2. Our Commitment to Your Privacy
The relationship between you and Carson Dunlop is based on trust. We value the trust you have placed in us and are taking all appropriate measures to safeguard your personal information and that of your clients, and to maintain your confidence. Carson Dunlop has established this privacy policy to ensure that your personal information and that of your clients is protected and that all our practices and procedures comply with relevant personal information protection and privacy legislation. Accordingly, we adhere to the privacy principles set out below, which are based on the principles set out in Schedule 1 of the Personal Information Protection and Electronic Documents Act (Canada). As used in our privacy policy, the term "personal information" means information about an identifiable individual including their home or other real property, but does not include the name, title or business address or telephone number of an employee of an organization. 

3. Accountability
Carson Dunlop is responsible for all personal information under our control. If we provide you with services which require you to disclose personal information of your clients, we will co-operate with you to review and abide by the terms of your privacy commitment to your clients.
Accountability for our compliance with this privacy policy rests with our Chief Privacy Officer. However, other individuals within Carson Dunlop may have responsibility for the day-to-day collection and processing of personal information.

Contact information for our Chief Privacy Officer is set out below:

John Kwasnik
Chief Privacy Officer
Carson, Dunlop & Associates Ltd.
120 Carlton Street
Suite 407
Toronto, Ontario
Canada
Tel: 416-964-9415
Fax: 416-964-0683
E-mail: privacy@carsondunlop.com

Carson Dunlop is responsible for personal information in our possession or custody, including: (i) information that needs to be disclosed to third parties in the course of our business; and (ii) personal information of clients of home inspectors using our services. We use contractual and other means to ensure that third parties to whom we disclose personal information for processing provide a comparable level of protection with respect to personal information in their possession or control.

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4. Identifying Purposes
We will clearly identify and document the purposes for which we may collect, use or disclose personal information at or before the time of collection. As part of our business operations, we may collect and use certain personal information strictly for the following purposes:

• To provide you with Carson Dunlop products and services that you request
• To provide information regarding Carson Dunlop and our products and services that may be of interest to you (If you wish to stop receiving such information, simply provide written instructions to our Chief Privacy Officer).

In addition, in the unlikely event that Carson Dunlop sells all or substantially all of its assets, personal information, including your collected personal information and that of your clients will be one of the transferred assets.

The specific uses of personal information in connection with the foregoing purposes will be limited to what a reasonable person would consider appropriate in the circumstances.

If we plan to use personal information we have collected for a purpose not previously identified, we will identify and document the purpose before such additional use. We will state the identified purposes in such a manner that you can reasonably understand how your personal information will be used or disclosed.  

5. Obtaining Consent and Opting Out/Withdrawing Consent
By using the services of Carson Dunlop, you consent to the collection, use and disclosure of certain of your personal information and that of your clients by Carson Dunlop as detailed in this privacy policy.
We will use reasonable efforts to seek your express consent for the collection, use or disclosure of your personal information at the time of collection. In some circumstances, such as where we want to use personal information for a purpose that was not previously identified, we may have to seek your consent after your personal information and that of your clients has been collected but before our use for that purpose.

We require you to have a privacy policy communicated with your clients that permits the holding of their information in Horizon under the terms expressed herein.

We will not, as a condition of providing the Carson Dunlop service to you, require you to consent to the collection, use or disclosure of personal information beyond that which is absolutely necessary.
You always have the choice of whether or not you wish to supply Carson Dunlop with personal information. If you wish to "opt-out" of receiving certain informational and promotional materials from us, simply provide written instructions to our Chief Privacy Officer at the address set out above. Similarly, if you wish to withdraw your consent with respect to a particular use or disclosure of your personal information and that of your clients, you may do so at any time by sending written instructions to our Chief Privacy Officer at the address set out above.

In certain limited circumstances, as permitted or required by law, we may collect, use or disclose personal information without the knowledge or consent of the individual. Although the following list is not exhaustive, these circumstance include: (i) personal information which is publicly available as defined by regulation; (ii) circumstances where collection or use is clearly in the interests of the individual and consent cannot be obtained in a timely fashion; (iii) to investigate a breach of an agreement or a contravention of a law; (iv) to act in respect of an emergency that threatens the life, health or security of an individual; (v) for debt collection; or (vi) to comply with a subpoena, warrant or court order.  

