We, at Home Is Home, are committed to protecting the privacy and confidentiality of the personal information of our clients. As financial service providers, we have a professional obligation to maintain in confidence the information we receive within that role. The purpose of the Privacy and Security Policy is to explain to our clients why we ask for personal information, how we use that information, what safeguards we employ to protect that information, and finally how to contact us with any privacy related questions or concerns.
THE TEN PRINCIPLES OF PRIVACY
The Personal Information Protection and Electronic Documents Act (referred to as PIPEDA) contains, in Schedule One, a code that all organizations must follow for the protection of personal information. The ten Principles of Privacy that Home Is Home governs itself by, are specified in Schedule One. (Please see www.priv.gc.ca to view the Act in full). The following is an explanation of these principles:
2) IDENTIFYING PURPOSES
Home Is Home will identify the purposes for which all personal information is being collected before, or at the time of collection.
Home Is Home will obtain your express consent before or when it collects, uses, or discloses your personal information. You may withdraw your consent at any time by contacting the Privacy Officer. Home Is Home may collect, use or disclose your personal information without your knowledge or consent in circumstances where such action is permitted or required by law.
4) LIMITING COLLECTION
The scope of personal information collected by Home Is Home will be restricted to those details that are necessary for the purposes identified to you, or to perform the services you have requested. All information will be collected in a lawful manner.
5) LIMITING USE, DISCLOSURE AND RETENTION
Your personal information will only be used for the purposes for which it was collected, or to perform the services that you have requested, unless you have consented to other uses. All personal information will be retained by Home Is Home for the period of time mandated by the Mortgage Brokers Lenders and Licensing Act (MBLAA), as regulated and administered by the Financial Services Commission of Ontario (FSCO). Home Is Home may disclose your personal information without your knowledge or consent in circumstances where such action is permitted or required by law.
Home Is Home will endeavour to maintain personal information that is as accurate, complete and current as possible. You may have this information amended where it is found to be inaccurate or incomplete. We may request updated information in order to fulfill services requested by you. This update will not occur without your express consent.
Home Is Home will safeguard all personal information by using measures reflective of the sensitive nature of that information, including, but not restricted to, security cameras, alarm systems, passwords, and shredding policies. We undertake to protect your personal information by following, at a minimum, the standards as set out by FSCO.
Home Is Home will make this Privacy and Security Policy easily available to all employees, clients or potential clients by providing access through its website, by emailing a copy upon request, or by any other means as required.
9) INDIVIDUAL ACCESS
Home Is Home will respond to your written request for details about the existence, use, disclosure and scope of the personal information held about you. You will also be given access to this information, and this access and our response to your request will be done in as timely a manner as possible. In the unusual case where we cannot provide these details to you, we will provide you with the reasons why, unless prohibited by law.
You may address a challenge to any part of this policy and its adherence to the principles above. The contact information for our Privacy Officer is provided at the end of these policies. All complaints will be treated in a respectful and open manner, and Home Is Home will take appropriate measures if a complaint is found to be justified. You may contact the Privacy Officer regarding any part of this policy, or about your personal information held by us.
APPLICATION OF THE TEN PRIVACY PRINCIPLES
WHAT IS PERSONAL INFORMATION?
In this Privacy and Security Policy, ‘personal information’ means information that is gathered in connection with an application, pre-approval, request for information for a mortgage or secured line of credit, or any other product offered through Home Is Home or Home Is Home’s affiliates. This information includes (but is not restricted to): contact information, demographics, financial information and identifying information. These details are provided to or collected by Home Is Home and its staff, or by Home Is Home’s agents, associates, and affiliates on Home Is Home’s behalf.
Home Is Home does not require your Social Insurance Number to accept an on-line application. You may choose to provide that information via the on-line application, or when you speak with us, to expedite the servicing of your mortgage application.
WHY DOES HOME IS HOME COLLECT PERSONAL INFORMATION?
Home Is Home collects and uses personal information for the following purposes:
- To provide mortgage brokering services to you, and to offer products and services that are best suited to your needs. Your personal information allows us to provide you with the products and services you have requested, and to ensure that you are satisfied with the products and services we have provided.
- To check your credit-worthiness via credit bureau inquiry and other information providing agencies
- To advise you of your options, as well as ongoing developments in the mortgage market, the mortgage industry and the economy as a whole.
- To ensure compliance with all applicable laws, weather municipal, provincial or federal (or otherwise defined).
- For any other specific purposes which are communicated to you by Home Is Home or its affiliates, or any other purposes as requested by you.
Unless otherwise permitted by law, Home Is Home will only use your personal information for the purposes identified above. When personal information is to be used for a purpose not so identified, Home Is Home will take all reasonable steps to ensure that the new purpose is clearly identified to you prior to said use.
HOW DOES HOME IS HOME COLLECT PERSONAL INFORMATION?
The client is our main source of information. With the client’s consent, we may also obtain information directly from third parties to help us determine eligibility for various financial products and services. For example, to analyze a client’s financial situation, it is essential that we know the client’s assets and liabilities, as well as the client’s credit history. Home Is Home will also contact other lenders, financial institutions, credit bureau reporting companies, and employers. Home Is Home cannot and will not make these inquiries without direct, written consent from the client. Without this consent, Home Is Home is not able to carry out the appropriate inquiries and thus will be restricted in its ability to advise on, and to offer, credit products. In most cases, Home Is Home requires consent to be given on specific forms designed for designated products, or on separate forms. The declaration of consent must be clear and unambiguous.
