What is PIPEDA?
PIPEDA is federal legislation that governs the collection use and disclosure of personal information in a manner that respects your right of privacy concerning your personal information. PIPEDA balances these rights against an organization’s need to collect, use and disclose personal information for purposes that a reasonable person would consider appropriate in the circumstances.
What is personal information?
Personal information is information about an identifiable individual. Examples of personal information include: gender, date of birth, drivers license number, current and previous home address, phone number, family status, credit score, names of former landlords, social insurance number, income, the name of your employer and other employment details, names of family members, and monthly rent.
What does this Policy encompass?
This Policy describes how the Welcome Home Management complies with PIPEDA including the purposes for which information is collected, used and disclosed, Welcome Home Management’s treatment of personal information and your rights concerning your personal information. It is organized based on the principles listed in the Canadian Standards Association’s Model Code found in Schedule II to PIPEDA, under which the landlord’s privacy responsibilities are organized. This Policy also applies to all individuals whose personal information is collected by the Landlord including, without limitation, applicants for residency and tenants.
The responsibility for the personal information under the Landlord’s control rests with its Privacy Officer. The individual designated as Privacy Officer may change from time to time, however, his or her identity will be made known upon request.
Welcome Home Management will occasionally disclose personal information under its control to third parties, but only for an identified purpose, and with the implied or express (as appropriate) consent of the tenant. When disclosing personal information, Welcome Home Management uses contractual means to ensure that it is treated in accordance with PIPEDA by the third party.
Protecting your privacy is a top priority of Welcome Home Management. Accordingly, procedures have been adopted to give effect to this Policy. Welcome Home Management’s employees have received training concerning this Policy and the procedures in place to implement it.
Credit Checks. Personal information is collected for the purpose of conducting a credit check on applicants for tenancy. The credit check is a risk assessment tool used to ensure that you will be able to make the monthly payments required to lease premises. Consent to collect personal information for the purpose of conducting a credit check will be requested on the application for accommodation or offer to lease premises. Your refusal to provide information and consent to its use and disclosure for the purposes of conducting a credit check is grounds for the Welcome Home Management to refuse rental accommodation. Credit checks may also be done on tenants with rent payments in arrears. Welcome Home Management will retain the results of a credit check for a minimum of two and a maximum of seven years following (i) a rejected application or (ii) the end of your tenancy.
References. (1) Your personal information may be used to provide credit or rental-history references to third parties. The Landlord will only disclose such information with your express consent. (2) Your personal information is collected in order for the Welcome Home Management to conduct a reference check during the application process. The reference check will include references concerning rental payments, cleanliness, noise violations and complaint history (the “Factors”). The reference check is an assessment tool used to determine your suitability to be a tenant of Welcome Home Management based on the Factors. Your refusal to provide reference names and telephone numbers and consent to their use and disclosure for the purposes of conducting a reference check is grounds for Welcome Home Management to refuse rental accommodation. Welcome Home Management will retain the results of a reference check for a minimum of two and a maximum of seven years.
Identification. Personal information is collected for the purposes of identification. Consent may not be withdrawn for this purpose during the term of the lease or any renewal of it.
Consent is required for the collection of personal information for the above purposes, or any new purposes that Welcome Home Management identifies.
The form of consent required by Welcome Home Management varies depending on the sensitivity of the information requested and the reasonable expectations of the tenant. Consent shall be implied for all purposes unless the purpose indicates that express consent will be collected.
Welcome Home Management may collect, use or disclose your personal information without your consent in circumstances indicated in PIPEDA. For example, Welcome Home Management may disclose personal information to a collecting agency for the purpose of collecting any rent that owed by the tenant.
Welcome Home Management does not collect personal information indiscriminately. Welcome Home Management limits the collection of personal information to that which is necessary for purposes it identifies.
Welcome Home Management primarily collects personal information directly from you; however, personal information may also be collected from other sources including credit bureaus, employers, previous landlords, referees, other tenants or other people who represent that they have the right to disclose information.
