2.2 Privacy Policy
2.2.1 Overview
At Mortgage Partners Corporation, we respect the privacy of our Mortgage Brokers/Agents and we are committed to keeping your personal information accurate, confidential, secure and private. We have adopted the following Privacy Policy to ensure that we continue to meet our commitment to your privacy.
2.2.2
Introduction
We provide a variety of products and services to the public, including, but not limited to Mortgage Financing Services, Lease Financing Services, and Mortgage Life Insurance Services.
In the course of complying with the various financial regulations that apply to mortgage Brokering, we are required to collect, with your consent, certain personal information about you. “Personal Information” means information about an identifiable individual Broker/Agent. This may include, without limitation, your name, home address, email address, age, gender, income, personal preferences, and other information about you or your family.
Our Privacy Policy is based on, and complies with, Canada’s Personal Information Protection and Electronic Documents Act (“PIPEDA”), which includes the Ten Privacy Principles outlined in the Canadian Standards Association Model Code for the Protection of Personal Privacy. For more information about this legislation, you can visit the official website of the Privacy
Commission of Canada at http://www.privcom.gc.ca. Adherence to this policy is required of all contractors and Employees.
The Privacy Policy describes the ten principles that we follow to ensure that we protect your personal information when we collect, use or disclose it in the course of carrying on commercial activities in Canada. Any Employee or Contractor of Mortgage Partners Corporation who may have a need to access to your personal information must be knowledgeable of this Privacy Policy and adhere to the Privacy Policy and related procedures. To this end, we have appointed a Privacy Officer (the Principal Broker of our Brokerage) to ensure compliance by all.
2.2.3
The Ten Principles of Privacy
The following Ten Principles govern our actions as they relate to the use of your personal information: Principle 1
Accountability Principle 2
Identifying purposes Principle 3
Consent
Principle 4 Principle 5 Principle 6 Principle 7 Principle 8 Principle 9 Principle 10
Limiting Collection Limiting Use, Disclosure and Retention Accuracy Safeguarding Personal Information Openness Accessing and Amending Your Information Addressing Mortgage Expert Complaints
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Principle 1 – Accountability We are accountable for all personal information in our possession or custody, including personal information disclosed to third parties for purposes of providing services requested by you.
Principle 2 – Identifying purposes We will inform you of the purposes for which we are collecting any personal information, either before, or at the time the information is collected.
Principle 3 – Consent We will obtain consent from you before or when we collect, use or disclose your personal information.
Principle 4 – Limiting Collection The information collected will be limited to those details necessary for the purposes we have identified that relate to managing our relationship with you. Information will be collected by fair and lawful means.
Principle 5 – Limiting Use, Disclosure and Retention Personal information will only be used or disclosed for the purpose for which it was collected unless you have otherwise consented, or when it is required or permitted by law. In certain exceptional circumstances, we may have a legal duty or right to disclose personal information without your knowledge or consent with respect to matters that concern the company’s or the public’s interest.
Principle 6 – Accuracy We will keep personal information as accurate, complete and current as necessary to fulfill the identified purposes for which it was collected. You may have this information amended where it is found to be inaccurate or incomplete.
Principle 7 – Safeguarding Personal Information Personal information is safeguarded using measures appropriate to the sensitivity of the information. All personal records will be securely safeguarded to protect against theft and/or falsification of the information.
Principle 8 – Openness We will make information available to you about the Policies and Procedures we use to manage personal information.
Principle 9 – Individual Access – Accessing and Amending Information Upon written request, you will be informed of the existence, use and disclosure of your personal information, and will be given access to it. We will respond to such requests as efficiently as possible. If we are prohibited from providing such access, we will explain the reasons for the lack of access, except where prohibited by law.
Principle 10 – Addressing Complaints and Suggestions You may challenge Mortgage Partners Corporation compliance with the Privacy Policy. We have policies and procedures to receive, investigate and respond to your complaints and questions. You may also contact our Privacy Officer to express any concerns or to request access to your personal information. The contact information for this individual is provided below.
