What is Personal Information?
Why All Ontario Financial Consultants Ltd. Collects Personal Information
AOFC 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 AOFC 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
- Other specific purposes which are communicated to the Client by a member of AOFC 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 the 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 client’s financial worth as well as the client’s’ 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.
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 All Ontario Financial Consultants Ltd. Collects Personal Information”. Under certain circumstances, AOFC 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 AOFC, witnesses in 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 AOFC 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 AOFC 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 Clients tells us otherwise
- Where it is necessary to pull a credit bureau for purposes of processing a mortgage transaction
- Protection of AOFC’s best interest;
- protection of public interest 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
AOFC 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 by our governing regulatory bodies and/or any other legal requirement, statutory or otherwise, from time to time.
AOFC 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.
AOFC endeavors to maintain adequate safeguards to protect against loss, theft, unauthorized access, disclosure, copying, use or modification of Client’s Personal Information in the care of AOFC. AOFC 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 AOFC. 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.
Communicating with AOFC
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 email. Our emails are sent with industry standard 128-bit encryption. Such encryption however does not guarantee privacy and security as encrypted messages can nonetheless be subject to interception and translation. IF clients do not wish us to communicate by email, they may speak with the consultant/broker/agent handling the matter about alternative arrangements.
Agent and Office 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 at AOFC. Once a file is complete, any un-required documentation will be returned the the client immediately.
It should be noted that all files are the property of AOFC. Although brokers and agents may retain data for marketing purposes, the clients belong to AOFC.
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.