Privacy of personal information is an important principle of Goldview Property Management Ltd. We are committed to collecting, using and disclosing personal information responsibly and only (limited) to the extent necessary for the premises, goods and services we provide. We endeavour to be open and transparent as to how we handle personal information. This document describes our privacy policies.
WHO WE ARE
Our organization, Goldview Property Management Ltd., provides property management services to condominium corporations and landlords of residential and commercial properties. We use a number of consultants and agencies that may, in the course of their duties, have limited access to personal information we hold. These include building superintendents, security, concierge, cleaning and maintenance companies, bookkeepers and accountants, computer consultants, and lawyers. We restrict their access to any personal information we hold as much as is reasonably possible. We in turn have their assurance that they follow appropriate privacy principles.
WHAT IS PERSONAL INFORMATION?
Personal information is information about an identifiable individual. Personal information includes information that relates to their personal characteristics (e.g., gender, age, income, home address or phone number, family status), their health (e.g., disabilities) or their activities and views (e.g., religion, politics, opinions expressed by an individual, opinions about an individual). Personal information is to be contrasted with business information (e.g., an individual’s business address and telephone number), which is not protected by privacy legislation.
COLLECTING PERSONAL INFORMATION: PRIMARY PURPOSES
Like all property managers, we collect, use and disclose personal information solely in order to serve our clients and to manage our client’s property. For our client’s, the primary purpose for collecting personal information is to ensure their safety, security and reasonable enjoyment and that of the other residents. As well, to ensure they have access to the premises, equipment and services that our clients have agreed to provide, to preserve our client’s property and to collect rents and other fees. Examples of the type of information we collect for these purposes include the following:
- Names of all occupants of units, parking spaces, lockers, etc.
- Business and emergency contact information
- Vehicle information
- Use and intended uses of the property
- Compliance with tenancy agreements and client’s rules and regulations
- Payment, banking and other financial information
- Any special needs of clients or their tenants (e.g., disability or health) and;
As a service and convenience for our clients we may maintain public directories of residents (e.g., by the front door). If you do not wish to be listed in any directories or wish to be described in a particular way, please let us know.
It would be rare for us to collect any personal information without the resident’s express consent, but this might occur in a case of urgency to investigate a breach of the tenancy agreement or contravention of the law.
Residential / Commercial Rental Properties
We subscribe to a consumer reporting (credit check) service. This service provides information to landlords about prospective tenants. In return, we, on behalf of our clients, provide information to the service in order for the service to maintain a databank on a tenant’s history. We collect full legal name and date of birth to ensure the accuracy of those records. Having a good tenant history filed with the service will make it easier for you to be accepted as a tenant at other properties in the future. We or our clients obtain your consent for using the consumer reporting service in the rental application form and tenancy agreement.
The information described above and the information set out below about prospective tenants can be collected or updated if the tenant is in arrears of rent or fees or wishes to renew atenancy agreement.
Prospective tenants are requested to complete a rental application form so that we or our client can assess their suitability as tenants and have necessary basic information should they become tenants. This would include the following types of information:
- Past tenancy history
- Employment history
- References and conduct history
- Financial means and credit history
- Automobile information and
- Intended use of the premises
We or our client will then confirm this information and check references and the conduct history of the prospective tenants. This might 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 you provided to us). We or our client may also contact a credit agency and/or a consumer reporting service for information about your suitability. We or our client might also check appropriate public sources (e.g., government, court or tribunal records). By completing a rental application form you agree to us or our client collecting this information about your suitability to be a tenant.
Suppliers and Contractors
We often deal with suppliers and contractors who provide goods and services to the properties we manage. We monitor their performance, including their promptness, reliability, quality and value of services. Most of this information is business information and would not be covered by privacy legislation. However, occasionally, this information relates to the conduct of an individual (e.g., skill of a particular employee of a supplier or contractor, inappropriate behaviour or comments by a particular representative). We reserve the right to collect this information, use it in deciding upon future services and to disclose it to the landlord or others involved in related or similar operations. We may also collect home contact information to reach them in case of emergencies.
Sharing Information with Our Clients
We collect contact information about our clients for better communication or to reach them incase of emergencies. We also collect information about our client’s instructions, wishes and preferences in order to better serve them. Generally we collect information about our clients directly from them and with their consent.
