- The Ten Principles of Privacy
- Application of the Ten Principles
- The kind of information we collect
- How we use your information
- When can we disclose your personal information?
- Who we share your information with
- How we safeguard your information
- Accessing your personal information
- Opting Out
Centract provides a variety of products and services to appraisers, mortgage lenders, Lawyers and the public. The Services include, but are not limited to, providing real property appraisal, legal document management, debt recovery, refinance and transfer mortgage document preparation and processing, software development and customer relationship management services. In addition to these services, we also provide desktop software and web-based technology products to mortgage lenders, lawyers and appraisers.
In the course of providing these products and services, Centract may collect certain personal information about borrowers.
“Personal Information” means information about an identifiable individual client. This may include without limitation, the individual’s name, address, age, gender, income, employment status, credit history, debts and liabilities, income, personal preferences and other information about his or her family. Personal information does not include the name, title or business address or telephone number of an employee of an organization.
The Ten Principles of Privacy
The following ten principles govern our actions as they relate to the use of our clients’ personal information:
Principle 1 – Accountability
Centract is accountable for all personal information in its possession or custody, including personal information disclosed to third parties for purposes of providing services requested by our clients or employees.
Principle 2 – Identifying Purposes
Centract relies upon such financial institutions, all of whom are bound by PIPEDA, to obtain their customers’ consent or rely upon an exemption to PIPEDA, before providing Centract Settlement Services with their customers’ personal information. Centract informs its clients of the purposes for which it is collecting any personal information, before or at the time the information is collected.
Principle 3 – Consent
Centract will obtain consent from its clients before or when it collects, uses or discloses their personal information.
A client’s consent can be express, implied, or given through an authorized representative. A client can withdraw consent at any time, with certain exceptions. Centract, however, may collect, use or disclose personal information without the client’s knowledge or consent in exceptional circumstances where such collection, use or disclosure is permitted or required by law.
Principle 4 – Limiting Collection
The information collected from the client will be limited to those details necessary for the purposes it has identified to the client. Information will be collected by fair and lawful means.
Principle 5 – Limiting Use, Disclosure and Retention
Personal information will only be used or disclosed for the purpose for which it was collected unless the client and the individual forming the subject of the personal information has otherwise consented, or when it is required or permitted by law. Personal information may only be retained for the amount of time needed to fulfil the purpose for which it was collected or to fulfil contractual obligations with respect to record retention.
In certain exceptional circumstances, Centract have a legal duty or right to disclose personal information without client knowledge or consent with respect to matters that concern the company’s or the public’s interest.
Principle 6 – Accuracy
Centract will keep personal information as accurate, complete and current as necessary to fulfil the identified purposes for which it was collected. Clients may have this information amended where it is found to be inaccurate or incomplete.
Principle 7 – Safeguarding Personal Information
Personal information is safeguarded using measures appropriate to the sensitivity of the information. See “How We Safeguard Information” below.
Principle 8 – Openness
Centract will make information available to its clients and the general public about the policies and procedures Centract uses to manage personal information. Clients and the general public have access to this information through our web sites, or through alternate means if requested.
Principle 9 – Client Access
Upon written request, a client will be informed of the existence, use and disclosure of their personal information, and will be given access to it. Centract Settlement Services will respond to such requests as efficiently as possible. If Centract is prohibited from providing such access they will explain the reasons for the lack of access, except where prohibited by law.
Principle 10 – Addressing Client Complaints and Suggestions
Application of the Ten Privacy Principles – How we treat your personal information:
The kind of information we collect
Centract gathers and uses personal information in order to provide its clients with the products and services they have requested. Providing us with personal information is a choice made by your financial institution, however, we may not be able to provide you or our financial institution clients with certain products or services if we are not provided with certain information. For example, we cannot provide appraisal or legal services if we do not know where you live.
The nature of our client’s product or service request will determine the kind of personal information we might ask for.
Information that is typically required to provide our products and services includes:
- Phone number(s)
- Approximate market value of the property being purchased/re-financed/transferred
- Address of the property being purchased/re-financed/transferred
- Specific financing details related to potential loans are sometimes collected
- Documentation created and processed in connection with transactions that are stored as a disaster recovery service for law firms using certain of our software packages
Centract may keep a file with your contact history to be used for client inquiry or disaster recovery purposes.