The personal information that Welcome Home Management collects directly from you may be disclosed by you to Welcome Home Management, generated by your transactions with Welcome Home Management, or from their observations.
The types of personal information collected include: (i) information related to the tenancy including name, proposed occupants, address, amount of rent paid, payment history, complaints, requests, etc.; (ii) information necessary to have a credit check conducted; (iii) information necessary to evaluate tenancy-worthiness such as employment information, banking information and references from prior landlords; and (iv) information necessary to identify you or locate you in the future.
Limiting Use, Disclosure and Retention
Welcome Home Management only uses and discloses information for the purposes for which, it was collected, or otherwise in accordance with PIPEDA. Any new purpose for which the information is to be used or disclosed shall be documented, and consent will be obtained for it.
Unless this Policy indicates otherwise, Welcome Home Management retains personal information for a minimum period of seven years. Personal information will be disposed of by shredding or otherwise destroying it. Third party services may be retained to destroy personal information; however, that third party will be required to enter into a confidentiality agreement with Welcome Home Management in order to protect the personal information.
Personal information will be kept as accurate, complete and up-to-date as necessary for the purposes for which it is to be used. You are responsible for informing the Landlord about changes to your personal information as appropriate. Welcome Home Management encourages you to examine your lease agreement, application for lease and any other documents that you submit to them that contain the personal information in order to ensure that the information is accurate. If you have concerns about the accuracy of your personal information collected by Welcome Home Management, contact them at the phone number or address indicated at the end of this document.
Welcome Home Management protects personal information against loss or theft; as well as unauthorized access, disclosure, copying use or modification; with security safeguards appropriate to the sensitivity of the personal information. Files are protected by keeping them in areas restricted to employees, and/or in locked filing cabinets or rooms. Welcome Home Management’s employees have been made aware of the need to safeguard personal information and they only access the information on an as-needed basis. Welcome Home Management also uses firewalls and passwords to protect electronic personal information.
Welcome Home Management’s policies and practices related to the management of personal information are contained in this Policy. The Policy as well as additional information and documents are available from the Privacy Officer. They include:
- A Personal Information Request Form to be used to inquire about or gain access to personal information held by Welcome Home Management; and
- A Privacy Complaint Form used to complain about the Welcome Home Management’s treatment of personal information.
Upon written request, Welcome Home Management will divulge the existence, use and any disclosure made of personal information and will give you access to your information. Written requests should be delivered to the Privacy Officer at the address at the end of this Policy. Personal Information Request Forms are available from Welcome Home Management. If assistance is needed with the request, please contact the Privacy Officer.
Welcome Home Management will respond to an access request within thirty (30) days, unless an extension of time is required, pursuant to PIPEDA, in which case the response may take up to an additional thirty (30) days. A fee for reasonable costs incurred pursuant to the request may be charged to the requestor by Welcome Home Management, provided that you are informed of the fee in advance and do not withdraw your request.
Welcome Home Management may require additional information from you in order to locate certain personal information. If this is the case, the additional information will not be used for any purpose other that locating the personal information.
Should your information on file with Welcome Home Management be proved to be incomplete or incorrect, it will be amended as required. Where necessary, the amended information will be transmitted to third parties using the information in question.
Welcome Home Managementwill not comply with access requests in certain situations:
- If it would reveal information about a third party;
- If the information is subject to solicitor-client privilege;
- If to do so would reveal confidential commercial information; and
- If the information was generated in the course of a formal dispute resolution process.
- If Welcome Home Management does not comply with an access request, it will inform you of the reasons for such refusal.
Your acceptance of these terms
By using this Site, you signify your acceptance of this policy. If you do not agree to this policy, please do not use our Site. Your continued use of the Site following the posting of changes to this policy will be deemed your acceptance of those changes.
Welcome Home Management Inc.
111 Fourth Avenue, Suite 139
St. Catharines, ON L2S 3P5
Toll Free: 1-855-375-3300 | firstname.lastname@example.org