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 documents not required will be returned to the client immediately.
Original documentation will be submitted to head office in either hard copy or electronic format, after the closing of the transaction. While agents may retain copies of files for their personal use, every effort must be made to safeguard the information on hand.
It should be noted that all files are the property of Real Mortgage Associates Inc.
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.
What Is Personal Information?
In this Privacy Policy, “Personal Information” means information that is gathered in connection with an application, pre-approval, request for information for a mortgage(s) or loan(s) and insurance or other product through Real Mortgage Associates or Real Mortgage Associates affiliates and is provided to, or collected by, Real Mortgage Associates Inc. and its staff or by Real Mortgage Associate’s agents, associates, and affiliates on Real Mortgage Associate Inc.’s behalf (collectively, “Real Mortgage Associates Inc.”).
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.
Why Real Mortgage Associates Inc. Collects Personal Information
Real Mortgage Associates Inc. 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 Real Mortgage Associates Inc. 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 the mortgage 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 Real Mortgage Associates 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.
Consent
A clients’ provision of Personal Information to Real Mortgage Associates Inc. means that they agree and consent that Real Mortgage Associates Inc. can collect, use and disclose such Personal Information in compliance with this Privacy Policy. Real Mortgage Associates Inc. will not collect, use or disclose a Client’s Personal Information without the Client’s written consent, except in certain extraordinary circumstances. Such extraordinary circumstances shall include without limitation, 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.
The most common method we use to obtain a Client’s consent is by way of the Client’s written consent as part of the application. We may also obtain a Client’s consent through communications of other written documentation. In order to produce evidence of consent, the mortgage broker must produce independent evidence of consent obtained directly from the person whose credit bureau is to be searched. This would include a consent form which has been physically signed by the person.
Verbal consent will be accepted provided it is accompanied with documentation such as a written log consisting of the consent, example being, date of conversation with the time of the consent from the client with his name, address and phone number and this is to be placed and kept in the clients file.
In addition, verifiable consent given to a mortgage broker from a person to have their credit bureau searched must be obtained prior to the credit bureau search, and not following it.
At Real Mortgage Associates Inc. (RMA) we recognize and respect every individual’s right to privacy. When you apply for a mortgage or other credit, RMA establishes a confidential file that is kept in our offices. We limit access to information in your file to RMA agents and staff who require it in order to perform their duties, to credit grantors, credit bureaus, suppliers of service, mortgage insurer’s, to persons you have granted access, and to persons authorized by law.
As discussed this is our privacy policy regarding personal information and a request for your authorization for us to access your credit information for the purpose of securing a mortgage approval, for you.
We use the information to determine your eligibility for credit and other administrative matters.
We will be unable to proceed with the mortgage approval without your authorization.
Yes we give you verbal authorization to access my credit history that is when you will document the Name of the client, time, date and year.
When receiving verbal authorization from a client the agent or broker will read the above statement and will document the Name, address and phone number of the client including the date and the time of the approval for authorization from the client which will be added and stored to clients file.
Agent/Broker will explain to client without this information the agent will not be able to proceed with the mortgage.
All files are stored electronically and a retention of files are kept for 6 years
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 Real Mortgage Associate’s ability to provide the Client with mortgage services. A member of Real Mortgage Associates Inc. will inform the Client of the implications of such withdrawal.
To withdraw consent, a Client should contact the Chief Privacy Officer in writing at:
Attn: Chief Privacy Officer
Real Mortgage Associates Inc.
3370 South Service Rd, Garden Floor
Burlington, Ontario
L7N 3M6
Phone: 1-877-677-7778
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 Real Mortgage Associates Inc. Collects Personal Information”. Under certain circumstances, Real Mortgage Associates Inc. 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 Real Mortgage Associates Inc., 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 Real Mortgage Associates Inc. 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 Real Mortgage Associates Inc. are provided to a Client requiring us to give 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 mortgage transaction;
- if Real Mortgage Associates Inc. engages a third party to provide administrative or support services to us (such as computer back-up services, payroll, shredding or archival file storage) and the third party is bound by our Privacy Policy;
- protection of Real Mortgage Associate’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
Real Mortgage Associates Inc. limits the collection of a Client’s Personal Information to that which is necessary for the purposes identified in this Privacy Policy as same may be amended from time to time, or for any additional purpose identified to the Client before the collection of the Personal Information. As well, Personal Information is not used or disclosed for purposes other than those for which it was originally collected, except with the consent of the Client or as otherwise permitted by law.
Real Mortgage Associates Inc. 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.
Accuracy
Real Mortgage Associates Inc. 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.
Safeguards
Real Mortgage Associates Inc. 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 the Real Mortgage Associates Inc. Real Mortgage Associates Inc. 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.
Protection
Client lists are never passed on to third parties other than affiliated members of Real Mortgage Associates Inc. 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
Real Mortgage Associates Inc. is responsible for the Personal Information under its control and has appointed a Chief Privacy Officer to oversee our efforts to comply in all material respects with applicable privacy legislation and the terms of this Privacy Policy. The Chief Privacy Officer and those designated by the Chief Privacy Officer address and investigate questions or concerns regarding a Client’s Personal Information.
Real Mortgage Associates Inc. will provide a Client access to their Personal Information. The Client may correct or amend any inaccuracies in the Client’s Personal Information. Real Mortgage Associates Inc. has the right to refuse a request for access to Personal Information if:
- 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.
