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Protecting your privacy and the confidentiality of your personal information has always been an important aspect of First National's operations. As a provider of financial products and related services, the collection and use of customers' personal information is fundamental to our day-to-day business operations. We strive to provide you with the best customer service. To us, that includes treating your personal information fairly and with respect. Each First National employee and representative must abide by our commitment to privacy in the handling of personal information.
Personal Information is information about an identifiable individual, but does not include the name, title, business address, or telephone number of an employee of an organization.
At First National, we take our commitment to securing your privacy very seriously. We have appointed a member of our management team as First National's Chief Privacy Officer. The Privacy Officer is responsible for analyzing all personal information handling practices at First National and insuring that our Privacy Policy is up to date and in force at all times. Our employees are informed about the importance of privacy and receive information periodically to update them about our Privacy Policy and related policies. Each employee and representative of First National is responsible for the personal information under his or her control.
Whenever we collect information about you, we will explain how we intend to use it, either at that time or earlier. We will limit the information we collect to what we need for those purposes and we will use it only for those purposes. If we wish to use your information for any other purpose we will obtain your consent.
We ask you for information to establish a relationship and serve your financial needs. We obtain most of our information about you directly from you, as well as from various credit rating agencies and other third party sources. Personal information is required:
- to verify your identity;
- to evaluate your application for financing, particularly with respect to the credit risk being undertaken;
- 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 and to offer those to you; and
- to administer our financial and lending programs properly.
Your knowledge and consent are required before we may collect, use or disclose your personal information, except in special circumstances, such as during a fraud investigation, an investigation by the police, or in situations otherwise permitted by law.
We accept any of the following as your consent for First National's existing use and future collection, use and disclosure of your personal information for the purposes identified herein or in any document in which you expressly give your consent:
- your receipt of this Personal Information Policy, unless you advise First National, either orally or in writing, that you do not agree with the terms stated in this Policy, and that you wish to opt out of all or portions of it;
- your unrestricted provision of information to First National either directly or through licensed agents or mortgage brokers; or
- your express written or oral consent as obtained through a mortgage commitment, a mortgage document or through an application process.
You may withdraw your consent at any time upon reasonable notice, subject to legal or contractual restrictions: for example, you may not withdraw your consent to disclosure of your information to our service providers (as defined below) during the term of your mortgage. Please note that withdrawing your consent may affect our ability to continue to provide you with the products and services that you have or would like to receive.
To withdraw your consent, you should contact our Privacy Officer at the address or telephone number listed. Unless we hear otherwise from you, you are giving to us your consent for the collection, use and disclosure of personal information as provided in this Policy for the purposes identified herein.
The personal information about you which we collect will be limited to that which is necessary for the purposes identified to you by us. Information will be collected by us by fair and lawful means.
We will not use or disclose your personal information for purposes other than those identified to you at the time your consent was given. We will seek your further consent before using the information for purposes beyond the scope of your original consent.
There are some unavoidable 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 third party lenders, rating agencies, consumer reporting agencies, partners, consultants and suppliers to First National (also known collectively as "service providers").
We will retain your information only for the time it is required for the purposes we describe and for a reasonable length of time thereafter in case we need to meet any potential obligations or legal or government requirements. Once your personal information is no longer required, it will be destroyed or made anonymous.
All decisions involving personal information should be based on accurate and timely information. While we will do our best to base our decisions on accurate information, we rely on you to disclose all material information and to inform us of any relevant changes.
We will protect your information, whether in electronic or paper based format, with strict safeguards and security measures, to protect it from unauthorized access, disclosure or misuse. We audit our security procedures regularly to ensure that they are being properly administered and that they remain effective and appropriate.
First National has prepared this plain language Privacy Policy to keep you informed. It is made available to the public in paper form at the address set out below, and in electronic form at www.firstnational.ca.
We will give you access to the information we retain about you within a reasonable time, upon receipt of a written request and satisfactory identification. You also have the right to know to whom your personal information has been disclosed, except where such disclosure was to a governmental body or service provider for routine purposes or to a governmental body where that body has exercised a legal right to obtain same.
We may charge you a nominal fee for processing your request and if so we will give you advance notice of the amount thereof.
In some cases we may not provide access to personal information 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/client privilege; or
- the information was collected during the investigation of a legal matter or for purposed related to the detection and prevention of fraud or 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.
Respecting and Responding to your Privacy Concerns
Updated versions of this Privacy Policy are posted on First National's website at www.firstnational.ca. You may feel free to contact us with any questions or concerns you might have about your privacy or our Privacy Policy. You should direct any queries to First National's Privacy Officer at the telephone, e-mail address or mailing address listed below.
Address:
100 University Avenue
7th Floor, North Tower
Toronto, Ontario M5J 1V6
Telephone No: 416-593-1100
Confidential Fax No: 416-597-5939
E-mail address: privacy@firstnational.ca
Internet: www.firstnational.ca
Please be sure to include your name, address, preferred method of communication, the nature of your complaint and relevant details, including your past communications with us. If you have a complaint and it is justified, we will take the steps necessary to resolve the issue, including, if necessary, amending our Privacy Policy procedures.
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