Privacy Policy

We at Elliot Lake Retirement Living (the “Landlord”) recognize the importance of privacy and the sensitivity of personal information. 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.

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

The Landlord employs and uses a number of individuals, agents, consultants and agencies that may, in the course of their duties, have access to personal information that we hold. The agents or consultants we use include, but are not limited to, property managers, building superintendents, contractors, cleaning and maintenance organizations, accountants, lawyers, computer consultants, temporary workers to cover holidays, and cleaners. 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

Like all landlords, we collect, use and disclose personal information in order to serve our tenants and to manage the residential complex. For our tenants, the primary purpose for collecting personal information is to ensure their safety, security and reasonable enjoyment and that of the other tenants, 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. We, or our agents, only disclose limited personal information, with permission from the tenant, to suppliers of services, such as telecommunications service providers, so that they can market and make available their services to new and existing tenants. We, or our agents, may also disclose personal information to insurers, lenders or prospective purchasers of properties we own or manage. 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 client’s rules and regulations

· Payment, banking and other financial information

· Any special needs of tenants (e.g., disability or health) and

· The amount of rent payable with respect to each rental unit

As a service and convenience for tenants we may maintain public directories of tenants (e.g., by the front door). If someone does not wish to be listed in any directories or wish to be described in a particular way, they should let us know.

It would be rare for us to collect any personal information without the tenant’s express consent, but this might occur in a case of urgency (e.g., the tenant is unavailable), where we believe the tenant would consent if asked and it is impractical to obtain consent (e.g., information provided by a relative about an absent tenant), 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, or our agents, subscribe to a consumer reporting service. This service provides information to us about prospective tenants. In return, we provide information to the service in order for the service to maintain a databank on a tenant’s credit history. We collect the full legal name and date of birth to ensure the accuracy of those records. We obtain the tenant’s 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 a tenancy agreement.

About Prospective Tenants

Prospective tenants are requested to complete a rental application form so that we can assess their suitability as tenants and have necessary basic information should they become tenants. This would include the following types of information:

· Past and current tenancy history

· Employment history

· Business and personal telephone and contact information

· References and conduct history

· Financial means and credit history

· Automobile information and

· Intended use of the premises

We, or our agents, 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 provided to us). We, or our agents, may also contact a credit agency and/or a consumer reporting service for information about the suitability of a prospective tenant. We, or our agents, might also check appropriate public sources (e.g., government, court or tribunal records). We or our agents may also provide the Applicant’s name, new address and move in date to a third party telecommunications or service or utility provider, if the Applicant is accepted as a tenant, in order to enable that third party to contact the tenant in regard to the provision of en-suite services. By completing a rental application form, a prospective tenant agrees to us, or our agents, collecting this information about their suitability to be a tenant.

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 tenants and the security of the property. For example we, or our agents, may operate security cameras and monitor the presence, vehicles and the conduct of visitors and non-tenants on our property. We believe that the collection of this information is implied by the private and residential nature of the residential complex.

Secondly, we, or our agents, might gather personal information in the course of marketing the residential complex to prospective tenants. 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 provided and only use that information for the purpose for which it was given to us (e.g., to respond to an email message, to provide information about our services). Cookies are only used to help navigate our website and are not used to monitor any individual.

About Suppliers and Contractors

We often deal with suppliers and contractors who provide goods and services to the residential complex. 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, or our agents, 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.

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

Like most landlords, we, or our agents, 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:

· To collect rents and other fees on behalf of related companies that we provide management services for (our “clients”).

· To collect fees and accounts from our clients.

· To advise clients and others of new developments in the area of landlord and tenant relations (e.g., a newsletter sent to a home address of a client).

· 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 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 tenant’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.

Individuals can choose not to be part of some of these related or secondary purposes (e.g., by not having a third party pay the rent). 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:

· Paper information is either under supervision or secured in a locked or restricted area.

· 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).

· Paper information is transmitted through sealed, addressed envelopes or boxes by reputable companies.

· Electronic information is transmitted either through a direct line or is anonymized or encrypted.

· Staff are trained to collect, use and disclose personal information only as necessary to fulfill their duties and in accordance with our privacy policy.

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 client files for a period deemed reasonable by our clients but will not be less than 7 years from the last month of tenancy. Our clients, tenant 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 someone again. We keep any personal information relating to our application process with people who are not tenants for approximately 12 months.

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.

How to access Information

With some exceptions, individuals have the right to see what personal information we hold about them. We can help identify what records we might have. We will also try to help individuals understand any information they do not understand (e.g., short forms, technical language, etc.). We will need to confirm identity, if we do not know the person, before providing them with this access. We reserve the right to charge a nominal fee for such requests.

If there is a problem, we may ask for a request in writing. If we cannot give access, we will advise within 30 days if at all possible and explain the reason, as best we can, as to why we cannot provide access.

If we collected personal information on behalf of an agent or consultant, we may have conveyed that information directly to the agent or consultant. If so, we may not have it as a part of our own files and the individual will have to go to the agent or consultant to look at the information.

If it is believed there is a mistake in the information, individuals have the right to ask for it to be corrected. We may ask for 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 the individual on the point and we will forward that statement to anyone else who received the earlier information.

Changes to this Privacy Policy

The Landlord reserves the right to change this Privacy Policy from time to time. If the Landlord makes a material change, this Privacy Policy will be updated accordingly. We recommend that you periodically review this Privacy Policy, which is posted in the lobby of the residential complex and on our website, if applicable, so that you are aware of any changes. You may also request a copy of this Privacy Policy from the Privacy Officer. Please note that this Privacy Policy will be provided in an accessible format upon request. Your continued reading of the policy and use of our site following the posting of any changes to this Privacy Policy shall constitute your acceptance of these changes.

Do You Have a Question?

Please contact the Landlord’s Privacy Officer:

Heather Goulding

289 Highway 108 N.

Elliot Lake, ON P5A 2S9

Phone: 705-848-4911 ext. 529

Email: hgoulding@elrl.ca

Fax: 705-848-7514

The Privacy Officer will attempt to answer any questions or concerns you might have.

If someone wishes to make a formal complaint about our privacy practices, they may make it in writing to our Privacy Officer. He or She will acknowledge receipt of the complaint; ensure that it is investigated promptly and ensure that they are provided with a formal decision and reasons in writing.

This policy is made under the Personal Information Protection and Electronic Documents Act (PIPEDA). 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

Toll-free: 1-800-282-1376

Fax: (613) 947-6850

TTY: (613) 992-9190