Royal Canadian Mint

RCMPA Program Privacy Policy

Introduction

The Royal Canadian Mint Prestige Account program (hereinafter referred to as the “RCMPA Program”) is an easy, convenient and safe way to hold unallocated precious metals within the Royal Canadian Mint's high security facility in Ottawa, Canada. The RCMPA Program allows customers to buy high purity precious metals from authorized RCMPA Dealers who have unallocated precious metal pool accounts at the Mint. Canada’s Proceeds of Crime Money Laundering and Terrorist Financing Act and the associated guidelines set for by the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC), require that we collect certain elements of personal information to meet our “Know Your Customer” (KYC) legislative obligations and industry best practice standards.  In an effort to both meet the legislative requirements and to determine your eligibility for the program, the Mint and the authorized RCMPA Dealers collect certain elements of personal information during the RCMPA Program application process.  A list of the information required during the application has been included for ease of reference in Appendix 1 of this policy, "Documentation and Personal Information Required to Open a Royal Canadian Mint Prestige Account”.

This Privacy Policy details how the Mint collects, uses, shares and protects that personal information within the context of the RCMPA Program. It complements the Mint’s general Privacy Policy, which can be read at http://www.mint.ca.

Application of RCMPA Program Privacy Policy

The Mint’s RCMPA Program Privacy Policy only applies to the activities of the Mint as they relate to the RCMPA Program. The authorized RCMPA Dealers are separate entities from the Mint; therefore, this Policy does not extend to them. Instead, each authorized RCMPA Dealer is responsible for issuing its own privacy policy, which has to reflect the laws of the jurisdictions in which it is located and operates. For information about the privacy policy of each authorized RCMPA Dealer please contact that organization directly.

Legal Requirements

The Mint is subject to the Privacy Act (http://laws.justice.gc.ca/eng/P-21/index.html), which is the federal Act that governs the collection, use, protection, disclosure/sharing, retention and disposition of personal information by federal government institutions. Generally, this means that we can only:

·            collect the personal information about you that we absolutely need to serve you well and to meet our legal obligations;

·            use that personal information only for the purposes that you have authorized and those by law;

·            disclose your personal information under the following circumstances:

·            to the authorized RCMPA Dealers, as necessary to serve you well;

·            with your fully informed and explicit consent; and

·            to meet our legal obligations, as described later in this document.

Collection of Personal Information

The document entitled “Royal Canadian Mint Prestige Account Program, Terms and Conditions” provides the detailed list of the elements of personal information which you are required to provide in order to apply for a Royal Canadian Mint Prestige Account. This list is reproduced in Appendix 1 of this Privacy Policy whereas the table at Appendix 2 summarizes the reasons for the collection of each separate element of personal information. Failure to provide any of the above documents may cause a delay in the approval process or result in rejection of your application.

Once the Royal Canadian Mint Prestige Account has been opened, additional information will be collected when you update your Account file as well as at the time of each transaction that you initiate. Only that personal information which is absolutely necessary for the processing of your transactions will be collected, at the time of each transaction.

The other circumstances that involve the collection of your personal information include:

·            exchange of correspondence and general inquiries that you may submit to us;

·            when you discuss your RCMPA transactions with us or when you express your needs and concerns with one of our employees or with an authorized RCMPA Dealer;

·            when you voluntarily complete surveys and other questionnaires in person, by phone or on our web site; and

·            any other circumstances where you choose to share your personal information with one of our employees or authorized RCMPA Dealer.

Depending upon the type of activity or interaction that we have with you, your personal information may be collected by telephone, regular mail, email or via our secure website or that of your authorized RCMPA Dealer.

We periodically analyze the emails that we receive to determine trends in information requested, and to revise our website as necessary to help customers obtain what they are looking for faster. Your email address is never used during this analysis and we will not contact you without your permission.

Transactions Conducted via the Mint’s Internet Website

The conduct of your RCMPA Program related transactions via our website may result in the collection of information that identifies you or the computer or the connection that you are using for that purpose. We suggest that you review the Mint’s Website Privacy Policy for detailed information about the processes that we use for that collection at http://www.mint.ca (click on ‘Privacy’ which is found at the bottom of each page).

Use of Your Personal Information

We only use your personal information for the following purposes:

·            for the purposes for which you provide it to us at the time of the opening of your Royal Canadian Mint Prestige Account and, subsequently, to update your account file and process your transactions;

·            in an anonymous fashion, to:

·            manage, develop and improve our business and operations; and

·            develop services and promotional offers that meet your needs.

In all other circumstances, we will always seek your express consent prior to using your personal information for a purpose other than those listed above.

Disclosure of Your Personal Information

We do not sell your personal information, and we only disclose whatever information is necessary to third parties under the following circumstances:

·            to validate your identity and your eligibility for the RCMPA Program with the organizations that we contact for that purpose;

·            to confirm your qualification for the RCMPA Program with the authorized dealer of your choice, as part of the initial opening of your Royal Canadian Mint Prestige Account;

·            to inform the authorized RCMPA Dealer of your choice of the changes made to your Account file, each time you update your Account information with us;

·            to the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) in accordance with the requirements of Canada’s Proceeds of Crime (Money Laundering) and Terrorist Financing Act and supporting Guidelines;

·            as required by other Acts of Canada’s Parliament, including Canada’s Income Tax Act; and

·            at your specific request or with your fully informed consent, depending on the circumstances that may require occasional disclosure.

In all other circumstances, we will always seek your express consent prior to disclosing your personal information to a party other than those listed above.

