Last Updated: March 13, 2020
The Bank of New York Mellon Corporation and its affiliates (collectively referred to as "BNY Mellon", "we", "us") take their data protection and privacy responsibilities seriously. This privacy notice (“Privacy Notice”) explains how we collect, use and share personal information in the course of conducting our business activities in Canada, including:
The BNY Mellon entity responsible for your personal information will be the member of BNY Mellon that originally collects information from or about you. This will be explained in separate privacy notices made available when your personal information is first collected by that BNY Mellon entity, for example where you or the business you work for engage us to provide a service.
We may amend this notice from time to time to keep it up to date with legal requirements and the way we operate our business. Please regularly check these pages for the latest version of this notice. If we make significant changes to this privacy notice, we will seek to inform you by notice on our website or email ("Notice of Change").
In this section you can find out more about:
BNY Mellon collects personal information about you if you:
BNY Mellon will collect your business contact information if you:
Personal Information we collect will fall within one of the below categories:
In general, BNY Mellon uses personal information to:
We will collect the personal information we use for the above purposes from one or more of the below sources:
We will only collect, use and share your personal information where we are satisfied that we have your express or implied consent, or an exception applies under applicable law to our collection, use or disclosure of your personal information without your consent. For example:
By providing your personal information to BNY Mellon, you consent to BNY Mellon’s collection, use and sharing of your personal information as described in this Privacy Statement.
Consent can be express or implied. Express consent can be verbal or written. For example, an application for registration of a retirement savings plan may contain a written consent for our use of your information to carry out the role of a retirement savings plan trustee. Or you might consent to release the information over the phone. Consent is implied when we can reasonably conclude that you have given consent by an action you have taken or not taken, or where the context reasonably requires that we have and use information to carry out what you have asked us to do.
You can withdraw your consent any time after you’ve given it to us by contacting our Chief Privacy Officer, provided there are no legal or contractual requirements to prevent this and you have provided us with reasonable notice. If you do not consent to certain uses of information or if you withdraw your consent, we may not be able to provide a particular service. If so, we’ll explain the situation to you to help you with your decision.
BNY Mellon may be required or permitted under statute or regulation to collect, use or disclose personal information without your consent, for example to comply with a court order, to comply with local, federal or foreign regulations or a legally permitted inquiry by a Canadian or foreign government agency, or to collect a debt owed to us.
When someone hires BNY Mellon to process your information for them, you may have provided them with express or implied consent to share that information with BNY Mellon so that BNY Mellon can carry out the information processing. BNY Mellon may process your information on behalf of other entities to whom you have provided your personal information. We will process the information only as necessary to provide the contracted services to those other entities and will safeguard and handle your information in accordance with this Privacy Statement. Once it is shared with us, we will safeguard it and handle it in accordance with this Privacy Statement.
In this section you can find out more about how we share personal information:
We share your information in the manner and for the purposes described below:
In this section you can find out more about:
We, and third party service providers acting on our behalf, use session and persistent Cookies to:
The third party service providers mentioned above use any personal information they collect on our behalf solely for the purpose of providing the contracted service to us. They have also agreed to confidentiality restrictions.
We may use aggregated usage data to track trends and analyse patterns on our websites. If you register to enter an area of our websites, the website will recognize who you are and collect all information that you submit (including subscription to emails, etc.). Information collected about you from this website may be associated with other identifying information that we have about you.
Most browsers are initially set to accept Cookies. However, you have the ability to change your browser settings. It may also be possible to configure your browser settings to enable acceptance of specific Cookies or to notify you each time a new Cookie is about to be stored on your device enabling you to decide whether to accept or reject the Cookie. You can also disable Cookies by configuring your browser setting to reject Cookies. Please refer to the help section of your browser for instructions on disabling Cookies. For more information about Cookies, how they work, why they are so useful and how to disable them, you can visit www.allaboutcookies.org.
If you do not wish to accept Cookies from our Website, please either disable them or refrain from using our website. If Cookies are disabled, it may mean that you experience reduced functionality or will be prevented from using all or part of our website.
In this section you can find out more about
We may use personal information to let you know about BNY Mellon products and services that we believe will be of interest to you. We may contact you by email, post, or telephone or through other communication channels that we think you may find helpful. In all cases, we will respect your preferences for how you would like us to manage marketing activity with you.
To protect your privacy rights and ensure you have control over how we manage marketing with you:
We recommend you routinely review the privacy notices and preference settings that are available to you on social media platforms, as well as your preferences within your BNY Mellon account.
In this section you can find out more about:
BNY Mellon operates on a global basis. Accordingly, your personal information may be transferred and stored in countries outside of your jurisdiction (such as the USA and India), that are subject to different standards of data protection. Where BNY Mellon transfers personal information internally within BNY Mellon or to any third party between different jurisdictions, for the purposes outlined in this document, it will take appropriate steps to ensure that transfers are in accordance with applicable law and carefully managed to protect your privacy rights and interests.
To this end:
We have implemented and maintain a comprehensive information security program with written policies and procedures designed to protect the confidentiality and integrity of personal information. The information security program contains administrative, technical and physical safeguards, appropriate to the type of information concerned, designed to: (i) maintain the security and confidentiality of such information; (ii) protect against any anticipated threats or hazards to the security or integrity of such information; (iii) protect against unauthorized access to or use of such information that could result in substantial harm, and (iv) ensure appropriate disposal of such information. The security of your personal information also depends in part on the security of the devices you use to communicate with us, the security you use to protect user IDs and passwords, and the security provided by your internet service providers.
We will store your personal information for as long as is reasonably necessary for the purposes for which it was collected, as explained in this notice. In some circumstances we may store your personal information for longer periods of time, for instance where we are required to do so in accordance with legal, regulatory, tax, accounting, or necessary technical requirements.
In specific circumstances we may store your personal information for longer periods of time so that we have an accurate record of your dealings with us in the event of any complaints or challenges, or if we reasonably believe there is a prospect of litigation relating to your personal information or dealings.
Subject to certain exemptions, and in some cases dependent upon the processing activity we are undertaking, you have certain rights in relation to your personal information. Click on the links below to learn more about each right you may have:
Right to access and correct personal information
Where we have relied on your consent to process particular information and you have provided us with your consent to process the information, you have the right to withdraw such consent at any time. You can do this by contacting the Global Privacy Office or the Line of Business that you have engaged.
If you consider that the processing of your personal information infringes applicable law, you have the right to lodge a complaint with the Office of the Privacy Commissioner of Canada. If you have any questions, concerns or complaints regarding our compliance with this notice and applicable data protection laws, or if you wish to exercise your rights, we encourage you to first contact our Global Privacy Office. We will investigate and attempt to resolve complaints and disputes and will make every reasonable effort to honour your wish to exercise your rights as quickly as possible and, in any event, within the timescales provided by data protection laws.
The Chief Privacy Officer can be contacted in the following ways:
By email: firstname.lastname@example.org
The Global Privacy Office
160 Queen Victoria Street
London EC4V 4LA