AMBA Policies and Bylaws
Alberta Mortgage Brokers Association (AMBA) is committed to safeguarding the personal information entrusted to us by our members, non-members, contractors, students and affiliates. We manage your personal information in accordance with Alberta's Personal Information Protection Act and other applicable laws. This policy outlines the principles and practices we follow in protecting your personal information.
This policy applies to the Alberta Mortgage Brokers Association (AMBA) and to any person providing services on our behalf or in partnership with AMBA.
A copy of this policy will be provided to any member, non-member, student, contractor or affiliate on request.
What is personal information?
Personal information means information about an identifiable individual. This includes an individual's name, home address and phone number, membership or other identifying number, financial information, educational history, etc.
What personal information do we collect?
We collect only the personal information that we need for the purposes of providing services to our clients (Defined as members, non-members, students, potential students, contractors, affiliates and partners of AMBA). This may include personal information needed to:
- Open and manage a membership account
- Deliver requested products and services
- Enrol a person in a course, conference, workshop, program or seminar
- Process publication advertisement requests
- Send out association membership information
- Assess suitability for membership or course enrolment
- Inform members of upcoming events and educational offerings
- Administer our value-added services program
- Follow up with course instructors for feedback and other communication
- Meet regulatory requirements
- Verify membership
- Process payment of fees
We normally collect information directly from our clients. We may collect your information from other persons with your consent or as authorized by law.
We inform our clients, before or at the time of collecting personal information, of the purposes for which we are collecting the information. The only time we don't provide this notification is when a client volunteers information for an obvious purpose (for example, submitting credit card information for an on-line or faxed-in purchase of a course, program or event when the information will be used only to process the payment).
We ask for consent to collect, use or disclose personal information, except in specific circumstances where collection, use or disclosure without consent is authorized or required by law. We may assume your consent in cases where you volunteer information for an obvious purpose.
In cases where we collected personal information before January 1, 2004, we assume your consent to our use and, where applicable, disclosure for the purpose for which the information was collected.
We ask for your express consent (Giving consent in writing or verbally is express consent. Written consent may be given electronically (by fax or e-mail) as long as AMBA is able to make a copy of the consent on paper) for some purposes and may not be able to provide certain services if you are unwilling to provide consent to the collection, use or disclosure of certain personal information. Where express consent is needed, we will normally ask clients to provide their consent orally (in person, by telephone), in writing (by signing a notice on a registration form, by checking a box on a form, via e-mail), or electronically (by clicking a button on a webpage).
In cases that do not involve sensitive personal information, we may rely on "opt-out" consent. For example, we may disclose your contact information to other organizations that we believe may be of interest to you, unless you request that we do not disclose your information. You can do this checking the appropriate box on our application or registration form or by calling our local number/toll-free number and notifying the Privacy Officer.
A client may withdraw consent to the use and disclosure of personal information at any time, unless the personal information is necessary for us to fulfil our legal obligations. We will respect your decision, but we may not be able to provide you with certain products and services if we do not have the necessary personal information.
We may collect, use or disclose client personal information without consent only as authorized by law. For example, we may not request consent when the collection, use or disclosure is reasonable for an investigation or legal proceeding, to collect a debt owed to our organization, in an emergency that threatens life, health or safety, or when the personal information is from a public telephone directory.
How do we use and disclose personal information?
We use and disclose client personal information only for the purposes for which the information was collected, except as authorized by law. For example, we may use client contact information to deliver goods, notify you of upcoming events or programs or manage membership databases. The law also allows us to use that contact information for the purpose of collecting a debt owed to our organization, should that be necessary.
If we wish to use or disclose your personal information for any new business purpose, we will ask for your consent.
In some cases, for example, if you are an instructor of the Mortgage Associates Program offered by AMBA, your contact information may be disclosed to students who require assistance from the appropriate instructor with regard to course content. Instructors will NOT be notified prior to disclosure for this purpose.
How do we safeguard personal information?
We protect client personal information in a manner appropriate for the sensitivity of the information. We make every reasonable effort to prevent any loss, misuse, disclosure or modification of personal information, as well as any unauthorized access to personal information.
- Locking filing cabinets which contain personal information.
- Maintaining administrative computers as password protected.
- Regular changing of computer passwords.
- Use of up-to-date virus and firewall software and network security software.
- Calls not answered by staff, but rather forwarded to confidential voice mails.
- All administrative staff signing Understanding of Confidentiality clauses inclusive in employment contracts.
We use appropriate security measures when destroying client personal information, including shredding paper records and permanently deleting electronic records.
We make every reasonable effort to ensure that client information is accurate and complete. We rely on our clients to notify us if there is a change to their personal information that may affect their relationships with our organization. If you are aware of an error in our information about you, please let us know and we will correct it on request wherever possible. Requests can be directed to: firstname.lastname@example.org.
In some cases we may ask for a written request for correction.
How long do we keep personal information?
We retain client personal information only as long as is reasonable to fulfil the purposes for which the information was collected or for legal or business purposes.
Access to records containing personal information
Clients of AMBA have a right of access to their own personal information in a record that is in our custody or under our control, subject to some exceptions. For example, organizations are required under the Personal Information Protection Act to refuse to provide access to information that would reveal personal information about another individual. Organizations are authorized under the Act to refuse access to personal information if disclosure would reveal confidential business information. Access may also be refused if the information is privileged or contained in mediation records.
If we refuse a request in whole or in part, we will provide the reasons for the refusal. In some cases where exceptions to access apply, we may withhold that information and provide you with the remainder of the record.
You may make a request for access to your personal information by writing to AMBA at email@example.com. You must provide sufficient information in your request to allow us to identify the information you are seeking.
You may also request information about our use of your personal information and any disclosure of that information to persons outside our organization. For personal information collected before January 2004, if we do not have a record of disclosures, we will provide information about any disclosure of your information that is likely to have occurred.
You may also request a correction of an error or omission in your personal information.
We will respond to your request within 45 calendar days, unless an extension is granted. We may charge a reasonable fee to provide information, but not to make a correction. We will advise you of any fees that may apply before beginning to process your request.
Questions and complaints
If you have a question or concern about any collection, use or disclosure of personal information by AMBA, or about a request for access to your own personal information, please contact:
Alberta Mortgage Brokers Association
#340 7326 10th St. N.E.
Calgary, AB T2E 8W1
If you are not satisfied with the response you receive, you should contact the Information and Privacy Commissioner of Alberta:
Office of the Information and Privacy Commissioner of Alberta
Suite 2460, 801-6th Avenue SW
Calgary, AB T2P 3W2
(403) 297-2728 / 1-888-878-4044
This Policy & Procedures standard has been adapted from the Personal Information Protection Policy, June 2004 - Service Alberta
For more information, please contact:
Alberta Mortgage Brokers Association