Privacy Policy for the Collection, Use, Disclosure and Security of Personal Information
Privacy of personal information about the unit owners, tenants and residents of the properties we manage is a fundamental cornerstone of our role as property managers and agents for condominium corporations, absentee owners of condominium units and landlords. We understand an individual’s right to privacy and we are committed to collecting, using, disclosing and securing your personal information responsibly and for no other purposes beyond the need to efficiently and effectively provide management services to you and to our clients.
Crossbridge Condominium Services Ltd. has adopted the following privacy policy to meet this commitment.
Introduction
Crossbridge Condominium Services Ltd. (hereinafter called “Crossbridge”) is a company that provides property management services to condominium corporations, non-resident owners of condominium units and landlords of rental residential properties (hereinafter called “Clients”). In the course of servicing these Clients, Crossbridge may collect certain personal information from condominium unit owners, tenants in condominium units and tenants or prospective tenants in rental residential properties (hereinafter called “Individuals”) necessary to carry on its activities as a managing agent for its Clients.
“Personal Information” means information that is personally identifiable to individuals. This may include, without limitation, the Individual’s name, address, telephone number, e-mail address, bank account number, payment histories and other information about his or her family in the case of a condominium unit owner and may further include, without limitation, age, income, employment status, credit history and debts and liabilities in the case of a tenant or a prospective tenant in condominium units or rental apartment buildings managed by Crossbridge.
This Privacy Policy is based on, and complies with, Canada’s Personal Information Protection and Electronic Documents Act (“PIPEDA”), which includes the Ten Privacy Principles outlined in the National Standard of Canada entitled Model Code for the Protection of Personal Information and similar provincial legislation.
This Privacy Policy sets out the ten principles that Crossbridge follows to ensure that we protect our Individuals’ and employees’ personal information when we collect, use or disclose it in the course of carrying on business activities in Canada. These correspond to similar principles contained in PIPEDA. All of our employees who have access to personal information must adhere to the Crossbridge Privacy Policy and related procedures.
Crossbridge’s Dedication to the Ten Principles of Privacy
The following ten principles govern our actions as they relate to the use of personal information of Individuals and others:
- Principle 1 - Accountability
- Principle 2 - Identifying Purposes
- Principle 3 - Consent
- Principle 4 - Limiting Collection
- Principle 5 - Limiting Use, Disclosure and Retention
- Principle 6 - Accuracy
- Principle 7 - Safeguards
- Principle 8 - Openness
- Principle 9 - Individual Access
- Principle 10 - Questions and Concerns
Principle 1 - Accountability
Crossbridge is accountable for all personal information in its possession or custody, including personal information disclosed to third parties for purposes of providing services requested by our Clients, prospective Clients or others. To this end, Crossbridge has appointed a Privacy Officer who has ultimate responsibility for ensuring compliance within Crossbridge and by all Crossbridge employees. Through its policies and procedures, Crossbridge will strive to implement this Privacy Policy throughout all of its operations. Crossbridge will seek to include in contractual arrangements with suppliers provisions requiring them to provide an appropriate level of protection for information transferred to them by Crossbridge.
Crossbridge will seek to include in contractual arrangements with suppliers provisions requiring them to provide an appropriate level of protection for information transferred to them by Crossbridge.
Principle 2 - Identifying Purposes
Crossbridge will identify the purposes for which it is collecting any personal information by such means as is appropriate in the circumstances. This may include providing disclosure orally, by telephone, or in person, providing disclosure in a contract or in other written information given to an Individual, posting a notice on Crossbridge’s website or any other means deemed appropriate in the circumstances.
In some instances, where the purpose for collecting information is reasonably evident to the person providing the information, the purpose will be implied but not explicitly stated (for instance, on rental applications, when a potential tenant provides us with his or her income and banking information or on Pre-Authorized Payment applications when a unit owner authorizes the condominium corporation to withdraw monthly common charges from an Individual’s bank account).
