About Paramount Mortgage Capital Mortgage and PIPEDA
Paramount Mortgage Capital Edmonton (“Paramount Mortgage Capital “) offers full service mortgage banking that originates, underwrites, structures, and administers institutional quality mortgage investments on behalf of clients. In the course of their businesses, we collect, use and share among themselves and in certain instances provide to third parties personal information.
PRINCIPLE 1 – ACCOUNTABILITY
PRINCIPLE 2 – IDENTIFYING THE PURPOSES
2.1 Identifying Purposes. Except for situations described in section 3.3, Paramount Mortgage Capital will identify the purposes for which it collects personal information, before or when the information is collected.
2.2 Explaining the Purposes. Paramount Mortgage Capital will generally identify the purposes for which it intends to use the personal information, in writing, orally in person or over the telephone or electronically. Paramount Mortgage Capital staff who collect personal information will be able to explain these purposes to you. In some cases the purposes for collecting personal information are obvious and will not be explained. However, you will always be entitled to ask and receive answers about such purposes.
2.3 General Purposes. Paramount Mortgage Capital uses your personal information to communicate with you, understand our borrower clients’ needs, analyze the suitability of our products or services for our borrower clients, process applications, solicit our lender clients to offer credit to our borrower clients, determine our borrower clients’ eligibility for products and services, offer, set up, manage and administer products and services, provide ongoing services to our clients and generally fulfill our legal and regulatory requirements. Paramount Mortgage Capital may, from time to time, contact you on behalf of external business partners about a particular offering that may be of interest to you. In those cases, your personal information is not transferred to the third party. Paramount Mortgage Capital may survey your opinions of current products or services or of potential new products or services that may be offered.
2.4 Credit Purposes. In connection with credit products and services, we and our lender clients need to know an individual’s creditworthiness. For this reason, Paramount Mortgage Capital may contact other lenders or credit bureaus to give us information on an individual’s credit history. Paramount Mortgage Capital may also contact employers or other personal references to verify information that has been given to us by the individual. Credit information is reported to credit bureaus, credit reporting agencies, credit insurers, and other lenders, to maintain the integrity of the credit-granting process. Your Social Insurance Number is used to match credit bureau information.
2.5 Insurance Purposes. In connection with insurance products and services, we, our lender clients and third party insurers need to know personal health information about you for the purpose of approving or declining a request. Personal health information is reported to the information bureau to maintain the integrity of the underwriting record. Personal health information will not be made available to others nor used for any other purpose, such as assessing a loan application.
2.6 Sale of Business. As Paramount Mortgage Capital continues to develop and grow, it may buy or sell parts of its business. As an important part of Paramount Mortgage Capital’s business includes customer relationships, personal information would generally be one of the transferred business assets.
PRINCIPLE 3 – CONSENT
3.1 Obtaining Your Consent. Paramount Mortgage Capital will make a reasonable effort to ensure you understand how your personal information will be used by Paramount Mortgage Capital. Generally, Paramount Mortgage Capital will obtain consent from you before or when it collects or uses your personal information. Sometimes Paramount Mortgage Capital may identify a new purpose and it will seek your consent to use and disclose personal information for that purpose after the information has been collected. If Paramount Mortgage Capital is seeking to collect personal information from you which is not required in order for us to provide a product or service to a client, Paramount Mortgage Capital will indicate that you are not required to provide it with such information.
3.2 Forms of Consent. An individual’s consent can be express or implied. Consent may be given through an authorized representative. Consent may be implied through action or inaction, such as by using or applying for a product or service offered by us or not responding to an offer to have your personal information removed from a list. Express consent is the preferred form. Express consent may be given orally, in writing or electronically. Before deciding what form of consent is appropriate, Paramount Mortgage Capital will consider the type of personal information it needs, the reason for its use, and the type of individual contact that is involved.
