The Canada Infrastructure Bank (“CIB” or “we”) is a crown corporation focused on financing and supporting the development of revenue-generating infrastructure projects that serve the public interest. Formed in 2017, the CIB has a mandate to attract and co-invest with the private sector and institutional investors, with particular focus on areas such as public transit, trade and transportation, green infrastructure and broadband.
The CIB is committed to protecting your personal information and complying with its obligations under the Privacy Act, the Privacy Regulations and applicable policies, directives and guidelines of the Treasury Board of Canada Secretariat (“Treasury Board”). In the course of our daily activities, the CIB may gather personal information from individuals, in order to provide services, make decisions and support its business operations, programs and activities.
“Personal Information” means information about an identified or identifiable individual, including name, address, email address, signature, an opinion, and other information relating to an individual.
C. Guiding Principles
The CIB is responsible for the protection of personal information under its control, both within the organization and when business activities are carried out by a third party on behalf of the CIB. The CIB’s ability to protect personal information requires ethical and responsible behaviour from our employees and applicable third parties, in accordance with the 10 following guiding principles:
- Accountability – The CIB is responsible for the personal information under its control. This includes the personal information of employees, business partners, as well as proponents of, or private sector investors or institutional investors in, infrastructure projects.
- Identifying purposes – The CIB identifies the purpose for collecting personal information before or at the time of collection.
- Limiting collection – The CIB will only collect personal information for the purpose that was identified. Personal information is collected under the authority of the Privacy Act, the Financial Administration Act and the Canada Infrastructure Bank Act.
- Limiting use, disclosure and retention – The CIB requests additional consent if it wants to use personal information for any new or additional purpose. CIB retains personal information only as long as necessary.
- Accuracy – Personal information is complete, accurate and up to date. This also applies to personal information provided to third parties.
- Safeguards – The CIB safeguards personal information with the level of protection appropriate to the sensitivity of the information. Employees are aware that confidentiality of personal information must be maintained.
- Openness – The CIB is open about its policies and practices for the management of personal information.
- Individual access – Subject to the exceptions in the Privacy Act, individuals have a right to access to their personal information collected by the CIB. This includes the ability to correct or amend any personal information that is not accurate.
- Providing recourse – Individuals can challenge the CIB’s compliance with the above principles.
D. Personal Information the CIB Collects and Uses
It is your choice to provide personal information to us. We only collect your personal information if it relates directly to the CIB’s operating programs or activities and for the following business purposes:
- when you visit our website;
- when you sign-up to receive communications from the CIB, such as current employment opportunities or other updates;
- when you apply for employment with the CIB, or otherwise provide us with a copy of your resume or other employment-related information;
- in connection with meetings, events, conferences or other activities organized or sponsored by the CIB;
- in connection with public consultations, opinion surveys, focus groups or feedback;
- in the course of the CIB’s project assessment process and due diligence activities;
- when you contact us with a comment or question or otherwise provide us with personal information.
The CIB’s collection and use of personal information is required for us to deliver our purpose and functions under the Canada Infrastructure Bank Act, and without which we would not be able to undertake certain activities. The CIB will not, without your consent, use your personal information under its control except for the purpose for which the information was obtained or compiled by the CIB or for a use consistent with that purpose.
We rely on you for the accuracy and completeness of the personal information you provide to the CIB. To ensure that there is no interruption in our communications with you, please contact us to advise of any changes in your information. The CIB’s contact information is set out in section I “Individual Rights: Providing Access and Accuracy of Personal Information” below.
- Visiting the CIB’s Website
We collect information about how you use our website. Even though this information is not linked to your identity, it can be in certain circumstances by using cookies. Therefore, we consider this data to be personal information as well when linked to your identity. The data we collect includes:
- the pages of our website viewed;
- the date and time when those pages were viewed;
- the region where you are connecting from (geolocation);
- how long each page was viewed; and
- the web browser used (Chrome, Edge, Firefox, Internet Explorer, Opera, etc.), browser settings and the type of device used (Mac or PC, mobile or desktop, etc.)
We may offer you the opportunity to engage with the CIB or its content on or through third-party social networking websites, plug-ins and applications. When you engage with us on or through third-party social networking websites, plug-ins and applications, you may allow us to have access to certain information associated with your social media account (e.g., name, username, email address, profile picture) to deliver content or as part of the operation of the website, plug-in or application.