Accuracy of Your Personal Information

The Mint exercises diligence in assuring that the personal information under its control remains accurate, up-to-date and complete; however, it is your responsibility to inform the Mint of any changes to your information and to any error that you may notice when reviewing your information or conducting transactions.

Protection of Your Personal information

We recognize that the personal information that you share with us is very personal and sensitive, and for this reason, we apply the highest standards possible in regard to its protection. Access to your personal information is limited to those company employees who have a strict need to know, and we implement sound security measures to protect it from unauthorized access, use, modification and destruction.

That said, you are entirely responsible for the protection of your personal information that is physically or electronically in your possession or under your control, and the Mint takes no responsibility for any security or privacy breach that may occur while the personal information is outside its control.

Thus it is of the utmost importance that you exercise caution when you access your Royal Canadian Mint Prestige Account information or when you conduct RCMPA Program-related transactions. More specifically, you should take adequate precautions to protect your identification numbers and passwords as well as all other personal information from unauthorized access, use, modification and destruction. It is also your responsibility to inform the Mint and your authorized RCMPA Dealer immediately of any real or suspected breach of your privacy so that measures can be taken to restrict access to your account information.

Retention and Disposition of the Personal Information

The description of the Personal Information Bank for the RCMPA Program, currently under development, specifies the retention period for the personal information that will be collected for the purpose of the Program, which will be five years to meet the requirements of FINTRAC.

Due to legal requirements, it is not possible for the Mint to destroy or otherwise dispose of your personal information before the end of the scheduled retention period.

Modifications to this Privacy Policy

The Mint reserves the right to change this privacy policy at any time, without notice or liability to you or any other person, by posting a new privacy policy on the Mint’s website.  Our collection, use and disclosure of your personal information will be governed by the version of the privacy policy that is posted and in effect at that time.

Right of Access and Right to Request Correction

In accordance with the Privacy Act you have the right to request access to all the personal information that the Mint keeps about you as well as the right to request the correction of that personal information. You can do so by completing the Personal Information Request Form (Personal Information Request Form (TBC/CTC 350-58) (RTF)) and send it to:

                                                      Access to Information and Privacy Coordinator
                                                      320 Sussex Drive
                                                      Ottawa, Ontario   K1A 0G8

The Mint has thirty days to respond in writing to your request, and there are no fees for requesting access to your personal information.

The Privacy Act establishes a complaint mechanism whereby individuals can ask the Privacy Commissioner of Canada to investigate any complaint that they may have regarding alleged non-compliance, by a federal government institution, with any of its provisions.  Should you wish to avail yourself of this right, you may contact the Privacy Commissioner of Canada at the following address:

                                                    The Privacy Commissioner of Canada
                                                    Tower “B”, Third Floor, Place de Ville
                                                    112 Kent Street, Ottawa, Ontario K1A 1H3
                                                    Telephone:     1-800-282-1376
                                                                                (613) 947-1698
                                                    Facsimile:        613-990-4665
                                                    Website:          http://priv.gc.ca

Do You Have Questions?

We invite you to contact us for any questions related to this RCMPA Program Privacy Policy or regarding our privacy protection program by writing to us at the address indicated in the previous section.




APPENDIX 1

Documentation and Personal Information
Required to Open a Royal Canadian Mint Prestige Account

Individual Customers:

Individual Customers enrolling in the Royal Canadian Mint Prestige Account (RCMPA) program must submit the following documentation to the authorized RCMPA Dealer:

1.             a completed RCMPA Know Your Customer Registration Form for an Individual Account;

2.             legible photocopies of two pieces of valid government issued identification documents (ID), one of which must include a clear picture:

§  passport

§  driver’s license

§  birth certificate

§  Permanent Resident Card

For Canadian Residents only (this excludes those with Canadian citizenship from this requirement):

§  Record of Landing

§  Old Age Security card

§  Certificate of Indian Status

§  Health Care card or Medicare card

3.             a signed copy of the Agreement between the authorized RCMPA Dealer and the Customer for the RCMPA Program;

4.             a signed copy of the RCMPA Unallocated Storage Agreement between the Mint and the Customer.


APPENDIX 2

Reasons for the Collection of Personal Information at the
Time of the Opening of a Royal Canadian Mint Prestige Account

 

Elements of Personal Information Collected

Sub-elements of Personal Information

Reasons for the Collection

1.

Name

First name and last name

To serve as the main identifier. Also required by FINTRAC Guideline 6I.

2.

Occupation

Type of business

Information pertaining to the applicant’s occupation information is used to complete a risk assessment.

3.

Company Name

 

For transactions that are conducted on behalf of a company. Also required by FINTRAC Guideline 6I.

4.

Address

Street name, street number, city, province/state, postal or zip code, P.O. Box

To contact the Customer and mail transaction related documentation.

5.

Date of birth

 

To distinguish individuals who may have the same name. Also required by FINTRAC Guideline 6I.

6.

Country of (permanent) residence

 

Required by FINTRAC Guideline 6I.

7.

Telephone and fax numbers

Home / business and extension, fax number

To contact the Customer concerning transactions.

8.

E-mail address

 

To contact the Customer.

9.

Identification – two pieces of valid government issued photo IDs

Only one piece of identification from each category:  national identity card issued by a federal government / birth certificate, or passport, or citizenship certificate, or permanent resident card; driver’s license; Health Care card or Medicare card.

For each of the two IDs, the following information is required:  ID type (driver’s license, passport, Health Care card, etc.); country of issue; ID number, date of issue, expiry date

To ascertain the identity of the customer, the production of Health Care ID cards is subject to the privacy legislation of the jurisdiction that issued the card.

10.

Primary banking institution

Name and location

For the conduct of financial transactions. Also required by FINTRAC Guideline 6I.