was collected. It keeps information for as long as it is required for the stated purposes.
Xdebts retention policy provides that files regarding Debt Consolidation Programs (DCPs) are retained for a maximum of 7 years from the date the DCP is closed, after which time the files are permanently destroyed.
Xdebts retention policy provides that files regarding financial counselling only sessions are retained for a maximum of 7 years from the date of the last counselling session, after which time the files are permanently destroyed.
Personal information that is deemed as no longer required to fulfil the identified purposes or that is not required to be retained pursuant to any applicable law is permanently destroyed, erased, removed or made anonymous. Xdebts periodically reviews the personal information in its custody and control in order to ensure that any personal information no longer required to be retained has been destroyed, erased or made anonymous.
Xdebts ensures, to the best of its ability, that the information it holds is accurate, complete, current and relevant to the identified purposes.
Xdebts maintains a strict confidentiality agreement with those who have access to the personal information being held by Xdebts. Any corrections to the information can be given to those parties. Xdebts recognizes that it is crucial that creditors of its clients have current and accurate information in order to make important decisions regarding the acceptance of our client Debt Consolidation Programs as well as other credit decisions.
Xdebts ensures that personal information is stored in electronic and physical files that are physically secure. Security measures include storage of files in locked filing facilities when not in use; secure locks on the offices of Xdebts and its satellite offices. Electronic files are protected by encryption software. Staff passwords to access such electronic files are controlled and employ high-level encryption practices.
Distribution of personal information regarding clients is restricted to the employees of Xdebts and any creditors for whom a Debt Consolidation Program is entered into in respect of Xdebts clients.
The employees of Xdebts sign a Confidentiality Agreement and will follow these privacy policies and procedures.
Physical Xdebts files containing personal information are routinely shredded under the supervision of Xdebts employees. Deleted electronic files will be permanently removed from the system, as discussed in “Limits for Disclosing Information Related to Debt Consolidation Programs”.
Upon written request, Xdebts will provide an individual with confirmation as to whether Xdebts has personal information about them, what the information is, what it is being used for and to whom the information has been disclosed.
Individuals should send their written request for access, with contact information and enough information about themselves to identify them to the Chief Director of Xdebts.
Xdebts will respond within thirty (30) days of receiving any access request at no cost to the individual.
If the individual can present proof of an error in the personal information held by Xdebts, then Xdebts will amend the information and where appropriate, send the corrected information to others who have used the incorrect information.
If Xdebts denies the individual’s request for access, it will state the reasons for denial.
Individuals may send any complaints regarding Xdebts’s compliance with its own privacy policies and procedures to the Program Director of Xdebts. The Program Director or designated staff will investigate the complaint and respond to the individual.
If the individual’s complaint is justified, Xdebts will change its policies and procedures related to the matter so that other individuals will not experience the same problem.