Christin Milloy:

Rise up and seize equality

PC Financial Takes Partial Steps to Correct Transgender Discrimination, More Is Needed

Today I spoke again with Vicki, my contact at PC Financial. Together we followed up on the issues I raised in my last post President’s Choice Responds, which continued the story from my original post President’s Choice Financial Discriminates Against Transgender People.

First, she confirmed that she had received and processed my name change request via the “special exception” procedure in her department (I faxed her the declaration along with the Ontario legal name change certificate after hours last night).

We then moved on to discussing the outstanding issues with the name change policy, and how name change must be made more accessible to trans people who need to get their information changed quickly, due to the special circumstances and because of the risk of harm. Vicki confirmed she had read my most recent posting, and that she had found no inaccuracy.

First, I asked if she was able to give some more definition to what, other than situations with transgender customers, would constitute a “special exception” worthy of her department’s attention. She told me that she was hesitant to disclose the details, since it was an internal policy (which PC Financial understandably doesn’t want to see published online). She did, however, suggest that the reasons I had conjectured in my earlier blog post were reasonable examples of situations her department might handle. We then moved on to discussing what went wrong with how PC Financial handled my name change request.

As I explained in my first entry, on May 12th when I went to the Pavilion, one of the first things the woman on duty there advised me to do was to call in to PC Financial customer service, to clarify the policy and explain my situation. It was on this call that the front-line CSR placed me on hold so that he could consult with “a supervisor.” After some time on hold, the CSR returned and informed me that a) the supervisor had confirmed there was no accommodation for my situation, and b) the supervisor would not join on the call.

Today, Vicki explained to me that, according to PC, the real failure was at that point– She informed me that the supervisor with whom the CSR had consulted was, as it turns out, a member of Vicki’s team. She said that he had looked up my customer record, and seen in the computer that at some point in the past, I had presented a driver’s license as ID to PC Financial. This is true: I had a G1 (learner’s permit) when I was a teenager, and it expired 4 years ago. From this, though, that supervisor had erroneously concluded that since I had at one point had a driver’s license in the past, that I “must” be able to “just go in and get a new one,” and therefore that I still deserved to be subjected to PC’s onerous ID requirement. Vicki informed me that the appropriate policy response in that situation would have been for the supervisor to join in the call and speak to the customer directly. Vicki agreed with me when I pointed out that, had the supervisor joined the call, I could have quickly clarified the situation about why I could not immediately access new ID.

According to Vicki, had this conversation taken place, the supervisor would have been obligated to assist me according to their “special exceptions” policy, which as I have outlined in my previous post, probably exists as a defense against the problem that PC Financial’s name change policy represents indirect discrimination against trans people due to the disproportionate negative impact, a human rights violation according to Ontario’s Human Rights Commission.

Vicki indicated to me that, in her opinion, this was more of a “coaching” issue with that particular supervisor (and her team in general) rather than a “policy” issue that would require changes across the board. She told me that her interaction with me has shed light on how her department should respond to the needs of people in my situation, and as a result of the incident with the unhelpful supervisor, Vicki told me that new information has been distributed to everyone on her team, so that in the future, supervisors would know how to assist trans people who need help quickly– that is, if the trans person manages to get escalated to a supervisor by whichever front-line CSR they end up talking to. I thanked her for taking this initial step within her own team, but still I wondered, “What about front-line CSRs?”

Vicki told me that decisions affecting training of front-line CSRs are not a part of her department (or, not in her control). She did state that she had passed my concerns further up along the hierarchy of the company, but when I asked at what time she expected to hear feedback from them on the issue, she admitted that she did not expect to hear back about it at all. Nevertheless, we agreed I would contact her again to follow-up the issue at a later date.

I told Vicki, I think it’s great that trans people in my situation can, once escalated to her department, receive the help they need– now that the necessity of such help has been clarified to them via the information Vicki distributed.