WHAT IS CONSENT?
The providing of personal information by a client to Home Is Home means that the client agrees and consents to Home Is Home collecting, using, and disclosing this personal information in compliance with this Privacy and Security Policy. Home Is Home will not collect, use, or disclose a client’s personal information without the client’s direct consent, except in certain extraordinary circumstances, which include, but are not limited to, occasions when legal, medical or security reasons make it impossible or impractical to obtain consent, or where it is otherwise in the best interests of the client.
Client consent must be in writing, signed by the client, or given by agreeing to the terms of our on-line application. Oral consent is not considered sufficient.
WITHDRAWING CONSENT AND OPTING OUT.
Clients may withdraw consent by providing written notice to Home Is Home at any time, subject to legal or contractual restrictions or reasonable notice. A client’s refusal to provide consent, or the withdrawal of consent previously given, may affect Home Is Home’s ability to provide the client with the service originally requested by the client. Home Is Home will endeavour to fully inform the client of the potential result of the withholding or withdrawal of their consent to collect personal information.
In order to provide our clients with our services and products, Home Is Home will, with your consent, contact you to provide you with information on our products and services and may share your personal information with other Home Is Home affiliates. Should you not wish to receive promotional materials from or have your personal information shared with these companies please contact the Privacy Officer at the address below.
To withdraw consent, please contact the Privacy Officer, in writing, at:
Home Is Home
Attention: Privacy Officer
123 Mary Street East
Whitby, L1N 2P3
Alternatively, you may call the office at 289-314-8786, and ask for the Privacy Officer.
HOW DOES HOME IS HOME USE AND DISCLOSE PERSONAL INFORMATION?
Home Is Home will use a client’s personal information for three general purposes:
- To communicate with you regarding the services and products you have requested
- To include with all other documentation pertaining to your file
- To monitor our level of service and remain in touch with you to ensure your satisfaction with our service, and for follow up, as discussed during our work with you.
We will only use your personal information for the purposes that we have disclosed to you. If we wish to use your information in a different manner, we will notify you, and ask you for your consent first.
Home Is Home is obliged to keep your personal information confidential except under circumstances when we are authorized by you, required by law or permitted by law.
In some cases, such as under a court order, Home Is Home 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. Home Is Home may also disclose personal information without your consent in situations such as (but not restricted to) those involving the collection of debt in arrears, medical emergencies, or suspicion of illegal activities.
Under no circumstances with Home Is Home ever sell information about you to anyone.
HOW DOES HOME IS HOME LIMIT THE COLLECTION AND RETENTION OF PERSONAL INFORMATION?
Home Is Home undertakes to limit the collection of personal information to those details that are deemed necessary under the provisions of this Privacy and Security Policy, or for any additional purposes as identified and explained to the client before the personal information is collected. As stated, Home Is Home will only use this information for reasons as disclosed in this policy, accepting the extraordinary circumstances as listed above.
Home Is Home will only retain a client’s personal information for as long as necessary to fulfill the purposes for which it was collected, and to meet its professional and/or legal requirements (whether statutory or otherwise) as set out by its governing regulatory bodies.
WHAT SAFEGUARDS AND PROTECTION DOES HOME IS HOME USE?
Home Is Home strives to maintain the strongest safeguards to protect against loss, theft, unauthorized access, disclosure, copying, use or modification of all clients’ personal information in its possession. For example, Home Is Home has commercial grade security software. Other safeguards include, but are not restricted to, physical security (Medeco locks, ADT alarms, video recording systems), computer and electronic security, thorough and secure destruction of information that is no longer required, and contractual protection with third party data processors.
Home Is Home does not share client lists with any third parties other than its affiliates. All associates of Home Is Home undertake to respect the confidential nature of all the personal information that has been collected. Only those associates who need to view the file as part of their work with the client have access to this information.
Home Is Home follows generally accepted industry standards set up to protect personal information that is submitted electronically, both by and to the company. No method of transmission over the Internet is 100% secure, however. Therefore we cannot guarantee absolute security.
REGARDING HOME IS HOME’S WEBSITE SECURITY.
Home Is Home may monitor traffic patterns on its website by collecting information about a visitor’s IP address, operating system, browser, system location, time and length of visit, pages viewed, internet provider, previous sites visited and links that are followed. This is done to optimize its web service and information. Home Is Home may provide aggregate information to third parties about these findings, but will never include any personal information in these statistics.
Home Is Home may also use this information to analyze trends, administer the website, and to track movements around the website in order to monitor the effectiveness of the content on the website.
Home Is Home’s website contains links to other websites, including those of its licensees and business partners. Home Is Home is in no way responsible and cannot guarantee the content or privacy of other websites so linked.
Home Is Home welcomes all questions and concerns about our Privacy and Security Policy. Please contact the Privacy Officer at:
Steve Tallo, B.Comm, CFA
Mortgage Agent (Lic. M14001732)
Oriana Financial Group of Canada (Lic. #10214)
123 Mary Street East,
Whitby, Ontario L1N 2P3
If you feel you need to escalate your issue, you may contact the Privacy Commissioner of Canada at:
The Privacy Commissioner of Canada
112 Kent Street
Home Is Home reserves the right to amend this Privacy and Security Policy.
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