3.3 Where Consent Unnecessary. Paramount Mortgage Capital may collect, use or disclose personal information without your knowledge or consent in exceptional circumstances where such collection, use or disclosure is permitted or as required by law. For example, Paramount Mortgage Capital will not ask for consent when personal information is collected, used, or disclosed in the following instances:
(a) where it is in your best interests and consent cannot be obtained in a timely way;
(b) where personal information is given to our legal representatives;
(c) where personal information is given to a person who in the reasonable judgment of Paramount Mortgage Capital is seeking the information as your agent;
(d) where personal information is given to agents of Paramount Mortgage Capital who need it to carry out business-related functions, such as product and services fulfillment, data processing, loans adjudication and insurance underwriting;
(e) when asking for consent may compromise the information sought and collection relates to an investigation of a breach of an agreement or a contravention of a law;
(f) to protect and defend Paramount Mortgage Capital’s rights or property;
(g) where personal information is disclosed for the purpose of collecting a debt, complying with a subpoena or warrant, responding to a lawful authority for lawful purposes, complying with the law;
(h) where PIPEDA permits personal information to be disclosed without obtaining your consent; and
(i) when Paramount Mortgage Capital obtains individual lists from another organization governed by PIPEDA, Paramount Mortgage Capital presumes that the organization obtained each individual’s consent before disclosing the information to Paramount Mortgage Capital.
3.4 Refusing to Consent. Subject to legal and contractual requirements, you can refuse to consent to our collection, use or disclosure of information about you, or you may withdraw your consent to our further collection, use or disclosure of information at any time in the future by giving us reasonable notice. If you refuse or withdraw your consent, Paramount Mortgage Capital may not be able to provide you or continue to provide you with some products, services or information which may be of value to you. During the term of a loan or credit arrangement, you may not withdraw your consent to our ongoing collection, use or disclosure of your personal information in connection with the loan or other credit arrangement you have with our lender client or have guaranteed. Paramount Mortgage Capital can continue to disclose such personal information to credit bureaus even after the loan or credit arrangement has been retired, and you may not withdraw your consent to our doing so. Paramount Mortgage Capital does this to help maintain the accuracy, completeness and integrity of the credit reporting system.
3.5 General Information We Collect. The types of information Paramount Mortgage Capital may collect about you depends on the nature of the product or service being provided to our clients. Typical information that Paramount Mortgage Capital collects includes your name, gender, marital status, family information and history, mailing address, e-mail address, phone number(s), date of birth, birth certificate information, banking information, such as bank account number(s), place and details of employment, annual income, net worth information, credit history, past loan transaction history and Social Insurance Number. In cases where insurance products and services are involved, Paramount Mortgage Capital may also collect personal health information where permitted by law. Paramount Mortgage Capital may also request additional information to help us provide you with advice and information about other products and services that Paramount Mortgage Capital believes would interest you.
3.6 Credit Information. Our lender clients routinely require us to provide personal credit and financial information. To comply with these requests, Paramount Mortgage Capital requires your consent. Paramount Mortgage Capital usually obtains this permission in a mandate letter, which you sign upon the commencement of our relationship with the borrower client. In other cases, your consent to the use and/or disclosure of your personal information will be obtained verbally or electronically or may be implied from the circumstances.
3.7 Marketing Additional Products and Services. Paramount Mortgage Capital may want to use personal information (except for personal health information) to market products and services to you, either directly or through other Members or third parties. Paramount Mortgage Capital will obtain your consent before using personal information for this purpose.
PRINCIPLE 4 – LIMITING COLLECTION
4.1 Limiting Collection. Paramount Mortgage Capital will limit the collection of personal information to that which is necessary for the purposes it has identified to you, using means which are fair and lawful.
4.2 Sources for Information. Although Paramount Mortgage Capital will collect your personal information primarily from you, it may also collect it from external sources such as credit bureaus, references, employers, personal property and land titles registries and other government agencies, other lenders, and with regards to insurance products, medical information bureaus, brokers, insurers, advisory organizations, underwriting and claims information networks, and attending physicians.