How Your Information Is Used
At Centract we use personal information for three general purposes:
- To communicate with you in order to provide our products and services. Some services may be provided by third party suppliers (such as appraisers or lawyers) to better serve your needs.
- Transactional information to monitor our level of service and report back to our clients to ensure satisfaction with the provision of such services.
- Disaster recovery protection.
We will only use personal information for the purpose that we have disclosed to our clients. If we want to use your information for a different purpose, we will notify you and our clients and obtain consent first.
When Can We Disclose Your Personal Information?
Centract is obliged to keep your personal information confidential except under the following circumstances:
When Authorized by our Clients
Many of the services offered by Centract require us to obtain personal information about you in order to perform the services we have been engaged to provide. We will use this information to tailor programs to meet our clients’ needs and objectives. We will always obtain consent, and we will never use the information for purposes other than those we have told our clients about.
For example, if we are going to provide an appraisal on your home we will need to obtain information about your telephone number or address. You may withdraw your consent at any time, subject to any legal implications (which we will inform you or your financial institution about). If you withdraw your consent to use or disclose certain personal information Centract may be unable to continue to provide all or part of the services requested.
When Required by Law
The type of information we are legally required to disclose usually relates to government tax reporting requirements. However in some cases, such as under a court order, we may be required to disclose certain information to persons specified in the court order. We will only provide the specific information requested and only upon being satisfied that the authorities have legitimate grounds to request the information.
When Permitted by Law
The legislation has provided certain situations where Centract is legally permitted to disclose personal information without your consent. Examples include situations involving the collection of debt in arrears, medical emergencies, or suspicion of illegal activities.
With Whom We May Share Your Information
Unauthorized use or disclosure of confidential client information by a Centract employee is prohibited and may result in disciplinary measures.
In order to better serve our clients, we may share some of your personal information with our affiliates. We will only do this with your express consent and you may withdraw this consent at any time. The procedure for withdrawing consent is outlined below under the section “Opting Out”.
Centract Third Party Suppliers
As you may know, we often engage and coordinate third party suppliers to provide certain services offered through Centract. We use third party suppliers to provide appraisal, legal and debt recovery services.
How We Safeguard Information
Centract has extensive controls in place to maintain the security of its information and information systems. Client files are stored according to the sensitivity of the information contained therein.
Centract uses network security tools, such as firewalls to safeguard personal information. We also use unique identifiers to identify, authenticate and authorize any employees, who can access, view or handle your personal information. We use a minimum of 128-bit encryption to store information and we encrypt data when we transport or communicate information on open communication channels to another party.
Physical access to areas where personal information is gathered, processed or stored is limited to authorized employees.
When you telephone a Home Inspection Network employee to speak about your file, you may be asked for some personally identifying information. This type of safeguard is designed to ensure that only you, or someone authorized by you, has access to your file.
Accessing and Amending Your Information
As a client, you have the right to access the personal information we keep in your file and you have the right to verify or amend the information if it is shown to be inaccurate. If you would like to view the personal information held in your file or to make a change to that information, please make a written request by sending an e-mail to email@example.com. We will respond to your request as efficiently as possible.
To make a change, please make a similar request in writing to the Privacy Officer.
Opting – Out
In order to provide you with our services and products, Centract will, with your consent, share your personal information with other Centract affiliates. Should you not want to receive promotional materials from or have your personal information shared with these companies please contact Centract at firstname.lastname@example.org.
Anonymous Information and “Cookies”
Centract may collect anonymous information about you. This means that the information collected cannot be traced back to a specific person. For example, our web servers may record certain information automatically when you visit Centract web sites. This information is collected using “cookies” and might include the pages you visited, your IP (Internet Protocol) address and other site usage statistics. This anonymous information is used for research and analytical purposes only (like evaluating how many visitors our web sites receive or which pages they visit most often). It does not reveal any personal information about you, the user. This aggregate data may be disclosed to third parties, but never with personally identifying information.
Cookies do not disclose the individual identity of a site user and cannot be used to collect sensitive information about your computer or data residing on your computer. Most major web sites use this technology and most browsers are set up to accept them.
You may configure your browser to notify you when you receive a cookie, and you may refuse to accept them entirely. However, if you refuse to accept cookies, you may limit the functionality that we can provide to you when you visit our site. For example, the www.centractworx.ca web site requires cookies to recognize clients with valid access to the database. If your browser does not accept cookies, the site will not grant you access via the login and password.