This policy is made under the Personal Information Protection and Electronic Documents Act and other applicable legislation.
B. PERSONAL INFORMATION
2. Personal Information generally means any information or data about an individual that allows that individual to be identified.
3. The confidentiality of personal information is an important principle at Park Property Management Inc. ("Park"). While it is a reality of doing business that we must collect personal information, we are committed to doing so in a responsible manner.
4. The following concepts are at the foundation of Park's approach to privacy protection as it relates to our existing tenants, prospective tenants, condominium owners, contractors and employees:
- Park will collect, use or disclose personal information only for authorized purposes.
- Park will comply with all applicable Provincial and Federal privacy laws.
- Park will preserve the confidentiality, accuracy and security of personal information.
- These principles will guide us in the collection, use, retention and disclosure of personal information.
- Each employee is responsible for compliance with this policy in relation to the personal information under his/her control. In addition, Park has appointed Susan Caswell as its Privacy Officer to assume overall responsibility for compliance with this policy and the applicable privacy legislation.
- Personal information will only be used for the purposes identified and access to personal information will be restricted to those who need to have access to it.
D. PURPOSES FOR WHICH WE COLLECT PERSONAL INFORMATION
(a) In our capacity as landlord
5. As a landlord, we are required to assess potential tenants for their suitability as tenants and collect the necessary basic information should they become tenants. Like all landlords , we collect, use and disclose personal information in order to serve our clients and their tenants, preserve and manage our clients' property, ensure the safety, security and reasonable enjoyment of the rented premises for each tenant, ensure access to the premises, equipment and services that we have agreed to provide, and to collect rents and other fees.
6. Park will confirm the information provided, check references and conduct a history check of each prospective tenant. This could include following up with other individuals identified during the course of these inquiries as having relevant information (e.g. a person identified by a reference provided to us). We, or our client, may also contact appropriate public sources or a credit agency and/or a consumer reporting service for information about an individual's suitability as a tenant.
7. The types of personal information we may collect include name, gender, family status, address, electronic address(s), telephone numbers, income or other identifying information, such as Social Insurance Number, driver's license or date of birth. In addition, images, movements, actions, or other identifiable information about our residents may be captured by video equipment monitoring the common areas at our properties. The purpose of such monitoring is to enhance security, safety and reasonable use and enjoyment by all lawful users of the property.
8. Information obtained during the course of a tenancy may be used for purposes of enforcing any term of the Tenancy Agreement and to obtain a consumer report in the event the tenant is in arrears of rent or wishes to renew their Tenancy Agreement.
(b) In our capacity as an employer
9. We collect the personal information on our employees for recruiting and hiring purposes and in order that we can check references and properly administer payroll and benefit plans. Our human resources department collects the following employee information: name, address, telephone numbers, work and business information, banking information, social insurance number, driver's license number, dependent particulars, among other information. This information is collected and used for payroll and benefit plans setup, administration, payment and tax remittance, to process any benefit or other claims, such as WSIB or medical related claims, and to comply with applicable employment legislation.
10. In addition, images, movements, actions, or other identifiable information about our employees may be captured by video equipment monitoring the common areas at offices and buildings under our management that an employee may visit as part of their duties.
11. Consent to use the information supplied by prospective tenants is provided by means of a signature(s) on the "Rental Application" form. By signing the Rental Application the applicant gives permission to the landlord or his agent to perform credit checks, to contact current and previous employers, previous landlords, references, or to take any other reasonable steps to assess the Rental Application for credit worthiness. Additional consent is granted by signing the Tenancy Agreement, if accepted to become a new tenant.
12. If a tenant applicant withdraws consent or refuses to provide certain personal information requested, it likely will mean that we cannot provide the applicant with a rental apartment or the services or information required.
13. Consent to use the information supplied by prospective employees is provided by means of the completion of an application for employment.
14. There may be situations where we collect personal information without the tenant's or employee's express consent, such as in the case of an emergency where we believe the tenant/employee would consent if asked and it is impractical to obtain consent (e.g. information obtained by a relative about an absent tenant, or a building emergency may necessitate entering the suite), access public sources (i.e. government, court or tribunal records) or to investigate a breach of the Tenancy Agreement or contravention of the law.
F. LIMITING COLLECTION
15. Personal information is only collected for necessary reasons and not indiscriminately. If we require information for any other purpose the individual will be notified of the new purpose and, subject to their consent, that new purpose will become an identified purpose. Park will only collect personal information by fair, lawful means and an appropriate staff member will be able to explain why the information is needed.
G. LIMITING USE, DISCLOSURE AND RETENTION
17. Park has guidelines and procedures in place for retention and destruction of personal information, taking into account legal requirements and restrictions. Personal information that has been used to make a decision about an individual will be kept for a reasonable time period that will allow the individual access to the information after the decision has been made. Information that does not have a specific purpose or that no longer fulfils its intended purpose is destroyed in a secure manner.
18. We will strive to keep personal information as accurate, complete and up to date as necessary, taking into account its use and the interests of the individual. Personal information will only be updated when necessary to fulfill the specified purposes. If either party feels the use or disclosure of out of date or incomplete information would harm the individual, a request can be made to resubmit more accurate and current data. Personal information relating to tenants is normally available at Park's management office serving the resident's apartment building or condominium unit.
19. All of Park's staff are responsible for maintaining and protecting all personal information under their control. We do not sell or transfer any personal information outside Park other than where explicit reference is made and approval obtained at the time the personal information is provided, or where passing that information to third parties is necessary to provide the information or service requested.
20. Information is kept at our premises, which are secured by an alarm system when office staff are not present. Information stored electronically is protected by passwords and other data security controls. Banking information provided for the purpose of electronic banking to pay rent or condominium fees is encrypted through software in use at Park, which is supplied by the banking industry.
J. ACCESS TO, AND CORRECTION OF, YOUR INFORMATION
21. All individuals supplying personal information have the right to request to view the information relating to them, with some exceptions. Often all the individual has to do is ask, but it is possible we may request that the reason be stated in writing. If we cannot give access to the information requested, we will tell the person within 30 days, explaining as best we can why we cannot give access to the information. We may only refuse access as authorized by law, and in any event will provide the individual with a written explanation for refusing the request.
22. We can help identify what records we might have about an individual as well as help explain any information that is not understood such as short forms, technical language, etc. We will need to confirm an individual's identity if we do not know who they are, before providing them with this access. Park reserves the right to charge a nominal fee for such requests if they are unreasonable or very time consuming. Assuming we allow review of information relating to the content and accuracy, an individual may request an update to the data, if appropriate.
23. If an individual believes there is a mistake in the information that we have on file, they have the right to request a correction although they may be asked to provide documentation. Where we agree that we made a mistake, we will make the correction and notify anyone to whom we sent this information. If we do not agree that we have made a mistake, we will still agree to include in our file a brief statement from the individual on the matter and we will forward that statement to anyone else who received the earlier information.
K. CHALLENGING COMPLIANCE
24. To make a formal complaint about our privacy practices, or for more general inquiries, requests may be made in writing to our Privacy Officer at Park Property Management Inc., 16 Esna Park Drive, Suite 200, Markham, Ontario, L3R 5X1, or call 905-940-1718. The Privacy Officer will acknowledge receipt of the complaint, ensure that it is investigated promptly and provide a formal decision and explanation in writing.
25. The Information and Privacy Commissioner of Canada oversees the administration of the privacy legislation in the private sector. The Commissioner also acts as a kind of ombudsman for privacy disputes. If we are not able to resolve a concern, the individual may contact Park Property Management Inc.'s Privacy Officer, who will provide them with the government contact information.
Issue Date: September 2016