PRINCIPLE 5 – LIMITING USE, DISCLOSURE AND RETENTION
5.1 Limiting Use and Disclosure. Paramount Mortgage Capital will use or disclose personal information only for the purposes it was collected, unless you give further consent to use or disclose it for another reason, or it is permitted or required by law.
5.2 Exceptions. Under certain circumstances including those set forth in section 3.3, Paramount Mortgage Capital has a legal duty or right to disclose personal information without the individual’s knowledge or consent.
5.3 Retention Policies. Paramount Mortgage Capital retains personal information only as long as it is required for the reasons it was collected. The length of time personal information is retained varies depending on the purpose for which the information was collected. This period may extend beyond the end of your relationship with Paramount Mortgage Capital but only for so long as it is legally necessary for Paramount Mortgage Capital to have sufficient information to respond to any issue that may arise at a later date. When your information is no longer needed for the purposes for which is has been collected, Paramount Mortgage Capital has procedures to destroy, delete, erase or convert it to an anonymous form.
PRINCIPLE 6 – ACCURACY
6.1 Keeping Information Accurate. Paramount Mortgage Capital will keep your personal information as accurate, complete and up-to-date as necessary for the purposes for which it is used. Paramount Mortgage Capital will update personal information only if it is necessary for the purposes for which it was collected and if the information is used on an ongoing basis. Paramount Mortgage Capital will also rely on you for keeping certain personal information accurate, complete, and current, such as a change in address.
6.2 Errors May Occur. Despite our efforts, errors sometimes do occur. Should you identify that a Member holds incorrect or out-of-date personal information about you, Paramount Mortgage Capital will make the proper changes and provide you with a copy of the corrected information. Where appropriate, Paramount Mortgage Capital will communicate these changes to other parties who may have unintentionally received incorrect personal information from Paramount Mortgage Capital.
PRINCIPLE 7 – SAFEGUARDING PERSONAL INFORMATION
7.1 Safeguarding Information. Paramount Mortgage Capital will protect personal information with security safeguards appropriate to the sensitivity of the information to protect personal information against loss or theft, unauthorized access, disclosure, copying, use, or modification. Paramount Mortgage Capital’s safeguards vary depending on the information’s sensitivity, amount, distribution and format of the information and the method of storage. Paramount Mortgage Capital uses a variety of security technologies and procedures to help safeguard your personal information. For example, personal information which Paramount Mortgage Capital holds electronically is on password protected computer systems with limited access that are located in controlled facilities. Paper-based files are kept in controlled facilities and access is restricted on a need to know basis. All security measures are appropriate to the sensitivity level of your information.
7.2 Staff Compliance. Paramount Mortgage Capital informs its staff about the importance of maintaining the confidentiality of personal information. As a condition of employment, Paramount Mortgage Capital’s staff are required to abide by its policies and procedures and they are prohibited from disclosing any personal information except as is necessary to carry on their employment duties.
7.4 Disposing of Information. Care is used by Paramount Mortgage Capital when disposing of or destroying personal information, to prevent unauthorized access to the information.
PRINCIPLE 8 – OPENNESS
PRINCIPLE 9 – INDIVIDUAL ACCESS
9.1 Access to your Information. Upon written request, Paramount Mortgage Capital will inform you of the existence, use, and disclosure of your personal information and will afford access to that information upon payment of any applicable charges. You are entitled to challenge the accuracy and completeness of the information and have it amended as appropriate.
9.2 Exceptions to Access. Please note that Paramount Mortgage Capital may not be able to provide information about you if it (i) would reveal personal information about a third party, (ii) is subject to legal privilege, (iii) contains other confidential information which would be revealed, (iv) is information that was generated in the course of a formal dispute resolution process, (v) relates to an investigation of a breach of agreement or contravention of laws, (vi) cannot be disclosed for other legal or security reasons, or (vi) is prohibitively costly to provide.
PRINCIPLE 10 – CHALLENGING COMPLIANCE