BMO Privacy Code - Canada

We have strict policies and procedures governing how we deal with your Personal Information. Each and every one of our employees is responsible for respecting and protecting the Personal Information to which the employee has access.

Our Chief Privacy Officer oversees privacy governance including policy, dispute resolution, education, communications activities and reporting to our Board of Directors on privacy matters. Please go to  Contact Us  for information on how to reach our Chief Privacy Officer.

We collect and use your  Personal Information  to:   

• Verify your identity; 
• Ensure we have accurate information about you; 
• Understand your financial needs (including your eligibility for products and services you requested or accepted or were pre-approved for); 
• To manage our relationship; 
• Protect against fraud and manage other risks; 
• Communicate with you regarding products and services that may be of interest; 
• Understand our customers, including through analytics, and to develop and tailor our products and services; 
• Comply with legal or regulatory requirements, or as permitted by law; and 
• Respond to questions you may have. 

 If we use your Personal Information for a different purpose, we will identify that purpose. 

When you apply for or accept a new product or service, we obtain your consent to collect, use or disclose your  Personal Information for purposes set out in Principle 2, Identifying Purpose.  

In some cases, if you are a director, officer, trustee, guardian, attorney for property, authorized signatory, authorized representative or other decision-maker for, or an owner or beneficiary (directly or indirectly) of, one of our customers, we may obtain your consent to collect, use or disclose your Personal Information through our customer. If you are a business customer, your authorized representatives may have access to your relevant Personal Information for the purpose of operating a business account.  

You can manage your  Direct Marketing preferences. You may also control your preferences of having account specific information shared among other members of BMO Financial Group. If you want to change these privacy preferences, please  Contact Us.

If you opt out, you will still continue to receive information that we are required by law to provide to you, service messages we need to send to you, and information about your current products and services.  Please note that you cannot withdraw your consent to the collection, use and disclosure of your Personal Information if:   

• we are legally required to collect, use or disclose your Personal Information, or 
• it relates to a credit product we have granted to you where we are required to collect and exchange your Personal Information on an ongoing basis with credit bureaus, credit insurers and other lenders, or 
• it is being shared between two or more members of  BMO Financial Group  that are providing you with a jointly offered product or service.   

Withdrawing your consent in certain situations may also mean that we may not be able to provide you with the products or services you have or requested. 

We only collect the Personal Information that we determine we need for purposes set out in Principle 2, Identifying Purpose. For example, we may collect:

• Contact Information including address, telephone number, mobile device number and email address.
• Social Insurance Number (SIN) as required in order to comply with tax requirements. We may also use your SIN to help us differentiate you from customers who may have the same or similar name. With your consent, we may use your SIN to ensure an accurate match between your Personal Information and credit bureau information.
• Financial Information to ensure that the advice and/or products we provide you are appropriate for you and the investments you purchase are suitable for you.
• Device Information such as information about your operating system, browser, software applications, IP address, geolocation, security status and other device information in order to improve your experience, to protect against fraud and manage risk. For more information, go to our Digital Privacy Policy.
• Website Use Information such as browsing behavior on BMOB M O sites and links, location you select, form data and downloads as well as other data gathered from the use of web tools to better understand your interests and needs so that we can serve you better. You may have the ability to limit this collection through your browser settings or by managing your preferences on BMO websites. For more information, go to our Digital Privacy Policy.
• Employment Information, including information about your previous and current employers, to confirm your eligibility for certain products and services.
• Health Information as required for some of our insurance products.

We may collect Personal Information about you, from you, and from third parties or sources that are available to the public to satisfy legal requirements or regulatory expectations or to manage our risk and to help us understand our customers in order to develop and tailor our product and service offerings.

You can choose not to provide us with certain information in some situations, but if you make this choice, we may not be able to provide you with the product, service, or information you have or requested.

We may monitor or record our incoming or outgoing telephone calls with you to ensure accuracy, security, service quality, for training purposes, to protect you against fraud, and to establish a record. We will tell you when we are recording a call and if you do not wish to have your call recorded you have other options to conduct business with us such as at one of our branches or ABMs, online, or by contacting us in writing.

With your consent, we may also use Voice ID technology for authentication purposes. To verify your identity, Voice ID creates and stores a voiceprint, a digital representation of your voice that’s made up of over 100 different identifying characteristics. Thereafter, each time you call us, Voice ID matches your voice to your voiceprint to make sure it’s you. Using Voice ID to verify your identity is optional. If you prefer to enter your password or answer authentication questions each time you call, you may continue to do so. If you want to change your preferences, go to Contact Us. 

