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Privacy of personal information is an important principle to The Regional
Group of Companies Inc. We are committed to collecting, using and disclosing
personal information responsibly and only to the extent necessary for the
premises, goods and services we provide. We also try to be open and transparent
as to how we handle personal information. This document describes our privacy
policies.
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.
Who We Are
Our organization, The Regional Group of Companies Inc., provides
real estate services including, but not limited to, as landlords, appraisers,
consultants, brokers and building managers, for our clients. 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
managers, security, cleaning and maintenance organizations, bookkeepers and
accountants, computer consultants, temporary workers to cover holidays, cleaners,
and lawyers. We restrict their access to any personal information we hold
as much as is reasonably possible. We also have their assurance that they
follow appropriate privacy principles.
We Collect Personal Information: Primary
Purposes
About
Tenants/clients
We collect, use and disclose personal information in order to serve
our tenants/clients and operate our properties. For our tenants/clients, the
primary purpose for collecting personal information is to ensure their safety,
security and reasonable enjoyment and that of our other tenants/clients, to
ensure they have access to the premises, equipment and services that we have
agreed to provide, to preserve our property and to collect rents and other
fees. Examples of the type of information we collect for these purposes includes
the following:
- Names of all occupants of the unit
- Business and emergency contact
information
- Use and intended uses of the
property
- Compliance with the tenancy
agreement and our rules and regulations
- Payment, banking and other financial
information
- Any special needs of tenants/clients
(e.g., disability or health) and
- Social insurance number, but only
for the purpose of issuing a tax receipt for interest on the rental
deposit
As a service and convenience for tenants/clients we may maintain
public directories of tenants/clients (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 tenant’s/client’s express consent, but this might occur in a case of
urgency (e.g., the tenant/client is unavailable), where we believe the tenant/client
would consent if asked and it is impractical to obtain consent (e.g.,
information provided by a relative about an absent tenant/client), appropriate
public sources (e.g., government, court or tribunal records) or to investigate
a breach of the tenancy agreement or contravention of the law.
We subscribe to a consumer reporting service. This service provides
information to landlords about prospective tenants/clients. In return,
landlords provide information to the service in order for the service to
maintain a databank on a tenant’s/client’s history. We collect your full legal
name and date of birth to ensure the accuracy of those records. Having a good tenant/client
history filed with the service will make it easier for you to be accepted as a tenant/client
at other properties in the future. We obtain your consent for using the
consumer reporting service in your rental application form and tenancy
agreement.
The information described above and the information set out below
about prospective tenants/clients can be collected or updated if the tenant/client
is in arrears of rent or fees or wishes to renew a tenancy agreement.
About Prospective Tenants/clients
Prospective tenants/clients are requested to complete a rental
application form so that we can assess their suitability as a tenant/client and
have necessary basic information should they become a tenant/client. 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 will then confirm this information and check references and the
conduct history of the prospective tenants/clients. 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 may also contact a credit agency and/or a
consumer reporting service for information about your suitability. We might
also check appropriate public sources (e.g., government, court or tribunal
records). By completing a rental application form you agree to our collecting
this information about your suitability to be a tenant/client.
About
Members of the General Public
For members of the general public, our primary purpose for
collecting personal information is to promote the safety of our tenants/clients
and the security of our property. For example we may operate security cameras
and monitor the presence, vehicles and conduct of visitors and non-tenants/clients
on our property. We believe that the collection of this information is implied
by the private nature of our property.
Secondly we might gather personal information in the course of marketing
to prospective tenants/clients. This information is collected either from
appropriate public sources (e.g., telephone directories) or directly from
the individuals with their consent.
On our website, we only collect, with the exception of cookies
(electronic markers identifying computers that have previously visited our
website), the personal information you provide and only use that information
for the purpose you gave it to us (e.g., to respond to your email message, to
provide information about our property and services). Cookies are only used to
help you navigate our website and are not used to monitor you.
