Privacy
Statement
As a member of the Manitoba Association
of the Appraisal Institute of Canada (the “AIC”),
Hoffer Wilkinson & Associates Ltd. is committed
to respecting the confidentiality and privacy of
personal information provided to us by our employees
and by our clients. We have adopted the ten privacy
principles set out in the Canadian Standards Association Model
Code for the Protectionof Personal Information and
embodied in the Personal Information Protection
and Electronic Documents Act (“PIPEDA”).
We observe our obligations under PIPEDA, under
provincial legislation in effect in Manitoba, and
under such other applicable provincial privacy
laws, which are substantially similar to PIPEDA
as may come into force from time to time. We will
collect, use and disclose personal information
only for such purposes and to such extent as is
necessary to enable us to provide our services
as professional real estate appraisers and to fulfill
our roles as active members of the AIC.
Definition of Personal Information
Personal information is information about an
identifiable individual but does not include the
name, title or business address or telephone number
of an employee of a business. Personal information
includes personally identifiable information such
as a person’s home address and residential contact
information, age, gender, income, credit rating,
financial information, consumer preferences, health
status and political affiliations.
Purposes of Use of Personal Information
We collect personal information for the sole
purpose of enabling us to perform independent real
estate appraisals for our clients. In the course
of performing these services, we will require the
name, address (including both business and home
addresses on occasion), business, cell, fax and home
telephone numbers and email addresses of identifiable
individuals. We may also require in certain circumstances
information relating to the purchase price paid for
real property, the details of any real estate transaction
relating to a subject property, details of any lease
transaction and documentation relating to a subject
property, financial information relating to repairs
or renovations on a subject property, individual credit
history, income and other sensitive financial personal
information of identifiable individuals.
Manner of Collection, Use and Disclosure
of Personal Information
As noted above,
we will only collect, use and disclose personal
information for the purposes of providing services
to our clients, and for purposes ancillary thereto,
such as billing and collection of accounts in respect
of which credit has been extended. We will collect
personal information in personal interviews, from letters
of instruction, from order forms, from financial institutions
and from other business contacts or real estate agents.
By providing us with such information, individuals
are deemed to consent to its use for the purposes
set out herein. When we require sensitive financial
personal information, or other information of a
particularly sensitive nature, we will seek to confirm
that consent was given for the disclosure of such information
prior to collecting, using or disclosing such information.
We
will not use personal information for any other or
secondary purpose. Specifically, we will not provide
personal information, either by way of sale or other
disclosure, to any marketing agency, mail house,
data processing agency or any other promotional entity
or third party without express written consent. We
will not collect information which we do not require
in the course of providing our services.
Retention and Disposal of Personal Information
We will not retain personal information longer
than is necessary for the purposes of serving our
clients hereunder and as otherwise required by
legislation. Specifically, certain appraisals are made
for mortgage lending purposes and for tax valuation
purposes and accordingly, we retain such information
and personal information forming the basis of such
information for periods equal to the reassessment limitations
periods imposed by tax legislation, to comply with
our insurance requirements, and as otherwise required
to comply with applicable laws. In general, we
will retain client files and personal information therein
for a period of seven years, after which time we
will no longer need to retain such information.
When we no longer have any use for the personal information,
we dispose of it by having it shredded or destroyed
in the case of physical files and documents, and
by erasing the files from our hard drive or other
storage medium in the case of electronic data files.
Protection and Security of Personal Information
We have implemented policies and procedures
to ensure that personal information is protected
from unauthorized access, use, tampering, loss
or disclosure. Firstly, only those who will be involved
in the provision of the services will have access
to personal information. Secondly, all personal
information which is retained on our computers will
be stored in secure folders and will not be available
for general access in our organization. All computer
and information systems with internet access will be
equipped with firewalls, antiviral software and power
source back up to ensure the security and integrity
of your personal information.
In the event that we
require the services of third parties and need to
provide personal information to such third party for
the purposes of providing our services, we will first
confirm that consent has been provided to so disclose
the information. Upon confirming the relevant individual’s
consent, we will not provide such information until
we receive reasonable assurances from any such third
party that they have in place a privacy policy which
is substantially similar to this policy.
Review of Accuracy of Personal Information
on File
If an individual has a concern
with the accuracy or contents of their personal
information which we have on file, such individual
may contact our privacy officer to request particulars
of his or her personal information. Any such request
must be made in writing and addressed to the privacy
officer at the address set out below. The privacy officer
shall review such request and endeavour to respond
within 30 days. The privacy officer may refuse
to provide this information to the individual if so
providing it would result in disclosure of personal
information about a third party who has not consented
to such disclosure. The privacy officer may also
refuse to provide such information where such information:
is protected by solicitor-client privilege; cannot
be separated from confidential commercial information;
the disclosure of which would result in the breach
of an agreement or of a law of Canada or one of
its provinces. The privacy officer may request that
the individual provide documentation or evidence to
support the challenge to the accuracy of the personal
information on file. The privacy officer reserves the
right to review such documents and evidence and shall
upon being convinced of error or inaccuracy, amend
the individual’s personal information accordingly.
Privacy Officer
In order to review
personal information, to express any concern relating
to privacy or review our compliance with this privacy
policy or any relevant federal or provincial privacy
legislation, an individual may contact us by mail,
email or telephone at the contact information set
out below:
Hoffer Wilkinson & Associates Ltd.
Attention: Greg
Wilkinson
Privacy Officer
202 – 611 Corydon Avenue
Winnipeg, MB, R3L 0P3
Email gwilkinson@hofferwilkinson.com
Telephone (204)
452-3334
More general information may
be found on the website of the Information and
Privacy Commissioner of Canada at www.privcom.gc.ca.
The Commissioner can be reached by mail at 112 Kent
Street, Ottawa, Ontario, K1A 1H3, and toll free by
phone at 1-800-282-1376.
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