At Western Mortgage Services Inc., we are committed to providing
our Clients, Customers, members Associates and Lenders with exceptional
service. As providing this service involves the collection, use
and disclosure of some personal information about our, protecting
their personal information is one of our highest priorities.
While we have always respected our Clients, Customers, Members,
Associates and Lenders privacy and safeguarded their personal information,
we have strengthened our commitment to protecting personal information
as a result of British Columbia’s Personal Information Protection
Act (PIPA). PIPA, which came into effect on January 1, 2004, sets
out the ground rules for how B.C. businesses and not-for-profit
organizations may collect, use and disclose personal information.
We will inform our Clients, Customers, Members, Associates and
Lenders of why and how we collect, use and disclose their personal
information, obtain their consent where required, and only handle
their personal information in a manner that a reasonable person
would consider appropriate in the circumstances.
This Personal Information Protection Policy, in compliance with
PIPA, outlines the principles and practices we will follow in protecting
personal information. Clients, Customers, Members, Associates and
Lenders Our privacy commitment includes ensuring the accuracy, confidentiality,
and security of our Clients, Customers, Members, Associates and
Lenders personal information and allowing our Clients, Customers,
Members, Associates and Lenders to request access to, and correction
of, their personal information.
Scope of this Policy
This Personal Information Protection Policy applies to Western Mortgage
Services Inc. This policy also applies to any service providers
collecting, using or disclosing personal information on behalf of
Western Mortgage Services Inc
Definitions
Personal Information –means information
about an identifiable individual Providing examples of information
to Western Mortgage Services Inc collects. E.g., including name,
age, home address and phone number, social insurance number, marital
status, , income, credit history, education, employment information].
Personal information does not include contact information (described
below).
Contact information – means information
that would enable an individual to be contacted at a place of business
and includes name, position name or title, business telephone number,
business address, business email or business fax number. Contact
information is not covered by this policy or PIPA.
Privacy Officer – means the individual
designated responsibility for ensuring that Western Mortgage Services
Inc complies with this policy and PIPA.
Policy 1 – Collecting
Personal Information
1.1 Unless the purposes for collecting personal information
are obvious and the Clients, Customers, Members ,Associates and
Lenders voluntarily provides his or her personal information for
those purposes, we will communicate the purposes for which personal
information is being collected, either orally or in writing, before
or at the time of collection.
1.2 We will only collect Clients, Customers, Members, Associates
and Lenders information that is necessary to fulfill the following
purposes:
The purposes for which Western Mortgage Services Inc collects
personal information. Examples of purpose statements, which may
or may not be applicable to our organization, include:
• To verify identity;
• To verify creditworthiness;
• To identify Client, Customer
• To understand the financial, banking, insurance needs
of our clients, customers,
• To deliver requested products and services mortgage
updates, renewals
• To provide Financial counselling services;
• To enrol the client in a program;
• To send out association membership information;
• To contact our clients, customers, members for fundraising;
• To ensure a high standard of service to our clients,
customers, members;
• To meet regulatory requirements;
• To assess suitability for tenancy;
To verify identity, we may collect name, home address, home telephone
number and birth date
Policy 2 – Consent
2.1 We will obtain Clients, Customers, Members ,Associates and
Lenders consent to collect, use or disclose personal information
(except where, as noted below, we are authorized to do so without
consent).
2.2 Consent can be provided Orally (verbal in writing, via email,
fax in person or through a representative or it can be implied
where the purpose for collecting using or disclosing the personal
information would be considered obvious and the Clients, Customers,
Members ,Associates and Lenders voluntarily provides personal
information for that purpose.
2.3 Consent may also be implied where a Clients, Customers,
Members ,Associates and Lenders is given notice and a reasonable
opportunity to opt-out of his or her personal information being
used for mail-outs, the marketing of new services or products,
fundraising and the Clients, Customers, Members ,Associates and
Lenders does not opt-out.
2.4 Subject to certain exceptions (e.g., the personal information
is necessary to provide the service or product, or the withdrawal
of consent would frustrate the performance of a legal obligation),
Clients, Customers, Members ,Associates and Lenders can withhold
or withdraw their consent for Western Mortgage Services Inc.to
use their personal information in certain ways. A Clients, Customers,
Members ,Associates and Lenders decision to withhold or withdraw
their consent to certain uses of personal information may restrict
our ability to provide a particular service or product. If so,
we will explain the situation to assist the Clients, Customers,
Members, Associates and Lenders in making the decision.