Please see section H “the CIB Website and Online Privacy” below for more details about the Website’s collection, use and disclosure of personal information.
- Signing Up for CIB Communications
We may provide you with an opportunity to sign up to receive the CIB communications by email, such as news and updates. If you choose to sign up to receive the CIB communications, we may collect contact information such as your name and email. You can opt out of receiving these communications at any time by clicking on the unsubscribe link included in our email communications or by contacting us. Please note that if you unsubscribe, you may continue to receive certain non-marketing electronic communications from us.
- Applying for Employment at the CIB
In connection with a job application through the Careers section of the website, you may provide us with certain personal information about yourself (such as that contained in a resume, cover letter, transcript, or similar employment-related materials). We may also obtain employment-related information that you publicly post to social media websites such as LinkedIn. We use this information to evaluate your qualifications and suitability for the desired position and to process and respond to your application. We may also keep this information on file to consider you for future job opportunities or to otherwise meet legal or business requirements. We may also collect optional demographic information, which we use on an aggregated basis for the purpose of supporting our employment equity and diversity initiatives and better understand our applicants.
We may also obtain your consent to collect additional personal information in the course of reference check and background verifications processes.
- Meetings, Events, Conferences and Other Activities
From time to time, the CIB may organize or sponsor meetings for discussion, events, conferences or similar activities. In the course of these activities, we may collect personal information or participants such as name, email address and contact information in order to administer registration for the meeting, event, conference or other activity. For example, the CIB may collect the name, email address and contact information of individuals who register to attend the CIB’s Annual Public Meeting. This information is used to communicate with the participants registered for the meeting, event, conference or other activity.
- Public Consultations, Opinion Surveys, Focus Groups or Feedback
The CIB or its authorized survey, polling or other service providers may conduct public consultations, opinion surveys, focus groups or solicit public feedback in which individuals participate to support the fulfillment of our mandate. In the course of these activities, the CIB may obtain consent from participants to collect and use personal information such as first and last name, email address, telephone number, and mailing address for the purpose of conducting research and/or public engagement. Reports generated from such public consultation will be provided to the CIB in aggregate form and in a manner that does not identify any individual participant.
- The CIB’s Project Assessment and Investment Activities
To ensure that we do not, directly or indirectly, unknowingly transact business with companies and/or individuals who present legal, regulatory and reputational risks to the CIB, we use information to detect and assess potential legal, regulatory and reputational risks in transactions involving the CIB and various counterparties. For example, in the course of the CIB’s project assessment and investment activities, we may collect personal information about individuals, including, but not limited to, members of the boards of directors (or similar) or management, clients, suppliers, of entities in which the CIB is providing advisory services or considering an investment. The information we collect may include information obtained through background verifications and collected from third party databases in the context of detecting and assessing potential legal, regulatory and reputational risks in transactions involving the CIB and various counterparties. The third party databases contain profiles of companies and/or individuals who present risks for various reasons including being named on official lists, such as terrorism, corruption, or sanctions lists, being identified as politically exposed, being investigated, charged or convicted for illegal activities, being subject to allegations of wrongdoing or being subject to adverse media. Profiles may contain personal information such as name, alias, birth date, country of birth, country of residence, family members, known associates and past convictions.
We collect and use this information in order to conduct due diligence regarding potential investments, to manage our investments and to meet ‘know your client’ requirements, as required by applicable law. The CIB uses this information to comply with industry best practices and with Canadian laws including the Corruption of Foreign Public Officials Act, Proceeds of Crime (Money Laundering) and Terrorist Financing Act, United Nations Act, Special Economic Measures Act, Freezing Assets of Corrupt Foreign Officials Act and the Criminal Code of Canada.
- Questions, Comments and Complaints
If you contact us with a comment, question or complaint, you may be asked for information that identifies you (such as your name, address and a phone number) along with additional information we need to help us promptly answer your question or respond to your comment or complaint. We may also retain this information to assist you in the future.
E. Disclosing Personal Information within the CIB and to Third Parties
Except as set out herein, we will not disclose, trade, rent, sell or otherwise transfer personal information to third-party vendors, without your consent.
