RE/MAX CENTRE CITY REALTY INC. COMPANY POLICY

RE: PRIVACY CODE LAW - EFFECTIVE JANUARY 1, 2004

1. The Privacy Code of The Canadian Real Estate Association

This company and its sales representatives are a member of The Canadian Real Estate Association (CREA) and adhere to and abide by the principles set out in the CREA Privacy code. All employees and sales representatives associated with this company must sign and acknowledge that they will comply with the requirements of the Code.

2. The Policy Statement

RE/MAX Centre City Realty Inc. and its sales representatives only collect personal information necessary to effectively market and sell the property of sellers, to locate, assess and qualify properties for buyers and to otherwise provide professional and competent real estate services to clients and customers. Personal information may be disclosed only as necessary to complete a listing or sales of a property.

3. The Person In Charge

Jody Lacey Administrator is the privacy compliance officer responsible for privacy compliance in this company. Her name shall be made available to consumers. The responsibilities of the privacy compliance officer shall include:

(a) establish and update information protection policies;
(b) establish criteria for classification of information;
(c) ensure policies are implemented by other organizations to which data-processing functions are outsourced;
(d) evaluate the accessibility of sensitive information and take corrective action where necessary;
(e) provide education to employees on the importance of information protection;
(f) attempt to resolve consumer privacy complaints to the satisfaction of the consumer.

4. The Collection, Use and Disclosure of Personal Information

(a) Only the information necessary to facilitate the real estate transaction or otherwise provide professional and competent service to clients and customers will be collected;
(b) No personal information shall be collected from an individual without first obtaining the consent of the individual to the collection, use and dissemination of that information;"
(c) Express consent (whether oral or written) must always be obtained except in the following situation. Consent may be implied where the information is not sensitive and where it can be reasonably assumed that the individual would expect the information to be disclosed in this fashion;
(d) Once information is collected, it will be used and disclosed only for the purposed disclosed to the individual;
(e) All representation agreements must include the approved privacy clauses.
(f) All agreements of purchase and sale must include the privacy clause.
(g) All computer programs with confidential information will have passwords for security and backup disks or tapes and all files will be locked in secure location. This applies to all company sales representatives records kept in their homes or off site offices.
(h) Clauses are in the new Agreement of Purchase and Sale and Representation Agreements supplied by the London & St. Thomas Real Estate Board.

5. Disclosure for New Purpose

(a) Anyone using personal information for some new purpose that extends beyond consent already provided must obtain the express consent of the person for that use;
(b) Requests fro information by law enforcement officials, lawyers, private investigators or other agents or subpoenas for documents by the court must be referred to the (privacy officer/company manager or broker/agent as appropriate).

6. Protecting Information

Information must be protected in a manner commensurate with its sensitivity, value and criticality. This policy applies to the company, salespeople and staff regardless of the media on which information is stored, the locations where the information is stored, the systems used to process the information, or the processes by which the information is handled (computers, files, backup tapes and disks, facsimiles, letters etc,).

(a) Collection and Disclosure

(i) Meetings with customers and clients on these premises must take place in a place and manner to ensure confidentiality;
(ii) Mail and faxes must be routed directly to the intended recipient;
(iii) Information should be available to other persons in the office only on a need-to-know basis

(b) Storage

(i) Filing cabinets designated by the company manager to contain personal, including sensitive, information are to be kept secured at all times;
(ii) All personnel have computer passwords. These passwords are confidential and are not to be shared with unauthorized persons.

(c) Destruction

(i) This company and its sales representatives have in place a record retention and destruction policy. (destruction policy #10)

7. Accuracy of Personal Information

To ensure the quality of the information collected:

(a) Insofar as possible, personal information should be collected directly from the consumer;
(b) Public property information (taxes, assessment data etc.) should be verified;
(c) disclaimers of accuracy in the form approved by the office should always be attached to any disclosure of information.

8. Access to Personal Information

(a) Copies of this company policy should always be available to the public in the reception area of the office;
(b) The individual set out in Section 3 as being responsible for the privacy compliance is the person responsible for responding to requests;
(c) On written request and appropriate identification satisfactory to the organization, an individual will be advised of personal information about him/her retained in the firms records;
(d) Where information cannot be disclosed (for example the information contains reference to other individuals or is subject to solicitor-client privilege) the individual will be given reasons for non-disclosure;
(e) An individual may have appended to a record, any alternative information where the office is of the view that the appended information is, in fact, correct;
(f) A minimal administrative fee may be charged to supply the information. (Cost for photocopies and time to retrieve information for the individual.)

9. Compliance

(a) Any complaints from an individual concerning the collection, use or disclosure of their personal information or concerning the individual's ability to access their personal information must be referred to the privacy compliance officer, who will attempt to resolve the complaint to the individual's satisfaction;
(b) In the even the complaint cannot be resolved internally to the individual's satisfaction, he or she will be advised of where to direct the complaint.

10. Destruction Policy

Each month all hard copies in regard to salesperson's previous monthly invoice are shredded after the new invoice is given to salesperson. All client and customer files in regard to listings and sales shall be locked and saved in locked storage room until they can be legally destroyed subject to the law of Revenue Canada and the Canadian Real Estate Association and the Real Estate Council of Ontario. Files destroyed by shredding will be destroyed by the year when they can legally be destroyed and record of each year destroyed will be kept by the Privacy Compliance Officer.