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Torys Quarterly: The new data economy: opportunity and risk for business. This federal framework consolidates and strengthens the Bank Act consumer protection provisions applicable to banks including authorized foreign banks and amends the Financial Consumer Agency of Canada Act to reinforce the role and increase the powers of the Financial Consumer Agency of Canada FCAC. The obligations imposed by the framework do not supersede either federal or provincial privacy laws. At a high level, and for banks with well-developed privacy and data governance programs, obligations under the framework should not entail the introduction of fundamentally new or novel processes. After all, banks already collect, use, and retain large volumes of highly sensitive data. This requirement raises the question as to how and from where banks can collect the necessary customer information to assess whether the product or service is appropriate. For example, can banks rely on information they already have? Are banks allowed to obtain and rely on information obtained from external sources such as social media or third parties? Information gathered by the bank during the course of their relationship with the customer is a key resource for assessing appropriateness, but banks may also wish to use information gathered from social media or third parties. If not, fresh consent may be needed. When revising or drafting new consent sign-offs, banks must ensure that the scope of use provided in the sign-off is reasonable. To establish reasonable use, banks will need to show that there is a defined business objective and that the personal information collected is necessary to achieve the objective. Banks should consider implementing the necessary controls to ensure that any data used in the appropriateness assessment is accurate, particularly when such data originates from external sources such as social media. As noted above, the new complaint management obligations imposed by the framework have several privacy implications. The first pertains to the very comprehensive record that banks will be required to create and maintain for each complaint. The privacy risk associated with this record-keeping requirement arises because banks will gather a considerable amount of new and sensitive information in the course of investigating and responding to a complaint 7. Banks will need to ensure that this information is only used for the purposes for which it was collected i. To aid compliance in this regard, information should be appropriately labelled or tagged, and banks may consider measures such as segregated storage of the data. In order to effectively investigate a complaint on a product sold by a third party, banks will likely ask the third party to share customer information with the bank. It should generally be possible to overcome these objections, as privacy law does not bar disclosure as a matter of course. Banks must not only investigate and respond to complaints, but are also required to retain all complaint records for seven years 9. As noted above, complaint records are likely to contain information from a number of different internal and external sources and may include proprietary or confidential information of the bank or a third party, or sensitive information about the complainant or other individuals e. Since these records must be kept for at least seven years, appropriate security and record retention policies and procedures should be developed and implemented to address the risks associated with them. Segregation of complaint records may assist with the implementation of these controls e. While complaint records do not present novel record retention issues, banks nonetheless should ensure that. Every quarter, banks must submit to the FCAC Commissioner a copy of the record 12 that reaches the designated level Although complaint information submitted by banks to the FCAC could be subject to access to information requests, we expect the FCAC to refuse such requests on the grounds that such information is protected by section 17 of the FCAC Act However, should the FCAC be unsuccessful in refusing the request, the bank will need to ensure that any sensitive information provided as part of the record be redacted before it is disclosed as a result of an access-to-information-and-privacy request. Although quarterly complaint records submitted by banks will most likely be protected, the FCAC will still be required to publish a report which will include a summary of the information provided by the banks in their annual complaint report Bill C amended the FCAC Act by adding the following two criteria when determining an administrative monetary penalty in the case of a violation:. The addition of duration as a criterion underlines the importance that banks establish explicit retention policies that refer to statutory retention and litigation holds. Banks may wish to consider adopting measures such as:. This publication is a general discussion of certain legal and related developments and should not be relied upon as legal advice. If you require legal advice, we would be pleased to discuss the issues in this publication with you, in the context of your particular circumstances. For permission to republish this or any other publication, contact Janelle Weed. Skip to main content. About Us Careers Offices. This article examines the privacy implications of the following aspects of the framework: New policies and procedures to ensure that the products or services offered or sold by banks and their intermediaries are appropriate for the person having regard to their circumstances, including their financial needs 2. A new complaint management process, which requires banks to: create and maintain a comprehensive record of all complaints for a period of seven years 3 ; and submit to the FCAC all complaint records received by a designated employee 4. Privacy law requirements The obligations imposed by the framework do not supersede either federal or provincial privacy laws. The complaint process As noted above, the new complaint management obligations imposed by the framework have several privacy implications. While complaint records do not present novel record retention issues, banks nonetheless should ensure that applicable policies define triggers that should prompt consideration of applying a litigation hold—for example, customer makes formal complaint to FCAC; the seven-year retention period for complaint records is appropriately socialized, in particular with those responsible for providing and implementing litigation hold notices; and the data is destroyed when the retention period expiries and any litigation holds are lifted Using duration to determine administrative monetary penalties Bill C amended the FCAC Act by adding the following two criteria when determining an administrative monetary penalty in the case of a violation: the duration of the violation the ability of the person who committed the violation to pay the penalty. Banks may wish to consider adopting measures such as: pseudonymization options to limit sensitivity of data kept long term safeguards such as offline storage. For example, complaint records may include call recordings from upset customers or new information about the customer's financial circumstances. The records may also contain proprietary or confidential information of the bank or third parties such as affiliates or resellers of bank products. Section The requirement to make a record of a complaint extends to anonymous complaints. Where the complainant refuses to provide their identity, banks are not required to take steps to identify the complainant. Segregation of data and appropriate tagging of proprietary and confidential information would also be valuable for complying with pending data portability requirements, as it would help with distinguishing information provided by the consumer and proprietary information of the bank or third parties. Appropriate destruction of records in accordance with regulatory requirements will help to mitigate a number of risks by limiting the amount of data on hand in the case of breach and avoiding the possibility that the record could be used to establish the duration of a violation for purposes of assessing a monetary penalty. The record submitted to the FCAC must include all of the information identified in section The FCAC Guideline on Complaint-Handling Procedures distinguishes between complaints handled by the non-designated first level of complaint handling and designated level level where complaints are escalated. To discuss these issues, please contact the author s. All rights reserved. Subscribe and stay informed. Stay in the know. Get the latest commentary, updates and insights for business from Torys.

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Buying hash Himos