We may use video surveillance in and around our branches, ABMs and other locations for the safety of our customers and employees, and to protect against theft, property damage and fraud.

We will only use or disclose your  Personal Information  for the purpose(s) it was collected and as otherwise identified in this Privacy Code.  

We do not sell the names or other Personal Information of our customers. We do not disclose the names or other Personal Information of our customers to companies outside of  BMO Financial Group, for their own use, without consent unless required or permitted by law.  

We may disclose your Personal Information:   

• Within  BMO Financial Group, including locations outside of your province or Canada where we do business, for the purposes described in Principle 2 Identifying Purpose. This sharing allows us to better serve you, open a new account faster, and to avoid offering you a product or service that you already have. This sharing also allows us to meet our legal and regulatory obligations and prevent fraud. 
• To businesses we buy or sell or when we sell or securitize our assets. We may also transfer Personal Information as part of a corporate reorganization or other change in corporate control. 
• To BMO's affiliates or other companies to provide services on our behalf such as data processing, account administration, analytics and marketing. These companies will only be given the Personal Information needed to perform those services and we do not authorize them to use or disclose Personal Information for their own purposes, including marketing. We have contracts in place holding these companies to the same standards of confidentiality by which we are governed. 
• To an authorized party acting for you or at your request. 
• To a merchant, a payment system, a payment card network, or a telecommunications provider. 
• To companies or affiliates where we offer loyalty or reward programs, for the purposes of the program, include analyzing and developing new benefits. 
• To a person who applies for or holds an account jointly with you who will have access to all of the account history and transaction details. 
• To third parties including legal or regulatory authorities in cases of suspected criminal activity or contravention of law, for the detection and prevention of fraud, or when required to satisfy the legal or regulatory requirements of governments, regulatory authorities or other self-regulatory organizations, or to comply with a court order or for the protection or recovery of our assets 

In some cases, these parties may be located outside of your province or Canada and your Personal Information may be accessed or processed in those jurisdictions. These parties may be required to disclose information to courts, government authorities, regulators or law enforcement in accordance with applicable law in that country. 

We have policies in place that govern the retention of your  Personal Information  so it will be kept only for as long as reasonably necessary to fulfill its intended purpose or to satisfy legal requirements. These requirements also apply to third parties who work with us. 

To determine the appropriate retention period, we consider different criteria, including the purposes for which we process your Personal Information, the need for maintaining your Personal Information to provide you with products and services, and all applicable legal and regulatory requirements. We may retain Personal Information beyond our designated retention periods due to regulatory requirements or in response to a legal matter.

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 records, or your Personal Information changes, please make these changes through digital banking or notify the branch or office where you do business immediately so that we can make the necessary changes. Failure to notify us of changes to your Personal Information may negatively impact the way we communicate with, or provide services to you. Where appropriate, we will advise others of any material amendments to your Personal Information that we may have shared with them. If we do not agree to make the changes that you request, you may challenge our decision as described in  Contact Us.

We use physical, electronic and procedural safeguards to protect against unauthorized use, access, modification, destruction, disclosure, loss or theft of your  Personal Information  in our custody or control.

We have agreements and controls in place with credit bureaus, credit insurers, other lenders and third party service providers requiring that any information we provide to them must be safeguarded and used only for the purpose of providing the service we have requested the company to perform.

To learn more about how we protect your Personal Information, visit  bmo.com/security.

Please go to  Contact Us  for information on how to get answers to any questions you may have about our Privacy Code.

You can access some of the Personal Information  we hold about you through your account-opening documents, account statements or by signing into digital banking.

You can also correct your Personal Information via digital banking.You can also make a request to access and correct the  Personal Information  we hold about you. If you are a resident of Quebec, you can also make a data portability request. You can make your request at the branch or office where you do business. Depending on the extent of your request, we may require you to provide it to us in writing and we’llassist you with the process. We will need specific information from you to process your request. Depending on the nature of your request, we may charge you a fee and we will advise you of any fee prior to proceeding with your request. If we are unable to provide some of the Personal Information we hold about you, we will tell you why.

If you have any questions regarding decisions made about you, including  Automated Decisions, we will tell you the reasons for those decisions. In order to provide you with decisions in real time we may use tools to automate the processing of your Personal Information, for example, whether to approve or decline your loan. You have the right to request the following additional information on Automated Decisions: (i) the personal information used to render the decision, (ii) the reasons and principal factors and parameters that led to the decision, and (iii) the right to have your relevant information modified. You also have the right to submit an observation about an automated decision we made about you. Please make the request in writing to the branch or office where you do business or  Contact Us.