Accuracy of Personal Information
It is the responsibility of Royal LePage Lakes of Muskoka to ensure that information collected, used and disclosed is current, accurate and verifiable. All public property information should be verified. Disclaimer of accuracy in approved form should be attached to any disclosure of information. All personal information should be treated as confidential and sensitive information, and should be updated only when necessary to fulfill the specific purpose for which it is originally intended and must include the date of updating.
Collection, Use and Disclosure of Personal Information
Only information necessary to facilitate the real estate transaction in a professional and competent manner will be collected. No personal information shall be collected from an individual without first obtaining consent, which may be oral or written (preferred) except when consent may be implied. Consent may be implied where the information is not sensitive and where a reasonable person would assume that the individual would expect the information to be disclosed. All listing and buyer agreements must include the approved privacy clauses – no exceptions. Meetings with clients in the office must occur in a place and manner to ensure confidentiality. Mail and faxes must be directed to the intended recipient. Information will be available to staff and sales representatives on a needto-know basis.
Any complaints from an individual concerning the collection, use or disclosure of their personal information or concerning access to their personal information must be referred to the Privacy Compliance Officer.
Disclosure for New Purpose
Any sales representative or employee using personal information for some new purpose that extends beyond reasonable consent must first obtain express consent of the individual. Request for information by law enforcement officials, lawyers, or other agents or court issued documents must be referred to the Privacy Compliance Officer.
Royal LePage Lakes of Muskoka is required by law to maintain employee records and records of sales representatives. Any changes to personal information should be reported in a timely manner to the Manager.
Listing and Deal Files
Listing files are confidential and will be located in a secure area that is accessible only by the Manager or branch administrator. The listing file is to contain all original documents, and documents must pertain only to the listing. Deal files are confidential and will be located in a secure area that is accessible only by the Manager or branch administrator.
The collection of personal information will be limited to marketing and promoting properties; location, assessment and qualifying of potential buyers; provision of professional service to clients which includes but is not limited to collecting personal information for the purposes of listing a property or submitting an offer on a property. Any clients with concerns over the collection or dissemination of their personal information should be invited and encouraged to contact the Royal LePage Lakes of Muskoka Privacy Compliance Officer.
Personal Information Protection and Electronic Documents Act (PIPEDA) The Personal Information Protection and Electronic Documents Act (PIPEDA) established rules for the management of personal information by organizations involved in commercial activities. As a result, Royal LePage Lakes of Muskoka must follow strict guidelines for records management and file maintenance for sales transactions and personnel files.
Information must be protected in a manner commensurate with its sensitivity and confidentiality. This applies to records regardless of their physical form or characteristics or media.
Privacy Compliance Officer
Clients will have full access to the Privacy Compliance Officer who will be the Manager and who will be responsible for:
- establishing and updating information protection policies;
- ensure that information out-sourced for processing is provided a comparable level of protection;
- establish criteria for classification of information;
- evaluate the accessibility of sensitive information and take corrective action; o attempt to satisfactorily resolve consumer privacy complaints.
Personal and sensitive information must be kept secure in filing cabinets within the office of the branch administrator. All computers must have personal passwords.