Calvert Home Mortgage Investment Corporation
Privacy Policy
At Calvert Home Mortgage Investment Corporation (CHMIC) we believe in building relationships with our customers based on trust and respect. As part of this commitment, and in accordance with the Personal Information Protection and Electronic Documents Act (“PIPEDA”) and the Personal Information Protection Acts in Alberta and British Columbia (“PIPA”), we want to inform you of our personal information handling practices, including the reasons we collect personal information, the security steps in place to protect your information, how we obtain consent and how you can access or correct your personal information. We acknowledge that your personal information is a valued asset and we want you to know we will treat it that way.
Personal Information is defined as information about an “identifiable individual.” This includes name, income, assets, liabilities, third-party account numbers, spending habits, marital status, employment information, education, home address, phone number, date of birth, and age. It does not cover general contact information such as title, business address or business contact information.
CHMIC is responsible for personal information under its control and has designated a Privacy Officer accountable for ensuring compliance with applicable privacy legislation. As outlined within this Privacy Policy, CHMIC ensures compliance through:
- Internal policies and procedures with regular reviews of same
- Staff Training
- Monitoring compliance
- Contractual controls over third-party service providers
- De-identification and Anonymization methods
Consent, Collection and Disclosure of Personal Information
CHMIC accepts personal information from two primary groups depending on the nature of their dealings with CHMIC:
- Borrowing – Individuals, partnerships, proprietorships and companies who may wish to borrow money from CHMIC or a related party.
- Investing – Individuals, partnerships, proprietorships and companies who wish to invest with CHMIC by purchasing one or more of our investment products.
Please refer to the appropriate section below for information regarding the information we collect, the purpose of its collection and related disclosure of this information.
1. Borrowers
Collection of Personal Information:
In order to provide you with our services, we may collect the following information about you:
- Contact and mailing information such as your name, address, home and mobile numbers, fax number and email addresses;
- Your date of birth;
- Your Social Insurance Number (optional to provide; only collected for the purpose of obtaining credit bureaus or verification of CRA tax information and not used as a general identifier);
- Employment information, income confirmation, credit information, asset information, spending habits, liabilities and financial obligations, net worth, copies of identification including photo ID, third-party account numbers and personal references;
- Education;
- Marital status;
- Information about the nature and financial situation of any company where you are a significant shareholder;
- Insurance information;
- Bank and third-party account information
- Municipal and legal descriptions of your properties;
- Audio or video recordings of telephone conversations, virtual meetings or in-person discussions when permitted by law and relevant to the provision of our services. These recordings may be stored securely for documentation, quality assurance, legal or compliance purposes; and
- Any other relevant information which is necessary to provide you with our services.
If we receive your information from a mortgage broker or other similar professionals, our Privacy Policy will apply the same as if we collected the information ourselves.
Purposes of Collection
We will only collect the personal information we require to fulfill the following purposes:
- To secure a mortgage on your behalf;
- To prepare security documents;
- To verify your identity;
- To cross reference residential and business addresses;
- To establish your credit worthiness and ability to repay;
- To assess your present and future needs;
- To establish character regarding contract completion history;
- To protect our security interests;
- To negotiate or sell our security interests;
- To identify client preferences;
- To communicate with you on our products and services;
- To contractually collect payments and the full amount of the debt, and may include SMS text messages;
- To ensure real estate insurance remains in place as part of the security package;
- To pay financial obligation to third-parties on your behalf as part of a negotiated mortgage advance;
- To process payments as part of a contract with you, and with permission;
- To de-identify and anonymize data in aggregate form for analysis purposes to improve our services and communication with you and others we serve; and,
- Any other purpose that is necessary to meet our legal or regulatory obligations.
