What Is Personal Information?
Why Singh Mortgages Collects Personal Information
Singh Mortgages collects and uses Personal Information for the following purposes:
- Provide mortgage brokering services to the Client and offer products and services best suited to their needs, including arranging and/or renewing loan(s)/mortgage(s), informing the client of group creditor insurance and other products offered or approved by Singh Mortgages or its affiliates that may be of interest to the Client;
- Checking Client credit worthiness through credit bureau inquiry and personal information agents who have information on a Client’s financial position.
- Advising Clients of the financial options, as well as, ongoing developments of themortgage market and industry;
- Auditing the services provided to our Clients;
- Compliance with all municipal, provincial, federal and other applicable laws; and
- Such other specific purposes which are communicated to the Client by a member of Singh Mortgages before collection of such Personal Information.
Except when otherwise permitted by law, we will only use a Client’s Personal Information for the purposes identified to the Client. When Personal Information is to be used for a purpose not identified, we will take all reasonable steps to ensure that new purpose is identified prior to use.
How Do We Collect Personal Information?
The Client is our main source of information. With the Client’s consent, we may also obtain information directly from a third party to help us determine eligibility for various financial products and services. For credit matters, for example, it is essential that we know the clients’ financial worth as well as the clients’ credit record. We will also contact other lenders, financial institutions, credit bureaus and employers.
Consent is therefore important because without it, we will not be able to carry out the
appropriate inquiries and it might be difficult for us to offer the credit product requested. In most cases, consent is given on the forms used for specific products or, from time to time, on a separate form. The declaration of consent is clear and unambiguous.
The most common method we use to obtain a Client’s consent is by way of the Client’s consent as confirmed by the application. Where practicable, we may also obtain a Client’s consent through oral communications or other written documentation.
Our Clients may withdraw their consent by written notice to us at any time, subject to any legal or contractual restrictions and reasonable notice. A Client’s refusal to provide, or subsequent withdrawal of, his or her consent may affect Singh Mortgages’s ability to provide the Client with mortgage services. A member of Singh Mortgages will inform the Client of the implications of such withdrawal. To withdraw consent, a Client should contact the Chief Privacy Officer in writing at:
123 ABC St.
Canada, ABC 123
Use and Disclosure of Personal Information
We will use a Client’s Personal Information to provide financial advice and services to the Client, to administer our database, to include Clients in direct marketing Activities and for the other uses described above under the heading “Why Singh Mortgages Collects Personal Information”. Under certain circumstances, Singh Mortgages will disclose a Client’s personal information to third parties. Specifically, Personal Information may be used, shared and disclosed to, from, or with, the members of Singh Mortgages, witnesses in a litigation proceeding, experts retained on a Client’s behalf, private investigators, agents retained on behalf of a Client, credit reporting agencies, credit bureaus, as well as such other third parties as are necessary to facilitate the matter for which the Client has retained our office and provided its consent.
Under certain circumstances Singh Mortgages may disclose Personal Information where:
- required or authorized by law to do so, for example if a court issues a subpoena;
- a Client has consented to the disclosure;
- when mortgage services by Singh Mortgages are provided to a Client requiring us togive Personal Information about a Client to a third party (for example, to a lender in a real estate mortgage transaction) the Client’s consent will be implied, unless the client tells us otherwise;
- where it is necessary to pull a credit bureau for purposes of processing a mortgagetransaction;
- protection of Singh Mortgages’s best interests;
- protection of public interests such as the denouncement of criminal Activity such as fraud or money laundering. In all such cases, authorities are contacted and personal information may be disclosed;
- if we retain a law firm(s) to Act on our behalf for any reason; or
- if the information is already publicly known.
Limiting collection and retention of Personal Information
Singh Mortgages limits the collection of a Client’s Personal Information to that which is
Singh Mortgages will retain Personal Information only for so long as it is needed to fulfill the purposes for which it was obtained and to meet our professional requirements as set out our governing regulatory bodies and/or any other legal requirement, statutory or otherwise, from time to time.
Singh Mortgages strives to ensure that a Client’s Personal Information is as accurate, complete, and up-to-date as is necessary for the purposes for which it is used.
Singh Mortgages endeavors to maintain adequate safeguards to protect against loss, theft, unauthorized access, disclosure, copying, use or modification of Clients’ Personal Information in the care of Singh Mortgages. Singh Mortgages uses various methods to safeguard personal information, including physical security, computer and electronic security, destruction of information no longer needed, and contractual protections with third party data processors.
Client lists are never passed on to third parties other than affiliated members of Singh Mortgages. When they are hired, our employees and agents must undertake to respect the confidential nature of client information. Only employees and associates who need to view the file as part of their work have access to this information.
Accountability, Openness and Client Access
- The information is protected by legal privilege;
- Granting access would reveal confidential commercial information;
- The information was collected for purposes related to the detection and prevention of fraud;
- The information was generated in the course of a formal dispute resolution process;
- The information would likely reveal personal information about another individual;
- The request is vexation or frivolous;
- To protect our firm’s rights and property.
Singh Mortgages Web site
Communicating With Singh Mortgages
We recognize that convenience and quick access to advice must be balanced with security needs. We use many different means to communicate with clients, some of which are more convenient such as e-mail. If clients do not wish us to communicate by e-mail or fax or any other none verbal communication method, they may speak with the consultant/broker/agent handling the matter about alternative arrangements.
123 ABC St.
Canada, ABC 123
AGENT PROTECTION OF DATA
All agents and brokers will take reasonable steps to protect personal data supplied by clients.
All original documentation will be kept in secure premises not accessible to the public. Once a file is complete, any un-required documentation will be returned to the client immediately.
Original documentation will be submitted to head office in either hardcopy or electronic
format prior to the closing of the transaction. While agents may retain copies of files, every effort must be made to safeguard the information on hand.
It should be noted that all files are the property of Singh Mortgages. Although brokers and agents may retain data for marketing purposes, the clients belong to Singh Mortgages.
Any documentation not further required, must be shredded immediately.
All electronic documentation must be password protected. Laptops containing client files shall not be left unattended in public areas.
HEAD OFFICE PROTECTION OF DATA
Head Office will take reasonable steps to ensure the security of the data of client files.
Scanned documentation must be adequately protected and catalogued. All client records and personnel records will be kept in locked cabinets or in secured electronic format. All computers at head office will be password protected and data will be backed up on a regular basis by a third-party source.