At Origination Mortgage Corp., protecting the privacy and confidentiality of our clients' personal information is of the utmost importance. As a provider of financial products and related services, we are committed to fair and lawful collection and maintenance of accurate personal information.
Personal information is information that enables us to identify our clients. It includes name, address, age, social insurance number, personal references, personal financial records and employment records Origination Mortgage Corp. upholds the following privacy principles delineated in the Canadian National Standards in "A Guide for Businesses and Organizations. Your Privacy Responsibilities: privcom.gc.ca/information/guide_e.asp
Principle 1 - Accountability
Principle 2 - Identifying the Purpose
The information we collect will be used solely for the identified purposes. We collect personal information to better serve our clients. Personal information is required in order to:
- Open an account
- Verify creditworthiness
- Identify client's preferences
- Establish client's eligibility for special offers and discounts
- Administer our financial services properly
Principle 3 - Obtaining Consent
We inform our clients of the purposes for the collection, use or disclosure of personal data.
Our consent clauses are:
- easy to find;
- use clear and straightforward language;
- do not use blanket categories for purposes, uses and disclosures;
- They are as specific as possible about which organizations handle the information
Principle 4 - Limiting Collection
We identify the type of personal information we need in our policies and practices. We also limit the amount and type of information gathered to what is necessary for the identified purposes.
Principle 5 - Limiting Use, Disclosure and Retention
Origination will retain the personal information only for the time it is required for the outlined purposes and for a reasonable period thereafter in case of any potential legal or government obligations. Information that does not have a specific purpose or that no longer fulfills its intended purpose will be disposed e.g. paper files will be shredded and electronic records will be deleted.
Principle 6 - Accuracy
We maintain personal information as accurate, complete and up to date as necessary, taking into account its use and the interests of the client. We rely on our clients for dis- closing all material information and informing us of any relevant changes.
Principle 7 - Using Appropriate Safeguards
We have established appropriate safeguards (e.g. physical, technological and organizational controls) aimed at protecting personal information. In addition, we make our employees aware of the importance of maintaining the security and confidentiality of personal information. We hold regular staff training meetings to ensure that our employees are aware of security safeguard considerations.
Principle 8 - Openness and Transparency
Principle 9 - Allowing Individual Access
We will respond to the client's request as quickly as possible and no later than 30 days after receipt of the request. We may charge a nominal fee for processing which will be communicated to the client in advance. In addition, any denial of request for access to personal information will be communicated in writing.
When a client successfully demonstrates the inaccuracy or incompleteness of personal information, we will amend the information promptly.
Principle 10 - Providing Recourse
If the Customer Service Representative is unable to resolve the matter to the client's satisfaction, the client should direct any queries to Origination Mortgage Corp.'s Privacy Officer at the address listed below.
Origination Mortgage Corp. Inc.
278 Mathison Place, Kelowna, BC
The Privacy Officer will acknowledge receipt of the letter, as well as record the date and the nature of the issue. The clients will be notified of the outcome of investigations clearly and promptly, informing them of any relevant steps.
If the above steps still fail to resolve the client's concern, the issue may be elevated to the Privacy Commissioner of Canada who may be contacted at the address listed below.
The Privacy Commissioner of Canada 112 Kent Street
Exceptions to "No Collection Without Consent" Rule
- if it is clearly in the individual's interest and consent is not available in a timely way;
- if knowledge and consent would compromise the availability or accuracy of the infor- mation and collection is required to investigate the breach of an agreement or contraven- tion of a federal or provincial law;
- if it is publicly available as specified in the regulations Exceptions to "No Use Without Consent" Rule
- if we have reasonable grounds to believe the information could be used when investi- gating a contravention of federal, provincial or international law and the information is used for that investigation;
- for emergency that threatens an individual's life, health or security;
- for statistical or scholarly study or research (Origination Mortgage Corp. will notify the Privacy Commissioner of Canada before using this information);
- if it is publicly available as specified in the regulations;
- if the use is clearly in the individual's interest and consent is not available in a timely manner;
- if knowledge and consent would compromise the availability or accuracy of the infor- mation and collection was required to investigate the breach of an agreement or contra- vention of a federal or provincial law Exceptions to "No Disclosure Without Consent" Rule
- to a lawyer representing Origination Mortgage Corp.;
- to collect a debt that the individual owes to Origination Mortgage Corp.;
- to comply with a subpoena, a warrant or an order made by a court or other body with appropriate jurisdiction;
- to the Financial Transaction and Reporting Analysis Centre of Canada (FINTRAC) as required by the Proceeds of Crime (Money Laundering) and Terrorist Financing Act;
- to a government institution that has requested the information, identified its lawful au- thority to obtain the information, and indicates that disclosure is for the purpose of en- forcing, carrying out an investigation, or gathering intelligence relating to any federal, provincial or foreign law; or suspects that the information relates to national security, the defense of Canada or the conduct of international affairs; or is for the purpose of admin- istering any federal or provincial law;
- to an investigative body named in the Regulations of the Act or government institution on Origination Mortgage Corp.'s initiative when the Origination Mortgage Corp. has reasonable grounds to believe that the information concerns a breach of an agreement, or a contravention of a federal, provincial, or foreign law, or suspects the information relates to national security, the defense of Canada or the conduct of international affairs;
- if made by an investigative body for the purposes related to the investigation of a breach of an agreement or a contravention of a federal or provincial law;
- in an emergency threatening an individual's life, health, or security (the organization must inform the individual of the disclosure);
- for statistical, scholarly study or research (the organization must notify the Privacy Commissioner before disclosing the information);
- to an archival institution;
- 20 years after the individual's death or 100 years after the record was created; * if it is publicly available as specified in the regulations;
- if required by law
Disclosure of Personal Information Outside of Origination Mortgage Corp.
Following the client's consent, the most frequent reason for release of personal information relates to the exchange of information in the course of our business activity. For example, we exchange personal information with Canada Customs and Revenue Agency, credit bureaus, credit granters, credit insurance companies as well as other financial companies that invest in or fund our mortgages or provide financial services.
No personal information will be sold, rented or disclosed to an outside party except as consented by a client.