Suppliers and Contractors
We often deal with suppliers and contractors who provide goods and
services to us or 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 our property manager or others involved in related or
similar operations. We may also collect home contact information to reach
them in case of emergencies.
About
Contract Staff
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).
We Collect Personal Information: Related
and Secondary Purposes
We also 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:
q To collect rents and other fees;
q We review tenant/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/client files and interviewing our staff;
q
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/client, 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;
q If your rent or fees are paid for by a third party (e.g., your employer, your trustee, the government) we may be asked to provide them with certain information. These third party payers often have your consent or legislative authority to direct us to collect and disclose to them certain information in order to demonstrate tenant/client entitlement to and responsible use of this funding;
q Tenants/clients or other individuals we deal with may have questions about the services they received. We also provide ongoing services for many of our tenants/clients over a period of months or years for which previous records are helpful. We retain our tenant/client information for a minimum of ten years after the last contact to enable us to respond to those questions and provide these services;
q
If The Regional Group of Companies Inc. or
its assets were to be sold, the purchaser would want to conduct a “due diligence”
review of the organization’s records to ensure that it is a viable business
that has been honestly portrayed to the purchaser. This due diligence may
involve some review of our accounting and service files. The purchaser would
not be able to remove or record personal information. Before being provided
access to the files, the purchaser must provide a written promise to keep
all personal information confidential. Only reputable purchasers who have
already agreed to buy the organization’s business or its assets would be provided
access to personal information, and only for the purpose of completing their
due diligence search prior to closing the purchase;
You can choose not to be part of some of these related or secondary
purposes (e.g., by not having a third party pay your rent or fees). 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, we have taken the following steps:
q
Paper information is either under supervision
or secured in a locked or restricted area;
q
Electronic hardware is either under supervision
or secured in a locked or restricted area at all times. In addition, passwords
are used on computers. All of our cell phones are digital, which signals are
more difficult to intercept (however, we still are careful on cell phones
because sometimes they switch over to an analog service);
q
Paper information
is transmitted through sealed, addressed envelopes or boxes by reputable
companies.
q
Electronic information is transmitted either
through a direct line or is anonymized (or encrypted);
q
Staff are trained to collect, use and disclose
personal information only as necessary to fulfill their duties and in accordance
with our privacy policy;
q
External
consultants and agencies with access to personal information must provide us
with appropriate privacy assurances.
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.
We keep our tenant/client files for about seven (7) years. Our tenant/client
and contact directories are much more difficult to systematically destroy, so
we remove such information when we can if it does not appear that we will be
contacting you again. However, if you ask, we will remove such contact
information right away. We keep any personal information relating to our
general correspondence with people who are not our tenants/clients for about
two years.
We destroy paper files containing personal information by shredding.
We destroy electronic information by deleting it and, when the hardware is
discarded, we ensure that the hard drive is physically destroyed or completely
reformatted.
You Can Look at Your Information
With some exceptions, you have the right to see what personal
information we hold about you. Often all you have to do is ask. We can help you identify what records we
might have about you. We will also try to help you understand any information
you do not understand (e.g., short forms, technical language, etc.). We will need
to confirm your identity, if we do not know you, before providing you with this
access. We reserve the right to charge a nominal fee for such requests.
If there is a problem, we may ask you to put your request in
writing. If we cannot give you access, we will tell you within 30 days if at
all possible and tell you the reason, as best we can, as to why we cannot give
you access.
If you believe there is a mistake in the
information, you have the right to ask for it to be corrected. We may ask you
to provide documentation that our files are wrong. 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 you on the point and we
will forward that statement to anyone else who received the earlier
information.
Do You Have a Question?
Our
Information Officer, Jeffrey M. Gould, Senior Vice President, can be reached at:
He will attempt
to answer any questions or concerns you might have.
If you wish to make a formal complaint about our privacy practices,
you may make it in writing to our Information Officer. He 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
Phone:
(613) 995-8210
Toll-free:
1-800-282-1376
Fax:
(613) 947-6850
TTY:
(613) 992-9190