Information Disclosure to Third-Parties
CHMIC may disclose your information to third-parties as necessary both during and after the course of fulfilling the purpose of its collection and providing our services to you, that may include but are not limited to:
- Accountants, Auditors, Lawyers, Insurers and Insurance Brokers, CHMIC Employees and Directors;
- Banks, Lenders and Creditors;
- Credit reporting agencies;
- Home Insurance, Mortgage Impairment Insurance and Title Insurance Corporations;
- Regulatory or Government bodies to meet our legal or regulatory obligations; and
- Third-Party Service Providers (ie: IT service providers, cloud storage vendors or cloud-based software systems used in the course of providing our services to you).
Obtaining Consent
We believe that part of establishing trust and integrity comes from allowing you to decide whether you wish to provide your personal information to us.
Consent for the collection, use and disclosure of personal information is required under various federal and provincial privacy legislation (PIPEDA and PIPA) unless an exception applies, and may be obtained in different ways, depending on the sensitivity of the information and your reasonable expectations. We will obtain consent through:
- The signing and dating of a credit application with a privacy policy disclosure;
- The signing of a commitment letter authorizing collection, use and disclosure with a privacy policy disclosure;
- Your authorization of a mortgage broker to release information to CHMIC on your behalf;
- Obtaining consent verbally over the telephone (noted in your file);
- An acknowledgment of your consent with a link to our privacy policy when submitting an application or a request for contact online through our website
- In all cases where telephone conversations, virtual meetings, or in-person discussions may be recorded (video and/or audio). CHMIC will obtain your explicit consent prior to initiating a recording. You will be informed of the purpose of the recording and how it will be stored, used, and retained. If you do not consent, the recording will not proceed.
2. Investors/Shareholders
Collection of Personal Information
In order to provide you with our services, we may collect the following information about you:
- Contact and mailing information such as your name, address, home and mobile numbers, fax number and email addresses;
- Your date of birth;
- Your Social Insurance Number (only collected as required by law for the purpose of reporting investment income to the Canada Revenue Agency, not used as a general identifier);
- Copies of identification, including photo ID;
- Employment, occupation, income financial assets and liabilities (net worth);
- Bank account and registered account numbers (RESP, RRSP, TFSA etc);
- Information regarding risk tolerance, investment knowledge and time horizon for investing;
- Enduring Powers of Attorney, Powers of Attorney and Trusted Individual name and contact information, as well as name and contact info for third-parties having Trading Authority on your behalf;
- Marital status
- Information about the nature and financial situation of any company where you are a significant shareholder or beneficiary;
- Audio or video recordings of telephone conversations, virtual meetings or in-person discussions when permitted by law and relevant to the provision of our services. These recordings may be stored securely for documentation, quality assurance, legal or compliance purposes; and
- Any other relevant information which is necessary to provide you with our services.
If we receive your information from an authorized investment advisor or other similar professionals, our Privacy Policy will apply the same as if we collected the information ourselves.
Purposes of Collection
We will only collect the personal information we require to fulfill the following purposes:
- To verify your identity as an individual;
- To verify the identity of any individual that is a beneficial owner or exercises direct or indirect control or direction over more than 25% of the voting rights of a corporation, or exercises control over the affairs of a partnership or trust;
- To confirm whether you are an insider of a reporting issuer or any issuer whose securities are publicly traded;
- To approve the opening of any account with CHMIC, including holding shares within a registered account;
- To assess suitability to purchase CHMIC investment products;
- To facilitate your purchase, transfer and sale of CHMIC investment products;
- To process distributions of income;
- To administer your account(s), maintain current information and provide required reporting;
- To assess if you are a politically exposed person;
- To communicate with you or your beneficiaries or trusted authority or attorney (such as under an Enduring Power of Attorney or Power of Attorney) in the administration of your account(s);
- To provide regulatory filings to Securities Regulators, FINTRAC and the Canada Revenue Agency;
- To de-identify and anonymize data in aggregate form for analysis purposes to improve our services and communication with you and others we serve; and,
- Any other purpose that is necessary to meet our legal or regulatory obligations.