- The CIB Employees or Representatives
Our employees or representatives may have access to personal information on a need-to-know basis to perform their work related to the CIB’s activities, such as responding to your question or conducting know your client due diligence regarding potential investments. They will not view your personal information for any other reason.
- Service Providers
We may transfer (or otherwise make available) your personal information to third-party service providers (including cloud-based providers) such as IT services, web analytics, human resources, legal and accounting service providers. For example, we may use service providers to conduct background verifications, send our emails, to perform analytics and reporting, host our website and operate certain of its features. Our service providers are given the information they need to perform their designated functions, and we do not authorize them to use or disclose personal information for their own marketing or other purposes.
We carefully select our service providers to ensure that your privacy and personal information are protected and that the CIB’s requirements under the Privacy Act are fully respected. In all such cases, we will only transfer your personal information if we have put in place appropriate safeguards in respect of the transfer, for example, industry standard contractual clauses. You may obtain a copy of the safeguards we use in respect of such transfers by contacting us as indicated below.
Some of our service providers are based outside Canada and some in the United States. They may store or process your personal information on our behalf. For instance, under the USA Patriot Act, they might be forced to disclose your personal information to U.S. authorities if they suspect that it is linked to terrorism or money laundering activities.
- Legal Requirements
The CIB and our Canadian, U.S. and other service providers may provide your personal information in response to a search warrant or other legally valid inquiry or order (which may include lawful access by Canadian, U.S. or other foreign governmental or investigative authorities, courts or law enforcement agencies), to an organization in the case of a breach of an agreement or contravention of law, to detect, suppress or prevent fraud, or as otherwise required or permitted by applicable Canadian, U.S. or other law. We may also disclose personal information where necessary for the establishment, exercise or defence of legal claims or disputes, and to investigate or prevent actual or suspected loss or harm to persons or property.
F. How Long Is Your Personal Information Retained?
We retain personal information as long as we need it: (i) for business purposes to fulfill our mandate (ii) in connection with litigation, investigations or proceedings, and (iii) as required or permitted by applicable law. In accordance, with legal requirements and applicable guidelines, the CIB will destroy, erase, render anonymous, or otherwise dispose of Personal Information after such period of time.
G. Safeguarding Your Personal Information
The CIB takes its responsibility to protect the confidentiality and integrity of your personal information very seriously. We are committed to managing your personal information in accordance with applicable laws, industry standard security practices and with the CIB’s procedures in respect thereof.
We have developed and continue to enhance security procedures to safeguard and protect your personal information against loss, theft, unauthorized disclosure, copying, and unauthorized use or modification. We maintain appropriate safeguards and security procedures that reflect the types of documents, including electronic or paper records, organizational measures including security clearances and limiting access on a “need-to-know” basis, and technological measures such as the use of passwords and encryption.
While we have taken reasonable efforts to protect your personal information, we cannot guarantee the security of electronic systems or email and cannot be held responsible for unauthorized or unintended access that is beyond our control. We also cannot guarantee, warrant, or represent in any way that the personal information you provide will be transmitted securely or protected completely against interception, loss, misuse or alteration and we strongly recommend that you use appropriate discretion before transmitting sensitive personal information electronically.
H. The CIB Website and Online Privacy
This section provides additional information about how we manage the collection, use, disclosure, retention and access to your personal information online, including our website.
The CIB’s Website does not automatically gather any specific personal information from you, such as your name, phone number or email address. We would only obtain this type of information if you supply it by sending us an email or registering in a secure portion of the website. Please note that we may monitor any part of our website at any time and may take appropriate measures to curtail inappropriate use.
- Digital Markers (including cookies)
When you visit our website, we collect your IP (Internet protocol) address and other related information such as page requests, browser type, operating system and average time spent on our website. We collect these types of personal information using automated means, including digital markers (including cookies).
A digital marker is a resource created by a visited website’s Web server in order to remember certain pieces of information for the Web server to reference during the same or subsequent visit to the website. Examples of digital markers are “cookies” or HTML5 web storage.