6. Limiting Collection
We will limit the amount and type of personal information collected to that which is necessary for our identified purposes and we will only collect personal information by fair and lawful means.
We may collect the following types of personal information from individuals visiting our website or purchasing Carson Dunlop products and services:

• Name
• Credit card number (if purchasing a Carson Dunlop product or service)
• Residential address (if purchasing a Carson Dunlop product or service)
• Residential telephone number (if purchasing a Carson Dunlop product or service)
• e-mail address

Through the use of Cookies our websites may automatically record some general information about your visit for website traffic analysis such as your IP address and type of browser. This information is used to improve your visit to our website.

Our website contains links to other sites. Once you leave our website, you are subject to the privacy policies of the other sites you visit.

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7. Limiting Use, Disclosure and Retention
Your personal information collected by Carson Dunlop will be used to deliver services, products or programs you have requested or enrolled in. In addition, you may receive invitations to participate in relevant surveys, and copies of Carson Dunlop’s e-newsletter.

Carson Dunlop also uses your personal information to inform you of other products, services or benefits available from Carson Dunlop and its affiliates.

For example:
Carson Dunlop may also contact you via surveys to conduct research about your opinion of current services, or on other research initiatives. Carson Dunlop will not contact your clients or affiliated groups, including real estate agents, without your permission.

Carson Dunlop will not use or disclose your personal information for purposes other than those for which it is collected, except with your express consent or as required by law. Carson Dunlop will not rent or sell your personal information or that of your clients or affiliated groups, including real estate agents, to any third party.

Carson Dunlop will retain your personal information and that of your clients or affiliated groups, including real estate agents, only for as long as is necessary for the fulfillment of those purposes, subject to legal requirements. Currently, our policy is to maintain personal information for as long as the inspection company is a subscriber of a Carson Dunlop service and for a period of one year thereafter. For Carson Dunlop’s home inspection clients, we keep reports for seven years. After the relevant time period has expired, our records are amended so that names are removed and the information can no longer be identified with an individual.

With respect to Horizon, our electronic report writing system, Horizon compiles inspection reports and maintains archive records including inspection work orders and reports for your use and the use of your clients. We will not access or use this information in any way for business purposes without your express permission. This includes contacting clients or real estate agents and reviewing report content. 

8. Accuracy
We will use our best efforts to ensure that personal information under our control that is used on an ongoing basis, including information that we disclose to third parties in accordance with this privacy policy, is as accurate, complete, and up-to-date as is necessary for the purposes for which it is to be used. In order to assist us in that regard, we urge you to provide us with updates regarding such information and to inform us of any errors affecting your personal information that we hold. 

9. Safeguards
Carson Dunlop is committed to protecting the security of your personal information and we will protect your personal information and that of your clients or affiliated groups, including real estate agents, with safeguards appropriate to the sensitivity of the information. We employ appropriate safeguards to protect personal information against loss or theft, as well as unauthorized access, disclosure, copying, use or modification, regardless of the format in which the information is held. We use security technologies and procedures to help protect your personal information and that of your clients or affiliated groups, including real estate agents, from unauthorized access, use or disclosure. For example, we store personal information you provide on computer systems with limited access in controlled facilities. When confidential information (such as credit card numbers) is transmitted over the Internet, it is protected through the use of SSL Encryption.

We make our employees and business partners aware of the importance of maintaining the confidentiality of personal information, and we will exercise appropriate care in the disposal or destruction of personal information to prevent unauthorized parties from gaining access to the information.

Our methods of protection include physical measures (for example, restricted access to offices), organization measures (for example, limiting access on a "need to know" basis), and technological measures (for example, the use of passwords and encryption).

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10. Openness
We will make specific information about our policies readily available, except to the extent that it is confidential commercial information.