Information Disclosure to Third-Parties
CHMIC may disclose your information to third-parties as necessary both during and after the course of fulfilling the purpose of its collection and providing our services to you, that may include but are not limited to:
- Accountants, Auditors, Lawyers, Financial Planning Professionals, CHMIC Employees and Directors;
- Registered Account Trustees;
- Your Designated Trusted Contact Person;
- Regulatory or Government bodies to meet our legal or regulatory obligations; and
- Third-Party Service Providers (ie: IT service providers, cloud storage vendors or cloud-based software systems used in the course of providing our services to you).
Obtaining Consent
We believe that part of establishing trust and integrity comes from allowing you to decide whether you wish to provide your personal information to us.
Consent for the collection, use and disclosure of personal information is required under various federal and provincial privacy legislation (PIPEDA and PIPA) unless an exception applies, and may be obtained in different ways, depending on the sensitivity of the information and your reasonable expectations.
We will obtain consent through:
- The signing and dating of a New Account Client Form (NCAF) with a privacy policy disclosure;
- The signing and dating of a Relationship Disclosure Information Form with a privacy policy disclosure;
- Obtaining consent verbally over the telephone (noted in your file);
- An acknowledgment of your consent with a link to our privacy policy when submitting a request for contact online through our website;
- In all cases where telephone conversations, virtual meetings, or in-person discussions may be recorded (video and/or audio). CHMIC will obtain your explicit consent prior to initiating a recording. You will be informed of the purpose of the recording and how it will be stored, used, and retained. If you do not consent, the recording will not proceed.
Withdrawal of Consent
You may withdraw your consent at any time, subject to legal or contractual restrictions and reasonable notice. To withdraw your consent, please submit a written request specifying the personal information that you are withdrawing consent for, to our Privacy Officer using the contact details below.
Please note that withdrawal of consent may affect our ability to provide certain services to you. We will notify you of the impact your withdrawal of consent will have at the time your request is received.
Safeguarding your Personal Information
Like you, we at Calvert Home Mortgage Investment Corporation (CHMIC) value your personal information. Part of valuing your personal information is ensuring it is protected and kept confidential. The following procedures are enforced to ensure your information is secure:
- Secure filing cabinets and storage areas;
- Access is restricted to secure storage and online systems to authorized employees;
- Professional shredding of documents and secure storage while awaiting shredding;
- Employee training on privacy protection;
- Use of screensavers and password protections;
- Firewalls, antivirus software and encryption for digital data;
- Frequent password changes and hard-drive erasure before disposal;
- Ongoing review and updates to hard copy and digital files;
- Audio or video recordings are stored in encrypted formats with access restricted to authorized personnel. Recordings are retained only as long as necessary for the purposes identified and are subject to the same retention and destruction protocols as other personal information.
- Where third-party service providers are engaged to process or store personal information on our behalf, the following actions are taken:
- An assessment is undertaken to confirm that the service provider has policies and processes in place, including employee training, privacy policy, and effective security measures to ensure information is properly safeguarded;
- They are contractually required to provide comparable protection of the information including only-as-needed employee access, and to only use the information for the purpose for which it is transferred to them; and,
- As part of our annual internal controls review, these third-party service providers are monitored, with an annual review of their most recent security documentation.
Cross-Border Transfers of Personal Information
In compliance with PIPEDA and PIPA, we advise you that in the course of providing services to you, your personal information may be collected, used, stored or processed outside Alberta or Canada by CHMIC or our third-party service providers. When this occurs, your information may be subject to the laws of those foreign jurisdictions and may be accessed by their courts, law enforcement or national securities regulators.
CHMIC endeavours wherever possible to have the information we collect, store or transfer to a third-party service provider for processing, remain within Canadian borders. Incorporated into our assessment of third-party service providers, is to examine their data residency practices and where possible give preference to those providers that have Canadian data centres. However, even providers that host the data in Canada may find it necessary for support, back-ups or redundancy purposes or to support certain processing features within their platforms, to have the data transferred outside of Canada to jurisdictions including but not limited to the US, UK and Australia. In addition, it is possible that the commercial system or application deemed most effective to enable us to provide our services to you requires the cross-border transfer or storage of information or data.