Name:
Email:
Tel:
2.2.4
Information We Typically Collect
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The information we typically require includes:
Name
6. Date of Birth Address
7. Banking Information Phone number(s)
8. Personal Work History E-mail
9. Personal Background Information Social Insurance Number
10. Educational Background
Additional information may be required from you for the purposes of your employment contract, independent contractor agreement, or to allow us to comply with the MBLAA, 2006 or other laws and regulations. You will be notified of what information is required and why we require it at the time it is requested.
2.2.5 How Your Information Is Used
At Mortgage Partners Corporation we use personal information for three general purposes:
1. To provide service or benefit providers the necessary information so they can accurately
and cost effectively provide these services or benefits to you; 2. To assist you in facilitating your business as a Mortgage Broker/Agent; 3. To develop and manage our professional relationship with you.
We will only use personal information for the purposes that we have disclosed to you. If we wish to use your information for a different purpose, we will notify you and ask for your consent in advance.
2.2.6 When Can We Disclose Your Personal Information?
We are obligated to keep your personal information confidential except under the following circumstances:
(0) When Authorized by You Many of the services offered by us require us to obtain personal information. We will use this
information to tailor programs to meet your needs and objectives. We will always obtain consent from you first, and we will never use the information for purposes other than those we have told you. You may also withdraw your consent at any time, subject to any legal implications (which we will inform you about).
(ii) When Required by Law In some cases, such as under a court order, we may be required to disclose certain information to persons specified in the court order. We will only provide the specific information requested and only upon being satisfied that the authorities have legitimate grounds to request the information.
(iii) When Permitted by Law The legislation has provided certain situations where we are legally permitted to disclose personal information without your consent. Examples include situations involving the collection of debt in arrears, medical emergencies, or suspicion of illegal activities.
2.2.7 With Whom We May Share Your Information
() Employees In the course of daily operations, access to sensitive personal information is limited to those Employees or Contractors with our Brokerage that have a legitimate reason for accessing it. As a condition of their employment, our Employees are required to follow all applicable laws and regulations, including this Privacy Policy.
Unauthorized use or disclosure of confidential Client or Contractor information by one of our Employees is prohibited, and will result in disciplinary measures against the Employee who disclosed the information in an unauthorized manner.
(ii) Affiliates In order to better meet your needs, we may share some of your personal information with our affiliated companies. We will only do this with your express consent and you may withdraw this consent at any time. The procedure for withdrawing consent is outlined below under the section “Opting Out”.
(iii) Third Party Suppliers As you know, we engage and coordinate third party suppliers (Lenders) to provide you with services offered through this Brokerage.
Such suppliers are only given the information that is needed to communicate with you directly about their products and services. Suppliers are contractually bound to protect the confidentiality of your personal information, and they are prohibited from doing anything with this information that we have not authorized them to do. They are required to treat your personal information in a manner consistent with our Privacy Policy.
(iv) Sale of Business We may transfer your personally identifiable information to a third party in connection with a sale, merger or other disposition (whether of assets, stock or otherwise) of our business.
2.2.8 How We Safeguard Information
Mortgage Partners Corporation has extensive controls in place to maintain the security of its information and information systems. Personnel files are stored according to the sensitivity of the information contained therein. Appropriate controls (such as restricted access) exist on our computer systems and form part of our data processing procedures. Physical access to areas where your personal information is gathered, processed or stored is secured and limited to authorized Employees.
2.2.9 Accessing and Amending Your Information
You have the right to access the personal information we keep in your file and you have the right to verify or amend the information if it is shown to be inaccurate. If you would like to view the personal information held in your file, please make a written request to the Privacy Officer at the address listed below. We will respond to your request as quickly as possible.
To make a change to your personal information, please make a similar request in writing to the Privacy Officer.
Name:
Email:
Tel:
2.2.10 Opting Out
In order to assist you in dealing with third party service providers, we may, with your consent, share your personal information with these and other affiliated companies. Should you not want relevant personal information shared with these companies, please contact the Privacy Officer directly.
2.2.11 Questions, Concerns and Complaints
If you have any questions, concerns, or complaints about your personal information, or about our Privacy Policy, please contact our Privacy Officer. Their contact information is available from the Principal Broker of our firm.