For people who are contracted to do work for us (e.g., temporary workers), our primary purpose for collecting personal information is to ensure we can contact them in the future (e.g., for new assignments) and for necessary work-related communication (e.g., sending out paycheques, year-end tax receipts, tax filings). Examples of the type of personal information we collect for those purposes include home addresses and telephone numbers. It is rare for us to collect such information without prior consent, but it might happen in the case of an emergency (e.g., an outbreak of a contagious disease) or to investigate a possible breach of law (e.g., if a theft were to occur).
COLLECTING PERSONAL INFORMATION: RELATED AND SECONDARY PURPOSES
Like most property managers, we collect, use and disclose information for purposes related to or secondary to our primary purposes. The most common examples of our related and secondary purposes are as follows:
- To collect fees or rents on behalf of our clients.
- To collect fees and accounts from our clients.
- In the event that management of a particular property is transferred
- We review resident, client and other files for the purpose of ensuring that we provide high quality services, including assessing the performance of our consultants, suppliers and staff. In addition, external consultants (e.g., auditors, lawyers, business consultants) may on our behalf do audits and continuing quality improvement reviews of our operations, including reviewing tenant or client files and interviewing our staff.
- Various government agencies (e.g., Canada Customs and Revenue Agency, Information and Privacy Commissioner, Human Rights Commission, etc.) have the authority to review our files and interview our staff as a part of their mandates. Also, we believe that we should report information suggesting serious illegal behaviour to the authorities. These reports could include personal information about a tenant or other individual to support the concern (e.g., illegal drug activity), although we try to keep this disclosure to a minimum. In these circumstances, we may consult with professionals (e.g., lawyers, a private security service) who will investigate the matter and report back to us.
- If a resident’s rent or fees are paid for by a third party (e.g., employer, your trustee, the government) we may be asked to provide them with certain information. These third party payers often have tenant consent or legislative authority to direct us to collect and disclose to them certain information in order to demonstrate tenant entitlement to and responsible use of this funding.
- Tenants, clients or other individuals we deal with may have questions about the services they received. We also provide ongoing services for many tenants and clients over a period of months or years for which previous records are helpful. We retain tenant and client information for a minimum of five years after the last contact to enable us to respond to those questions and provide these services.
- If Goldview Property Management Ltd. or its assets were to be sold; personal information may be one of the transferred business assets.
You can choose not to be part of some of these related or secondary purposes (e.g., declining to receive our newsletter). We do not, however, have much choice about some of these related or secondary purposes (e.g., external regulation).
PROTECTING PERSONAL INFORMATION
We understand the importance of protecting personal information. For that reason, Goldview has taken measures to protect the security and confidentiality of personal information as are appropriate in the circumstances. However, any information transmitted via the Internet may be intercepted by third parties. Goldview does not assume any liability for interception, alteration or misuse of information transmitted over the Internet.
RETENTION AND DESTRUCTION OF PERSONAL INFORMATION
We need to retain personal information for some time to ensure that we can answer any questions you might have about the services provided and for our own accountability to external regulatory bodies. However, we do not want to keep personal information too long in order to protect your privacy.
At such time as personal information is no longer required for the purposes stated herein or other statutory requirements, such personal information will be made anonymous or destroyed.
Upon request, you have the right to see what personal information we hold about you. Clients may verify the accuracy and completeness of their information, and may request that it be amended, if appropriate.
Should you wish access to your personal information, we would ask that you make your request in writing to Goldview’s Information Officer, stating specifically which information you are requesting. We will try to respond to your request as soon as possible. We may charge you a reasonable fee for administering your request, but only after first advising you of the approximate cost.
Goldview reserves the right to confirm the identity of the persons seeking access to personal information before complying with any requests.
COMMENTS AND QUESTIONS
Any comments or questions about this Statement, should be addressed to Goldview Property Management Ltd. as follows:
Goldview Property Management Ltd.
51 Toro Road, Suite 200
Toronto, Ontario M3J 2A4
Attention: Information Officer
By e-mail: firstname.lastname@example.org
By Facsimile: 416-630-3132
If you wish to make a formal complaint about our privacy practices, you may make it in writing to our Information Officer who will acknowledge receipt of your complaint, ensure that it is investigated promptly and that you are provided with a formal decision and reasons in writing.
This policy is made under the Personal Information Protection and Electronic Documents Act. It is a complex Act and provides some additional exceptions to the privacy principles that are too detailed to set out here. There are some rare exceptions to the commitments set out above.
For more general inquiries, 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. The Information and Privacy Commissioner can be reached at:
112 Kent Street
Ottawa, ON K1A 1H3
Phone: (613) 995-8210
Fax: (613) 947-6850
TTY: (613) 992-9190