CHMIC remains accountable for your personal information and takes this responsibility seriously. As such, and as noted in the ‘Safeguarding Your Personal Information’ section, to fulfil this responsibility, we conduct an assessment of all third-party service providers to ensure they are providing a comparable level of protection to Canadian practices by way of a review of their security and encryption practices, data residency, sub-processors and internal training and privacy policy along with a review of their security assessment documentation.
If we are satisfied that the provider can provide a comparable level of protection of your information, our primary method to secure this compliance is in the form of a contract. While the form of contract may differ between third-party services providers, these contracts confirm their obligations regarding safeguarding, storage and access to the information, holds them to their own practices and provides the ability to exercise the right to audit or inspect their practices when warranted and with reasonable notice.
You may request further information about our policies and practices, including the name or position of a contact person who can respond to your questions, by contacting our Privacy Officer.
Updating and Accuracy of your Personal Information
Calvert Home Mortgage Investment Corporation (CHMIC) will do its best to ensure that your personal information is accurate, complete and kept current. We will accomplish this by:
- Contacting you to verify information before making decisions or taking action;
- Using credit bureaus and public databases as applicable, to confirm accuracy;
- Relying on your due diligence to notify us of changes or errors; and,
- Obtaining updates or confirmation of information prior to entering into a new borrowing or investing transaction, as applicable.
Retention of Information
We retain information only as long as necessary to fulfill the stated collection and usage purposes or to meet legal or regulatory obligations as outlined below:
- For Borrowers, personal information will be retained for a minimum of 7 years from payout and not longer than 8 years;
- For Applicants who have been declined or withdrawn their application, personal information will be retained for a minimum 7 years from the date of decline or withdrawal, and not longer than 8 years; and
- For Investors or Shareholders who have applied to open an account for the purpose of purchasing one or more of CHMIC’s investment products, personal information is retained for a minimum 7 years after the later of: the date of the original application/ inquiry or the date the account is closed.
Destruction of Information
To ensure that information is properly destroyed the following destruction procedures include:
- Date stamping hard copy files when declined or paid in full;
- Labelling of electronically stored files with a decline, paid out or account closed date (as applicable);
- Removal of information in systems or databases that does not require retention once the purpose for its collection or use or any legal, reporting or regulatory need has been fulfilled;
- Annual destruction cycle triggered via automated or manual diary systems (as applicable) for both physical and digital files; and,
- Rendering the information non-identifying (anonymized and/or de-identified) so that it can no longer be used to identify an individual but can be used for statistical and business analysis purposes, particularly in aggregate.
Requests for Access to Personal Information
You may submit a request in writing to CHMIC’s Privacy Officer to obtain:
- A record of your personal information under our custody or control;
- The purpose for which we are using such personal information; and
- The names of person(s) to whom your information may be disclosed and the circumstances under which this will occur.
Please note that a nominal fee may be charged based on the volume of the information requested.
Requests for Correction of Personal Information
You may submit a written request to CHMIC’s Privacy Officer, to correct errors or omissions in your personal information that are under our custody or control. When provided with a written request, CHMIC may either:
- correct the personal information and, if reasonable to do so, send correction notifications to any other firm or service provider to whom we previously disclosed such information or,
- decide not to correct the personal information but annotate the personal information that a correction was requested but not made.
Access, Inquiries, Requests and Complaints
As outlined above, you have the right to access, verify or correct your personal information in addition to making an inquiry or complaint about our privacy practices. Should you wish to do so, please contact our Privacy Officer at the contact details below:
Privacy Officer: Dale Koeller
Phone: 1.403.278.0249
Toll Free: 1.888.752.4642
Fax: 1.403.225.0549
Email: admin@chmic.ca
All inquiries, requests and complaints will be referred to the Privacy Officer who shall acknowledge the inquiry within 48 hours.
The Privacy Officer will complete the full response to any inquiries or requests within 45 days as required by PIPA or 30 days under PIPEDA, as appropriate, subject to any permissible extensions.