Purpose and Scope:
Denman Housing Association respects and upholds an individual’s right to privacy and to protection of his/her personal information. Denman Housing Association is committed to ensuring compliance with applicable privacy legislation.
This document sets out the policy of Denman Housing Association with respect to the protection of the personal privacy of our applicants/tenants.
“Personal information” for the purposes of this policy means information about an individual. It does not include aggregate information which cannot be associated with a specific individual and it does not include the name, title, business address, business e-mail address, or business telephone number of an individual.
“Third party” for the purposes of this policy is an individual or an organization other than the Denman Housing Association and the applicant/tenant.
Denman Housing Association is accountable for the personal information in its possession or control, including information that has been transferred to a third party for processing. Denman Housing Association has appointed a Privacy Officer who is responsible for the organization’s compliance with this Policy.
All persons officially associated with Denman Housing Association are obligated to protect the personal privacy of applicants /tenants with regard to all personal information collected by Denman Housing Association and are required to follow the procedures of this Policy regarding the management of personal information.
All persons officially associated with Denman Housing Association will be provided with information about the privacy laws applying to the organization.
2. Purposes for Collection, Use & Disclosure
Denman Housing Association collects and uses personal information about applicants and/or tenants for the following purposes:
- to assess the need for housing;
- to determine eligibility for housing provided by our organization;
- to assess any special needs an applicant may have with respect to housing, such as a need for accommodation of certain disabilities, and to determine our ability to accommodate these special needs;
- to assist applicants in filling out a rental accommodation application, if assistance is required;
- to verify information provided in the rental accommodation application;
- to provide for housing needs;
- to process payments for services provided, such as rental payments;
- to enable us to collect payments owing to us which are overdue;
- to enable us to communicate with applicants/tenants;
- to enable us to provide statistical information to potential funding organizations; and
- to enable us to protect the safety and security of the rental accommodation for our tenants and Denman Housing Association employees
Denman Housing Association will not collect, use or disclose information beyond that required to fulfill the specified purposes.
When personal information is to be used for a purpose not previously identified, the new purpose will be identified to the persons concerned prior to use.
Unless we hear otherwise from you, your use of Denman Housing Association‘s services and facilities constitutes consent for us to collect, use, and disclose personal information for the purposes stated in this Policy.
You may refuse or withdraw consent at any time, subject to legal and contractual restrictions and reasonable notice. Refusal or withdrawal of consent may prevent usfrom providing to you a service or access to our facilities.
You may refuse or withdraw consent by contacting us at DenmanHousing@gmail.com. Our staff will explain your options and any consequences of refusing or withdrawing consent, and will record your choices.
4. Disclosure of Information to Third Parties
The only circumstances under which personal information may be disclosed to third parties is for the fulfillment of any purposes identified above, with express consent, or as required by law. If personal information is disclosed to third parties for the fulfillment of any purposes identified above, Denman Housing Association will ensure that appropriate security undertakings, such as confidentiality clauses in contractual agreements, are employed to protect the transfer and use of personal information. Denman Housing Association does not sell, trade, or rent information to third parties.
5. Limiting Collection
We collect personal information only for the purposes identified above.
6. Limiting Use, Disclosure, and Retention
We do not use or disclose personal information for any purpose other than those for which it was collected, except as required by law, or with consent.
Personal information is retained only as long as is necessary for the fulfillment of the purposes for which it was collected, or as required by law.
Denman Housing Association will make all reasonable efforts to ensure that personal information is as accurate, complete, and current as required for the purposes for which it was collected. Denman Housing Association relies on applicants/tenants to ensure that certain information about them, such as their contact and reference information, is current, complete, and accurate. It is the applicant’s/tenant’s responsibility to inform Denman Housing Association if their personal information changes.
Denman Housing Association uses security safeguards to protect personal information. These safeguards are appropriate to the sensitivity of the information.
Denman Housing Association will make all reasonable efforts to protect personal information against loss or theft, as well as unauthorized access, disclosure, copying, use, or modification.
The security safeguards include:
- Physical measures (ie.: locked offices and/or filing cabinets;)
- Administrative measures (ie. immediate filing of all application forms; timely destruction of old files; protection of files in use from access by unauthorized persons;)
- Technological measures (ie. the use of passwords; assignment of user accounts; the implementation of firewalls for all computers accessing the Internet)
9. Individual Access
Individuals have the right to access their personal information under the control of Denman Housing Association. The Privacy Officer will assist them with their access requests. We will deal with access requests within 30 days of the request being made.
Access requests should be made, in writing, to the Privacy Officer at DenmanHousing@gmail.com. In certain exceptional situations, further to privacy legislation, we may not be able to provide access to certain personal information that we hold about applicants/tenants. Examples of where we may not provide access include, but are not limited to, the following:
where provision may reveal personal information about another individual;
where the information is subject to solicitor-client privilege;
where the information was collected in relation to the investigation of a breach of an agreement or a contravention of a federal or provincial law; or
where provision could reasonably be expected to threaten the health or safety of an individual.
If access cannot be provided, Denman Housing Association will notify the individual making the request, in writing, of the reasons for the refusal.
10. Openess Concerning Policies and Practices
Denman Housing Association will make available specific information about its policies and practices regarding the management of personal information. To contact us to obtain further information regarding our policies and practices, please refer to section 12 below.
12. Concerns or Questions Regarding Compliance
An individual may address a concern or question about compliance with this policy to Denman Housing Association‘s Privacy Officer, at DenmanHousing@gmail.com
Denman Housing Association will investigate any complaints received in writing.If a complaint is found to be justified, Denman Housing Association will take appropriate measures to resolve the complaint including, if necessary, amending its policies and procedures. An individual will be informed, in writing, of the outcomes of the investigation regarding his or her compliant.
Dated at Denman Island, this 23 day of July, 2013.