I told her, in order for this issue to be completely resolved, future transgender customers who call into PC Financial must be able to access Vicki’s department. I asked her, how do front-line CSRs recognize what her department calls “exceptional situations,” in order to escalate them properly? Is there a policy in place which defines for a first-line CSR what constitutes “exceptional?”

As it turns out, the answer is yes and no (but really, no). She explained it to me as follows: When PC Financial CSRs are faced with any call which is, as Vicki puts it, “outside the norm significantly,” they “should know,” based on “common sense,” that it is something which should be raised to the attention of her department. She offered the thought “unfortunately, it is difficult to document common sense.”

So I asked her, if a trans person in my situation were to call in, today, needing help quickly and not yet having new Photo ID with the new name, did she think the CSR, via the “common sense” approach, would choose help the trans customer and escalate them to Vicki’s department? Vicki hopefully suggested that she thought they would.

I wasn’t so sure of that. I was still concerned that trans people are going to be discriminated against when dealing with front-line CSRs, who don’t realize they need to escalate trans customers to the supervisor for the “special exceptions” process. So, I ran a spot check.

At 3:25 PM (Eastern), I telephoned PC Financial customer service, to test how effective their “common sense” policy is at preventing PC’s tedious name change policy from effecting indirect discrimination against trans persons, putting PC Financial in violation of the Ontario Human Rights Code.

Note: Although I do not record my calls with Vicki, I did decide to record the spot-check call, to document it as proof that front-line CSRs are refusing to help trans people reach the “special exceptions” team. Please note, my recording is perfectly legal in Canada, especially considering the fact that PC Financial acknowledges “this call may be recorded for quality assurance, security, and for training purposes.” We can only hope this call will be used for training purposes!|width=620

Transcript: (DOWNLOAD MP3) EDIT – Fixed broken MP3 Link (Sorry about that!)

PC Financial: This is Stephanie, how can I help you?

Christin: Hi, um, my name is Christin, I’m calling to ask a question, um… I’ve just recently changed my name with the Province of Ontario, legally, and I need to, um, find out– I need to just ask you a general question about how I would get that changed with PC Financial?

PC Financial: Oh okay, um, the quickest way to have that done is just to go into any Pavilion with the legal name change document, as well as two pieces of standard ID in the new name.

Christin: Two pieces of ID with the new name?

PC Financial: Yep, exactly, one with a photo and one without, so if you had, say, a credit card with your new name on it and your driver’s license updated, that’s all you’d need.

Christin: Oh. Okay, I haven’t actually got any new ID yet. I just, uh, did this name change recently, and I sort of need to be able to do banking under my new name as quickly as possible.

PC Financial: Um, we do need ID before we’re able to change the name.

Christin: Okay, um, it’s– I changed it from a man’s name to a woman’s name, and I’d rather not, um, have– like I’d rather not write cheques, and, and whatnot with my– with my old name on it.

PC Financial: (pause) Okay. Um, yeah unfortunately I mean I wish that there was some way for us to get around this, just, you do need the standard ID just so that we know that it’s actually the right person. Um, it’s the same for any situation. I know that seems kind of strict but it’s the only way that we’re able to do it.

Christin: Okay–

PC Financial: But um, if we do this through the mail it can take up to about 15 to 20 business days, if we do this at a Pavilion it takes ten business days, basically within 24 hours of us having all of the documents needed, we’d have your name updated…

Christin: Alright–

PC Financial: …and then from there we can just issue you some cheques so that you’re issued cheques properly,

(sound of car driving by on my end)

Christin: See, um, part of my concern is that it will take me quite some time to get my hands on new identification suitable for this policy, um, so I mean realistically, if I’m looking at a month or so to get, you know, a new passport sent out, as well as 20 days from President’s Choice Financial, it’s– it’s– we’re talking about, I think, more than a month, more than a month or two to get this changed.

(sound of car alarm in the distance)

Christin: Is there, is there any possible– I’m sorry about the noise.

PC Financial: No that’s okay.

