First National's commitment to privacy
What is personal information?
Personal information is information about an identifiable individual including, name, age, gender, home address, home telephone number, identification numbers (such as your social insurance number), financial records, personal references and employment records.
Personal information does not include the name, title, business address, or telephone number of an employee of an organization or any information that has been anonymized such that an individual’s personal information is non-identifiable.
Accountability to customer
First National employees, agents and representatives are informed about the importance of handling personal information safely and securely and maintaining the confidentiality of customer personal information. This is communicated to our employees through employment contracts, policies and procedures and through on-going privacy training.
Why we collect information and how we use your personal info
Whenever we collect personal information about you, we will explain how we intend to use the information. We will limit the information we collect to what we need for those purposes and we will use it only for the purposes described.
We collect your personal information to establish a relationship with you and to serve your financial needs, including qualifying your mortgage application, determining your eligibility for insurance products, and funding and servicing your mortgage loan.
We obtain most of our information about you directly from you or through your interactions with a mortgage broker, as well as from other sources such as, credit reporting agencies, public registries, your employer, personal references and any other organization with whom you provided your consent to disclose personal information to us. Personal information is collected and used by us for several purposes, such as:
- to evaluate your application for financing, particularly with respect to the credit risk being undertaken by reviewing your credit history and transactions (including annual income, assets, liabilities and account history);
- to evaluate your financial needs and determine which financial products or related services, whether provided by us or organizations with which we have strategic alliances, may be of use to you and help meet your needs;
- to verify your identity (such as, for example, name, address, occupation, date of birth) and check your name against Canadian and foreign watch lists;
- to administer our financial and lending programs, including the securitization program sponsored by Canada Mortgage Housing Corporation (“CMHC”);
- to offer and administer mortgage life insurance products relating to the loan (we collect personal health information on the application form and provide it to the insurer);
- to administer our home warranty program with a third party provider;
- to renew or refinance existing mortgages, transfer / switch mortgages from another institution or fulfill payout and discharge requests;
- to pay municipal property taxes related to the mortgaged property, if applicable;
- to protect you and us from error, fraud and other illegal activities;
- to respond to your questions and requests;
- to provide you with electronic and other marketing communications with information and offers that may of interest to you; and
- to comply with legal and regulatory requirements and as otherwise required or permitted by applicable laws.
Monitoring and Recording
(i) Communicating Over the Telephone
First National is committed to superior service to its customers. For our mutual protection and to enhance customer service, customer calls may be recorded and used for quality assurance, monitoring, security and ongoing training of our employees. In compliance with applicable privacy laws, customers are informed that their call may be recorded. After hearing this message, should you decide to continue with the call, your consent to record the call will be implied. Otherwise, you may contact a First National customer service representative through our Contact Us section on our Webpage for other options to communicate with us. First National may also record outbound customer calls placed to our customers for similar purposes.
(ii) Communicating through Live Web Chat
If you use the live chat functionality through My Mortgage to communicate with one of our live customer service representatives, we may monitor or record our discussions with you for our mutual protection, to confirm our discussions, any requested transactions and to enhance our customer service.
(iii) Communicating through Email
When you send us an email or ask us to reply to you by email, we collect your email address and any other personal information that you have included in the email. We will keep and store your email communications together with our reply, if any, in our records to confirm our discussions and any requested transactions and to assist you in the future.
We will obtain your consent to collect, use and disclose your personal information, except as set out under applicable privacy legislation. Consent may be obtained in different ways depending on the situation or interaction with us.
You may withdraw your consent at any time upon reasonable notice, subject to legal, regulatory or contractual requirements.
Please note that withdrawing your consent may affect our ability to continue to provide you with the credit products and services that you have or would like to receive and which may be of value to you. For example, to obtain a loan, you are required to provide your consent to permit us to obtain and update credit reports and other credit information about you with credit bureau agencies and other organizations that support the credit reporting system.
Limiting collection of personal information
The personal information about you which we collect will be limited to that which is necessary for the purposes identified to you by us. Personal information will be collected by us by fair and lawful means.
How personal information may be shared by us
We will not disclose your personal information without your consent, except as otherwise set out herein.
If you have a loan with us that involves another person (e.g. a co-borrower or guarantor for a loan) or you add and authorize a third party to your account, we may share certain details of your personal information with that person in connection with your loan.
There are some types of disclosure of your personal information which may occasionally occur as part of First National fulfilling its routine obligations and/or conducting its business in the ordinary course. This includes, for example, disclosure to businesses such as investors (for example, financial institutions and pension funds) mortgage insurers, title insurers, auditors, regulatory and governmental authorities, credit rating / consumer reporting agencies.
In the event that we sell or securitize your mortgage loan (for example, as part of the CMHC securitization program), we may disclose personal information to prospective investors or CMHC to facilitate such sale or securitization.
First National uses contracts and other agreements with service providers, holding them to similar standards of confidentiality and privacy by which we are governed. First National ensures the practices of its service providers can be reviewed and audited, if necessary.
