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Privacy Policy

This Privacy Policy sets out the rules and procedures governing the personal information management practices of the Real Estate Institute of Canada (REIC).  The Personal Information Protection and Electronic Documents Act (PIPEDA) sets out rules to govern the collection, use and disclosure of personal information in a manner that recognizes the right of privacy of individuals with respect to their personal information and the need of organizations to collect, use or disclose personal information. The balance of this Policy describes the detailed privacy and information management practices of REIC.

A.  PRIVACY STATEMENT 
REIC recognizes the importance of privacy and the sensitivity of personal information. We are committed to protecting the privacy and the confidentiality of the members, students, prospects, and staff of their personal information, in a manner that complies with relevant privacy legislation. 
B. APPLICATION OF THIS PRIVACY POLICY
This privacy policy outlines how and when the personal information of REIC's prospective, current and former members (the "Members"), whether living or deceased, is collected, used, disclosed, retained and protected by:
•    The Staff when they are providing services related to the administration of Members’ files;
•    Affiliated partners such as the Institute of Real Estate Management (IREM), Institute of Real Estate Studies (IRES);
•    REIC Chapters
•    Individuals and organizations who perform services on behalf of REIC including for example, lawyers, accountants, auditors and consultants hereinafter referred to as service providers. 
C. WHAT IS PERSONAL INFORMATION?
Personal information is information about an individual or information that allows an individual to be identified.  It includes, but is not limited to home address and contact information, age, occupation, employment status, income and education. Financial information such as credit card or banking information may be collected from time to time.
Personal information does not include the name, business address or business telephone number of an employee of an organization.  
D. PRIVACY PRACTICES
1. What is the purpose of collecting personal information?
1.1    REIC staff and service providers collect personal information for the purpose of administering Members’, Candidates and Students education and/or Membership status, taking into consideration any legislative requirements, fiduciary and other legal obligations.  
1.2    REIC staff and service providers will not collect personal information for any other purpose without identifying this purpose to the individual and obtaining their express consent. 
2. What personal information is collected?
2.1 REIC staff and service providers limit the collection of personal information to what is necessary for the purposes identified in section D.1 of this Privacy Policy.  
2.2     For a list of examples of personal information that REIC and service providers collect, see section C of this Privacy Policy. 
2.3    REIC and service providers may collect personal information about Members. 
3. How is personal information collected?
3.1 REIC and service providers may collect personal information throughout the course of a membership in or affiliation with REIC. REIC and service providers collect personal information primarily in writing from a variety of documents including pre-printed enrolment forms, applications, identification documents (birth certificates, citizenship certificates and passports), and post-secondary educational institutions.  
3.2    REIC and service providers also collect personal information orally and by mail, fax, couriers and electronic mail.
3.3     REIC and service providers may sometimes obtain information about Members from other sources including, but not limited to: 
•    Other members; 
•    The member's chapter;
•    The respective regulatory body for example RECO;
•    Consultants and advisors;
4.    How is consent given for the collection, use and disclosure of personal information?
4.1    Consent for the collection, use and disclosure of personal information may be obtained orally or in writing, and may be given or implied.  In determining how to obtain consent, REIC staff and service providers will take into account the sensitivity of the personal information being collected, used and disclosed.  
4.2    When express consent is required, REIC and service providers will usually use pre-printed forms both to obtain consent and collect information.
4.3    By submitting personal information to REIC or their service providers, Members agree to the collection, use and disclosure of such personal information in accordance with this Privacy Policy, and as permitted or required by law.  
4.4    REIC and service providers may obtain consent from an authorized representative or substitute decision-maker of an individual, such as a legal guardian or a person with power of attorney.
4.5    REIC and service providers do not obtain consent:
•    When it is inappropriate to do so;
•    Where legal, medical or security reasons may make it impossible or impractical to obtain consent; or
•    Where the collection, use or disclosure is permitted without consent under the federal Personal Information Protection and Electronic Documents Act ("PIPEDA"), and/or, for those members in British Columbia, the Personal Information Protection Act, S.B.C. 2003, c. 63, and/or, for those members in Alberta, the Personal Information Protection Act, S.A. 2003, c. P-6.5.  
4.6    Subject to legal and contractual requirements, Members may refuse or withdraw their consent at any time by contacting the Privacy Officer identified in this Privacy Policy. 
5.    How is personal information used?
5.1 REIC staff and service providers only use personal information for the purposes identified in section D.1 of this Privacy Policy.
5.2    REIC's and service providers' specific uses of personal information include, but are not limited to:
•    Maintaining a master file containing Members' personal information;
•    Preparing membership status correspondence and statements for Members;
•    Enrolling new Members;
•    Verifying eligibility;
•    Providing information to Members about news and developments related to REIC, IREM, and Chapter initiatives;
•    Answering questions posed by Members;
•    Processing payments around dues or education.
5.3    REIC staff and service providers do not disclose personal information to any third party to enable them to market their products.
6.    WHEN IS PERSONAL INFORMATION DISCLOSED?
6.1    From time to time, under certain circumstances, REIC may disclose personal information about Members.  Examples of such circumstances include: 
•    When required or authorized by law to do so (for example, if a court issues a subpoena or an arbitrator issues a summons, or where a request is made pursuant to an applicable federal or provincial legislation);
•    When the Member has consented to the disclosure; and 
•    When REIC seeks the advice of legal counsel.
7.    UPDATING PERSONAL INFORMATION
7.1    It is important that the personal information held by REIC be accurate and up to date. If any personal information changes, Members must advise REIC staff, appropriate service providers or the Privacy Officer, so that REIC's records can be adjusted.  
7.2    Members have the right to access their personal information at any time and can do so by contacting the Privacy Officer identified in this Privacy Policy. 
8.    HOW IS PERSONAL INFORMATION PROTECTED?
8.1    REIC takes all reasonable precautions to ensure that personal information is kept safe from loss, unauthorized access, modification or inappropriate disclosure.  This includes maintaining the following:
•    secure premises;
•    restricted access to personal information stored electronically and physically;
•    technological safeguards like security software and firewalls to protect from hacking or unauthorized computer access;
•    internal passwords and security policies; and
•    proper training for staff with respect to the sensitivity of personal information and compliance with this Privacy Policy;
•    destruction of credit card information once processed;
•    destruction of old member files or documents no longer required for administrative and legislative purposes.
8.2 Where personal information is sent to a third party for processing, REIC ensures that the third party has appropriate privacy policies that protect information in accordance with relevant privacy legislation and REIC's Privacy Policy.
9.    CHANGES TO THE POLICY
9.1    REIC reserves the right to modify or supplement this policy at any time and for any reason. Changes will be posted on the REIC website and the revised policy will be available upon request to the Privacy Officer. 
E. PRIVACY OFFICER
1.1    REIC has designated a Privacy Officer whose responsibilities include: 
•    Facilitating REIC's and service providers' compliance with this Privacy Policy and relevant privacy legislation;
•    Responding to requests by Members or other individuals to withdraw their consent to the collection, use and disclosure of personal information by  and service providers;
•    Responding to requests for access to personal information;
•    Responding to requests to update, change or correct personal information; and;
o    Receiving complaints about alleged contraventions of this Privacy Policy or the relevant privacy legislation by or their service providers.
    1.2   The designated Privacy Officer of REIC is: Sandra De Medeiros, Director of Operations.
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