The information we will make available will include: (i) how to gain access to your personal information and that of your clients or affiliated groups, including real estate agents; (ii) the type of personal information held by us, including a general account of its use; (iii) general information concerning our privacy policy; (iv) what personal information is made available to third parties; and (v) how to contact our Chief Privacy Officer.
Copies of the current version of our privacy policy are available by contacting our Chief Privacy Officer. Our privacy policy can also be viewed at our website at http://www.discoverhorizon.com/ 

11. Access
Upon written request addressed to our Chief Privacy Officer, we will inform an individual of the existence, use and disclosure of his or her personal information and we will give the individual access to that personal information. An individual can challenge the accuracy and completeness of his or her personal information under our control and have it amended as appropriate.

We will respond to an individual’s written request within a reasonable time (generally within 30 days) and we will assist any individual who informs us that he or she needs assistance in preparing a request. We may require an individual to provide sufficient information to permit us to provide an account of the existence, use and disclosure of personal information. While our response will typically be provided at no cost to the individual, depending on the nature of the request and the amount of information involved, we reserve the right to impose a reasonable cost. In these circumstances, we will inform the individual of the approximate cost to provide the response and proceed upon payment by the individual of the cost. Requested information will be provided or made available in a form that is understandable. Where possible, we will indicate the source of the information.

If you feel that your personal information or that of your clients or affiliated groups, including real estate agents, we hold is inaccurate or incomplete, you are invited to advise our Chief Privacy Officer of such inaccuracies and ask that we amend the personal information or that of your clients or affiliated groups, including real estate agents. Any such request must be in writing.

In providing an account of third parties to which we may have disclosed personal information about an individual, we will attempt to be as specific as possible. When it is not possible to provide a list of the organizations to which we have actually disclosed personal information, we will provide a list of organizations to which we may have disclosed the personal information.

If an individual successfully demonstrates an inaccuracy or incompleteness of his or her personal information under our control, we will amend the personal information as appropriate. If a challenge is not resolved to the satisfaction of the individual, we will record the substance of the unresolved challenge. Where appropriate, the amended information or the existence of the unresolved challenge, as the case may be, will be transmitted to third parties having access to the information in question.

In certain situations, we may refuse a request or not be able to provide access to all the personal information we hold about an individual. Exceptions to the access requirement will be limited and specific, as permitted or required by law. Where permitted, the reasons for denying access will be provided to the individual upon request. Although the following list is not exhaustive, exceptions may include: (i) information that contains references to other individuals or contains confidential commercial information, where such information cannot be severed from the record; (ii) information collected in the course of investigating a breach of an agreement or in the course of a formal dispute resolution process; and (iii) information that is subject to solicitor-client privilege.

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12. Challenging Compliance
If you are not completely satisfied with our privacy policy and wish to submit comments or concerns regarding our privacy practices, we invite you to contact our Chief Privacy Officer. We will thoroughly investigate all written complaints addressed to our Chief Privacy Officer. If we find a written complaint to be justified, we will take all appropriate measures, including, if necessary, amending our policies and practices.
If for any reason you are not satisfied with the results of our investigation of and responses to your complaint, you may file a complaint with the Office of the Federal Privacy Commissioner, 112 Kent Street, Ottawa, Ontario, K1A 1H3, Telephone: 1-800-282-1376.  

Glossary
Cookies - Cookies are small text files that Web sites place in your computer to help your browsers remember specific information. For example, they might store your passwords and user IDs. They are also used to store your preferences for content or personalized pages. Most shopping carts use cookies. These allow you to choose items and leave the virtual store, then return later and find that all the items are still in your shopping cart. Some sites use temporary cookies (called session cookies) that are deleted when you exit your browser. Others place persistent cookies, which stay on your hard drive for long periods.

IP - An abbreviation for Internet Protocol, the basic network transmission protocol of the Internet.

SSL Encryption - SSL, or Security Socket Layer, encrypts your customers' credit card numbers, as well as other confidential information. This allows for secure online business. When your Web page has SSL, your page will show a small gold lock or key in the lower right hand side of your browser.

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