Cookies are small files that are downloaded to the device you use to visit a website. They are generally used to help improve visitors’ experiences on the site, by, for instance, remembering preferences, log in information, or otherwise recognizing that they have visited the site previously (or are the same user during a single visit). They are also used to track what information is viewed on a site which helps website administrators ensure visitors find what they are looking for and make improvements to the site based on visitor behaviour. In some cases, they are used to collect and store information about specific users.
The CIB uses sessional and persistent digital markers on some portions of its website.
- A session cookie is a small text file placed on your browser by a web server. It acts as an identification card because it’s unique to the user but can only be read by the web server. Session cookies improve site navigation by maintaining information from page to page within these applications. Session cookies are deleted from your computer hard drive when you close your web browsing software.
- A persistent cookie is more permanent remains on your computer or other Internet-connected device for a certain period of time after you close your web browsing software, unless you delete them. A persistent cookie acts as your identification card and can only be read by the web server. At the CIB, we use persistent cookies to help us remember your official language preference and to better understand how you access, navigate and use our website.
By accessing the CIB’s website, you consent to the use of digital markers and agree to have their browser set to accept digital markers, including cookies.
You can choose to prevent cookies from being downloaded to your device by blocking some or all of them. However please note that if you do this you may not be able to use the full functionality of the site. You can also delete cookies that have already been downloaded.
- Web Analytics
Web analytics is the collection, analysis, measurement, and reporting of data about Web traffic and visits for purposes of understanding and optimizing Web usage. Information in digital markers may be used for the purpose of web analytics in order to remember your interactions with the CIB’s website.
The CIB uses Web analytics to improve its website. We collect the following types of information for Web analytics:
- the originating IP address
- the date and time of the request
- the type of browser used
- the page(s) visited
- the type of device used
- the frequency of visits
- the duration of visits
- the traffic sources.
The CIB uses Google Analytics and the information collected is disclosed to Google and external third-party service providers. The user’s IP address is anonymized prior to being stored on the service provider’s servers in order to help safeguard the user’s privacy. The information collected is depersonalized by truncating the last 4 digits of your IP address. You can learn more about Google Analytics cookies here. You can also choose to opt out of being tracked by Google Analytics.
Data collected for Web analytics purposes may be sent to, and stored in, locations outside of Canada, such as the United States and other countries where Google’s servers are located and may be subject to the governing legislation of those countries (for example the USA Patriot Act).
Information used for the purpose of Web analytics is collected pursuant to the Section 5 of the Canada Infrastructure Bank Act. Such data may be used for communications and information technology statistical purposes, audit, evaluation, research, planning and reporting.
- Third-Party Social Media
The CIB’s use of social media serves as an extension of our Web presence. Social media accounts are public and not hosted on the CIB servers. Users who decide to interact with CIB through these social media must read the conditions of service and privacy policies of these third-party providers of services and applications used in order to access them. The CIB has social media accounts with Twitter and LinkedIn.
- Links to Other Website
I. Individual Rights: Providing Access and Accuracy of Personal Information
The CIB is accountable to ensure that your personal information in our records is accurate and complete.
Please contact us if:
- You wish to access, update and/or correct inaccuracies in your personal information in our custody or control;
- You otherwise have a question or complaint about the manner in which we or our service providers manage your personal information.
You may contact us by email at email@example.com or by mail at the following address:
Canada Infrastructure Bank
Attn: Access to Information and Privacy Coordinator
150 King St. W., Suite 2309, P.O. Box 15
Toronto, ON M5H 1J9
Please include sufficient details to enable us to search for relevant records. Our Access to Information and Privacy Coordinator will respond to you as soon as possible. The CIB has 30 days to respond in writing to your personal information request, subject to a time extension in certain specific circumstances, and there are no fees for requesting access to your personal information.
The Privacy Act establishes a complaint mechanism whereby individuals can ask the Office of the Privacy Commissioner of Canada to investigate any concerns that they may have regarding alleged non-compliance by a federal government institution with any of the provisions of the Privacy Act.
If you are not satisfied with the CIB’s response to your privacy concern, you may wish to contact the Office of the Privacy Commissioner of Canada at the following address:
Office of the Privacy Commissioner of Canada
30 Victoria Street
Gatineau, Quebec K1A 1H3
Telephone: 1-800-282-1376 (toll free)
Facsimile: (819) 994-5424