Under certain circumstances, federal and provincial privacy laws permit or require the use or sharing of personal information without a customer’s knowledge or consent. We or our service providers may release information about you without your consent in certain circumstances, including the following:
- an investigation by law enforcement and regulatory authorities or self-regulatory organizations
- if a warrant, court order or other instrument compels First National to disclose personal information, which may include lawful access by Canadian, U.S. or other foreign governmental authorities, courts or law enforcement agencies
- responding to production order requests from Canada Customs and Canada Revenue Agency
- in connection with a prospective or completed sale or transfer of all or part of our assets to a third party or as part of a corporate reorganization, stock sale or other change in corporate control
- the protection of First National assets (e.g. mortgage enforcement proceedings in connection with a delinquent loan) or where necessary for the establishment, exercise or defence of legal claims
- to other organizations in the case of investigating a breach of an agreement or contravention of law
- for the detection, prevention and suppression of fraud and other criminal activity (e.g. grow-operations and money-laundering) and other matters in the public interest
- the protection of First National’s employees, customers and others
- in situations otherwise permitted or required by applicable Canadian, U.S. or other law
Retention of information
We will retain your personal information for the time it is required to meet the purposes set out above and for a reasonable length of time thereafter or to otherwise meet legal or regulatory requirements (e.g. for tax purposes). Once your personal information is no longer required for such purposes, it will be destroyed, deleted or made anonymous.
Accuracy of information
We make all reasonable efforts to keep your information up-to-date and we endeavor to base our decisions on accurate and timely information when we make a determination that may impact you. We rely on you to disclose all material information to us and to inform us of any relevant changes out-of-date or incomplete information (for example, a name change or change in telephone number). If you discover any inaccurate information, please contact us and we will make the corrections and ensure this change of information is conveyed to third parties to whom we may have provided the information, such as a credit reporting agency. We want to ensure that our service to you is not affected by incomplete or inaccurate information.
For any information that may conflict or is in dispute, we will make a note of this in your customer file.
Safeguarding your information
First National secures and protects personal information in our custody and control, whether in electronic or paper based format, with safeguards and security measures appropriate to the sensitivity of the personal information, in an effort to protect against the theft, loss and unauthorized access, disclosure, copying or use of personal information. These safeguards include physical security controls (locked filing cabinets and restricted access to offices through security pass cards), technological security controls (passwords to computer terminals, personal identification numbers, encryption and password protection, audit trails and alerts, access levels and timed out computer terminals) and organization controls (such as policies and procedures and annual audit tests).
We review our security procedures regularly to ensure that they are being properly administered and that they remain effective and appropriate to the sensitivity of the personal information.
In general, you can visit our Website without telling us who you are or submitting any personal information. However, we collect the IP (Internet Protocol) addresses of visitors to our Website and other information about your visit, such as page requests, browser type, operating system and average time spent on our Website. We use this information to help us understand our Website activity, and to monitor and improve our Website.
A note about the use of Web tools such as Cookies
Cookies are small files that a website or its service provider transfers to a computer’s hard drive through your browser (if permitted), enabling the site or service provider's system to recognize your browser (e.g. Google Chrome, Internet Explorer, Firefox and Safari) and capture and remember certain information, such as your browser type and address of the website from which you arrived from.
We may contract with third party service providers to assist us in better understanding our site visitors and record your browsing habits in order to improve our product and service offerings and customer service.
You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies by changing the settings in your browser. We note that if you turn cookies off, you will not have access to certain features on our sites that make your online experience more efficient and some of our services may not function properly.
Our Website may also use a technology called “tracer tags” or “Web Beacons”. This technology allows us to understand which pages you visit on our Website. These tracer tags are used to help us optimize and tailor our Website for you and other future visitors to our Website.
We may offer you the opportunity to engage with our content on or through third-party social networking websites, plug-ins and applications. When you engage with our content on or through third-party social networking websites, plug-ins and applications, you may allow us to have access to certain information associated with your social media account (e.g. name, username, email address, profile picture, gender) to deliver the content or as part of the operation of the website, plug-in or application. When you provide information from your social media account, we may use this information to personalize your experience on our Website and on the third-party social networking websites, plug-ins and applications, and to provide you with other products or services you may request.
Third Party Links
Access to your information
We may charge you a nominal fee for processing your request and if so we will give you advance notice of the amount thereof. It may take up to 30 days to conduct the search and respond to your inquiry.
In some cases we may not provide access to personal information about you that is within our possession or control. This may occur if:
- doing so would reasonably be expected to threaten the life or security of another individual;
- disclosure would reveal confidential commercial information;
- the personal information is protected by solicitor-and-client privilege;
- the information contains references to other persons that is subject to confidentiality or legal privilege;
- the information was collected during the investigation of a legal matter or for purposed related to the detection and prevention of fraud; or
- the information cannot be disclosed for other legal reasons.
If we deny your request for access to your personal information, we will advise you in writing of the reason for the refusal.
Challenging compliance – how First National respects and responds to your privacy concerns
Please be sure to include your name, address, mortgage number (if applicable), preferred method of communication, the nature of your complaint and relevant details, including past communications with us, if any. If you have a complaint and it is justified, we will take the steps necessary to resolve the issue.
First National Financial LP
100 University Avenue
7th Floor, North Tower
Toronto, Ontario M5J 1V6
Attention: Hilda W. Wong, Chief Privacy Officer
Telephone No: 416-593-1100
If the Chief Privacy Officer does not resolve the issue to the customer’s satisfaction, the customer may contact the Privacy Commissioner of Canada.
Last update: September 2016