Christin: Is there any possible exception to this policy?

PC Financial: Um, I’ll take a look. Just one second. I … doubt it.


PC Financial: See, oh it looks like if you do drop it off at the Pavilion it can take as few as five business days, so it would be between a week and two weeks.

Christin: But they would still require the Photo ID and the extra ID with the new name?

PC Financial: It’s true, I double checked and we do need the standard ID in the new name, as well as the, uh, just the legal name change document, so just some kind of documentation of the name change.

Christin: Okay so, there’s absolutely no process or procedure that would enable you to help someone in my situation to get around this policy?

PC Financial: Unfortunately not. I know that it’s a unique situation and I wish that there was some other way that we could do this for you, but it’s just not a possibility for us right now.

Christin: Okay, so you– um, you guys don’t have, like, a special department or something that handles, um, what did you say? It was an “exceptional situation?”

PC Financial: Um, yeah I mean if it’s a situation different from marriage or anything like that, where it’s going to take you a longer time to get standard ID, there’s no different procedure for us to go on, we do have to follow this procedure.

Christin: Okay, um, thank you very much — I’m sorry, what did you say your name was?

PC Financial: My name is Stephanie.

Christin: Stephanie– Is that spelled the normal way?

PC Financial: Yep.

Christin: Okay. Thank you very much Stephanie, have a great day.

PC Financial: No trouble, you too. Bye bye.

Christin: Bye.

First I want to point out, I do not hold any ill-will against “Stephanie.”  She clearly wanted to help me, but truly believed she wasn’t able to, due to their policy. It does concern me that she knew nothing of any special exceptions, which does not jive well with the information and assurances I received from Vicki.

Once again I think Vicki is a wonderful person, and she has handled our discussions very professionally. But given my conversation with Stephanie, I think Vicki’s confidence in the quality of PC Financial’s front-line CSR training materials is highly misplaced. Had I really been a young, poor trans person about to rent an apartment, or about to apply for a job, or about to apply for student housing, I would once again have been disproportionately disadvantaged by PC’s lack of accommodation for transgender customers, and I would have been forced to “out” my trans status to those other individuals, potentially placing me at risk of harm or harassment.

Until PC Financial distributes training to front-line CSRs and solves this problem, Trans people are still being put at risk, and that means President’s Choice Financial is still guilty of indirect discrimination.

I promise to follow this up with Vicki, and if necessary, get in touch with whomever is responsible for developing policy for front line CSRs. In the mean time, thank you all for continuing to share and discuss this issue. For this to change, the issue must be noticed by as many people as possible.

EDIT – I almost forgot to mention. In my previous post, I had suggested that in lieu of the $100 they offered me, PC Financial might wish to make a charitable donation to a group supporting trans youth. Vicki advised me that charitable donations are decided at a much higher level, and it was not something she could authorize. She suggested they could pay me the money directly and I could “pass it on” to the trans youth group myself, but that really doesn’t strike me as carrying quite the same symbolic meaning, so I said I would think about it and get back to her. I would prefer PC Financial choose to make the symbolic gesture, as a way to make up for the hardship that transgender customers have faced as a result of their policy.

If it does come to passing the money through me, at least I will now be able to make the donation via a cheque written in my new name, since Vicki helped me out by ordering some for me. Stay tuned for further updates.


  1. Euan
    Thursday, 2011.05.19 at 21:26

    You have been very brave to do all these. As an another transgender citizen in this country, thank you so much for changing the society 🙂

    • chrinfinity
      Thursday, 2011.05.19 at 21:49

      Thank you Euan,

      That means a lot to me. Somebody has to document these situations and make the world aware of just how and why they are discriminatory. If I am able to make a change, I will be overjoyed.

      I hope you are well.


      Christin Scarlett Milloy

  2. Jesse Larabee
    Thursday, 2012.07.19 at 01:06

    You need to secretly record government officials. You can secretly record under section 183.1 of the Criminal Code of Canada.

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Christin Milloy