Collection of Personal Information

1. Manner of Collection: ISC will, where reasonably practicable, collect personal information about an individual from the individual affected, except where the law provides otherwise for lawful collection from other sources.
2. Collect Only What is Needed: ISC will attempt to limit collection of personal information to that which is necessary for the proper functioning of its business or required to deliver a product or service to the individual in accordance with the stated purposes as they relate to the programs or activities of ISC
3. What information does ISC Collect? ISC may, from time to time, collect financial and other personal information about you. ISC may collect this information when you apply for an account or establish any other relationship with ISC during the course of our business dealings with you. This information may be obtained from your account application, references you provide, our records, credit reporting agencies, other financial institutions, other service providers ISC selects to provide services to you and from other suppliers of services of or benefits made available to you. With your consent, ISC and its affiliated companies may collect personal information from you in person, over the telephone, by mail, through the Internet or on applications, whether in writing, verbally or electronically. 
4. Your Choices: You may choose to not provide us with any of your personal information; however, if you make this choice, we may not be able to provide you with the product, service or information that you requested, or that could be offered to you.

Use of Personal Information

1. Manner of Use: ISC shall use personal information under its control only for the purpose for which that information was obtained or collected, or for a use that is consistent with that purpose.
2. How We Use Your Information: ISC may use your personal information for the purposes listed here. 
3. Statistics: We may also use the information you provide to us for analytical purposes, to generate statistics and aggregate reports for internal use. These statistics and aggregate reports will not contain any personal identifiable information. Your identity will be kept anonymous. We use statistics gathered at an aggregated level to determine usage patterns and help us improve our products and services. 
4. Future Needs: We may also use this personal information to assess your future needs and to offer products and services that may better meet those needs. Personal information may also be used for other purposes, subject to obtaining your consent for such use.  

Your Consent

1. Consent: ISC will collect, use and disclose your personal information as described in this policy with your consent, where applicable, except where otherwise permitted or required by law.
2. Express and Implied: Your consent may be obtained in various ways. We may obtain your express consent or we may determine that consent has been implied by the circumstances; for instance, you choose to continue with a service when given the opportunity to opt out. Where reasonably possible, we will attempt to get your consent directly from you. Express consent could be in writing (for example, signed consent, email or application form), or verbally, in person or over the telephone. Your consent to our collecting, using and disclosing your personal information will be implied in cases where: the purpose of the collection, use or disclosure of the information is reasonably apparent to you; a reasonable person would expect the information to be collected, used or disclosed for those purposes; and where it is reasonable to assume that you have consented. 
3. Choice: Providing us with your personal information is always your choice. When you request services from us, we ask that you provide information that enables us to respond to your request. In doing so, you consent to our collection, use and disclosure to appropriate third parties of such personal information for the purposes described in this policy. You also authorize us to use and retain this personal information for as long as it may be required for the purposes described. Your consent remains valid even after our relationship with you has ended. ISC will assume that unless we hear otherwise from you, that you wish ISC to continue to collect, use, and disclose your personal information in accordance with this Privacy Policy. You may provide us with written notice that such consent is limited or withdrawn, subject to legal, contractual or practical restrictions and reasonable notice. You may choose to have your name removed from our telephone, mail or e-marketing lists. By withdrawing your consent, or not providing it in the first place, you may limit or even prevent us from being able to provide you with the products or services desired. 
4. Exceptions: In certain circumstances, there are legal exceptions where we do not need to obtain consent or explain the purpose for collection, use or disclosure of personal information. These are set out in the Personal Information Protection and Electronic Documents Act. For example, this exception would apply where there is an emergency that threatens the life, health or security of an individual, or where we must comply with a court order.

Disclosure of Personal Information

1. Confidentiality: We take the issue of safeguarding your privacy very seriously. In fact, it is integral to the way we conduct our operations and provide you with service every day and at every level of our business. Our Privacy Policy describes the measures taken to protect your personal information and explains when this information may be shared with other parties.
   
   Our employees are required to follow procedures with respect to maintaining the confidentiality of our customers’ personal information.



2. Security: ISC undertakes appropriate security measures to protect against inadvertent disclosure of personal information on its computer systems, devices, files and records. Additionally, we maintain physical, electronic and procedural safeguards to protect the information. This includes performing ongoing evaluations of our systems containing customer information and making changes when appropriate.
   
   ISC protects the security and confidentiality of personal information with safeguards appropriate to the sensitivity of the information.
    
3. Sharing Information: Your personal information is not sold or rented to any parties outside of ISC, without your consent. We do share this information with the companies we select as our business partners, and who supply services to us. ISC’s policy is not to disclose personal information in its possession or under its control, except in the following types of circumstances:
   • Where the individual affected, or a person ISC reasonably believes to be an agent acting on the individual’s behalf, gives consent
   • Where the law allows for the disclosure of such personal information without the consent of the individual affected
   • In order to administer the delivery of our products and services, we may share your personal information with various entities, including credit reporting agencies, other financial institutions, provincial and municipal governments (for the collection of a debt) and data storage and output providers
   • We may share your personal information with organizations or agencies collaborating with ISC to provide products or services, and/or
   • Where request is made by entities legally empowered to request and obtain the information.
      
     ISC may disclose personal information if legally required to do so or if necessary to comply with legal process served on ISC, to protect ISC’s rights or property or to take emergency action to protect the personal safety of the public. In providing our services, we may need to disclose the personal information we collect to affiliates, successors and other service providers or agents who perform various functions for us; however, we require them to honour our privacy principles in the handling of personal information and to use the information disclosed only for the purposes for which it was collected. In certain circumstances, we may be required to provide personal information to third parties for legal or regulatory purposes.
      
     Personal information is not, without consent, used or disclosed to a third party for any purpose other than that for which it was collected, or consistent with that purpose, unless its use or disclosure is required or allowed by law. This may include use or disclosure in order to protect, promote or defend the company’s interest in civil proceedings or in proceedings involving criminal activity, fraud or misrepresentation.

Disposition of Personal Information

1. Destruction: When personal information is no longer required for the purpose for which it was collected or its retention is no longer required or allowed by law, ISC will routinely destroy that information, using an appropriate secure method, in accordance with approved retention and destruction policies*. Record retention schedules are established to meet these legal requirements*.
   
   The retention schedules are timetables which determine how long records are required to be retained in order to meet their physical, legal and operational requirements. When these requirements are met, the information no longer needed is destroyed. 



2. Retention Periods: ISC retains customer information only as long as it is needed for the products and services you are using, to offer you new products and services, or to meet any physical, legal or operational requirements.