2.5 We may collect, use or disclose personal information without
the Clients, Customers, Members ,Associates and Lenders knowledge
or consent in the following limited circumstances:
The situations that may be applicable to our organization. A
full listing of such circumstances can be found in sections 12,
15, and 18 of PIPA. Some examples include:
• When the collection, use or disclosure of personal
information is permitted or required by law;
• In an emergency that threatens an individual's life,
health, or personal security;
• When the personal information is available from a public
source (e.g., a telephone directory);
• When we require legal advice from a lawyer;
• For the purposes of collecting a debt;
• To protect ourselves from fraud;
To investigate an anticipated breach of an agreement or a contravention
of law
Policy 3 – Using and
Disclosing Personal Information
3.1 We will only use or disclose Clients, Customers, Members
,Associates and Lenders personal information where necessary to
fulfill the purposes identified at the time of collection [or
for a purpose reasonably related to those purposes such as:
Any related purposes for which our organization uses or discloses
personal information. Examples that may be applicable to our organization,
include:
• To conduct client, customer, member surveys in order
to enhance the provision of our services;
• To contact our [clients, customers, members] directly
about products and services that may be of interest;]
3.2 We will not use or disclose Clients, Customers, Members
,Associates and Lenders personal information for any additional
purpose unless we obtain consent to do so.
3.3 We will not sell Clients, Customers, Members ,Associates
and Lenders lists or personal information to other parties
Policy 4 – Retaining
Personal Information
4.1 If we use Clients, Customers, Members ,Associates and Lenders
personal information to make a decision that directly affects
the Clients, Customers, Members ,Associates and Lenders we will
retain that personal information for at least one year so that
the Clients, Customers, Members ,Associates and Lenders has a
reasonable opportunity to request access to it.
4.2 Subject to policy 4.1, we will retain Clients, Customers,
Members, Associates and Lenders personal information only as long
as necessary to fulfill the identified purposes or a legal or
business purpose.
Policy 5 – Ensuring Accuracy
of Personal Information
5.1 We will make reasonable efforts to ensure that Clients,
Customers, Members, Associates and Lenders personal information
is accurate and complete where it may be used to make a decision
about the Clients, Customers, Members ,Associates and Lenders
or disclosed to another organization.
5.2 Clients, Customers, Members, Associates and Lenders may
request correction to their personal information in order to ensure
its accuracy and completeness. A request to correct personal information
must be made in writing and provide sufficient detail to identify
the personal information and the correction being sought.
5.3 If the personal information is demonstrated to be inaccurate
or incomplete, we will correct the information as required and
send the corrected information to any organization to which we
disclosed the personal information in the previous year. If the
correction is not made, we will note the correction request in
the file.
Clients, Customers, Members, Associates and Lenders
Policy 6 – Securing Personal
Information
6.1 We are committed to ensuring the security of Clients, Customers,
Members, Associates and Lenders personal information in order
to protect it from unauthorized access, collection, use, disclosure,
copying, modification or disposal or similar risks.
6.2 The following security measures will be followed to ensure
that Clients, Customers, Members, Associates and Lenders personal
information is appropriately protected:
Examples may include: the use of locked filing cabinets; physically
securing offices where personal information is held; the use of
user IDs, passwords, encryption, firewalls; restricting employee
access to personal information as appropriate (i.e., only those
that need to know will have access; contractually requiring any
service providers to provide comparable security measures].
6.3 We will use appropriate security measures when destroying
Clients, Customers, Members, Associates and Lenders personal information
such as methods your organization employs. Examples may include:
shredding documents, deleting electronically stored information].
6.4 We will continually review and update our security policies
and controls as technology changes to ensure ongoing personal
information security.
Policy 7 – Providing
Clients, Customers, Members, Associates and Lenders Access to Personal
Information
7.1 Clients, Customers, Members, Associates and Lenders have
a right to access their personal information, subject to limited
exceptions. the exceptions to access can be found in section 23
of PIPA. Some examples include: solicitor-client privilege, disclosure
would reveal personal information about another individual.
7.2 A request to access personal information must be made in
writing and provide sufficient detail to identify the personal
information being sought. Broker of record
7.3 Upon request, we will also tell Clients, Customers, Members,
Associates and Lenders how we use their personal information and
to whom it has been disclosed if applicable.
7.4 We will make the requested information available within
30 business days, or provide written notice of an extension where
additional time is required to fulfill the request.
7.5 A minimal fee may be charged for providing access to personal
information. Where a fee may apply, we will inform the Clients,
Customers, Members, Associates and Lenders of the cost and request
further direction from the Clients, Customers, Members ,Associates
and Lenders on whether or not we should proceed with the request.
7.6 If a request is refused in full or in part, we will notify
the Clients, Customers, Members, Associates and Lenders in writing,
providing the reasons for refusal and the recourse available to
the Clients, Customers, Members ,Associates and Lenders
Policy 8 – Questions
and Complaints: The Role of the Privacy Officer or designated individual
8.1 The Privacy Officer OR Broker of Record is responsible for
ensuring Western Mortgage Services Inc compliance with this policy
and the Personal Information Protection Act.
8.2 Clients, Customers, Members, Associates and Lenders should
direct any complaints, concerns or questions regarding compliance
in writing to the Privacy Officer. If the Privacy Officer is unable
to resolve the concern, the Clients, Customers, Members, Associates
and Lenders may also write to the Information and Privacy Commissioner
of British Columbia.
Contact information for Western Mortgage Services Inc
Broker of Record
Western Mortgage Services Inc.
Yousra M.Jomha AMP
403-652-1997