Principle 3 - Consent
Crossbridge will seek to obtain consent from an Individual before or when it collects, uses or discloses personal information except as described below. Crossbridge will strive to ensure that Individuals understand how their personal information will be used or disclosed. Consent can be expressed (i.e. given orally, electronically or in writing), implied or given through an authorized representative. Consent may be implicit when the purposes are not stated expressly but are implied by the circumstances of the transaction or follow logically from other expressly stated purposes). You can withdraw consent at any time, with certain exceptions (for example, subject to any legal or contractual restrictions) and upon reasonable notice to Crossbridge. Crossbridge will strive to inform an Individual of all implications of withdrawing his or her consent. You may contact Crossbridge’s Privacy Officer respecting the withdrawal of any previously given consent or any change in the purposes for which information held by Crossbridge may be used, disclosed or retained. Note that information may be retained by Crossbridge for audit or archival purposes notwithstanding any withdrawal of consent otherwise applicable but the fact that consent has been withdrawn will be noted so as to prevent an unauthorized use. Crossbridge, however, may collect, use or disclose personal information without the an Individual’s knowledge or consent in exceptional circumstances where such collection, use or disclosure is permitted or required by law.
Principle 4 - Limiting Collection
Crossbridge will only collect information that is reasonably necessary for the purposes identified. Information will be collected by fair and lawful means.
Principle 5 - Limiting Use, Disclosure and Retention
Personal information will only be used or disclosed for the purpose for which it was collected unless an Individual has otherwise consented, or when it is required or permitted by law. Personal information may only be retained for the amount of time needed to fulfill the purpose for which it was collected. In certain exceptional circumstances, Crossbridge may have a legal duty or right to disclose personal information without an Individual’s knowledge or consent with respect to matters that concern the public’s interest.
Principle 6 - Accuracy
Crossbridge will keep personal information as accurate, complete and current as necessary to fulfill the identified purposes for which it was collected. Crossbridge will update or correct any personal information held by it if the individual concerned provides Crossbridge with particulars, satisfactory to it, of any required updating or correction.
Principle 7 - Safeguarding Personal Information
Personal information is safeguarded to protect against loss, theft or unauthorized access, disclosure, use or modification of information using measures appropriate to the sensitivity, amount, format, nature and storage of the information and will involve, as applicable, physical, organizational and electronic security measures. Crossbridge has controls in place to maintain the security of its information and information systems. Files are stored according to the sensitivity of the information contained therein. Appropriate controls (such as restricted access) using user I.D.’s and passwords are placed on our computer systems and data processing procedures. Physical access to areas where personal information is gathered, processed or stored is limited to authorized employees.
Crossbridge has controls in place to maintain the security of its information and information systems. Files are stored according to the sensitivity of the information contained therein. Appropriate controls (such as restricted access) using user I.D.’s and passwords are placed on our computer systems and data processing procedures. Physical access to areas where personal information is gathered, processed or stored is limited to authorized employees.
Principle 8 - Openness
Crossbridge will make information available to Individuals and its Clients and others about the policies and procedures Crossbridge uses to manage personal information. Individuals and Clients have access to much of this information through our web site, or through written correspondence with Crossbridge’s Privacy Officer.
Principle 9 - Individual Access
As an Individual, you have the right to access the personal information we keep in your file and you have the right to verify or amend the information if it is shown to be inaccurate.
If you would like to view the personal information held in your file, please make a written request to Crossbridge’s Privacy Officer. Crossbridge will respond to your request as efficiently as possible and will advise of the individual cost, if any, prior to the retrieval of such records. Crossbridge will not respond to frivolous or vexatious requests for access to information. If Crossbridge is prohibited from providing such access it will explain the reasons, except where prohibited by law. To make a change to your personal information (as discussed under “Accuracy” above), please make a similar request in writing to the Privacy Officer.
Principle 10 - Questions or Concerns
Crossbridge has policies and procedures to receive, investigate and respond to any questions or concerns respecting this Privacy Policy or the personal information that we hold. Individuals may contact the Crossbridge’s Privacy Officer with any questions or concerns or to request access to their personal information. Specific Information about our Use and Disclosure of Your Personal Information:
The Kind of Information We Collect
Crossbridge gathers and uses personal information as described below. Providing us with your personal information is your choice; however, we may not be able to provide you with certain products or services if you do not provide us with certain information nor will we be able to fulfill contractual obligations to third parties. For example, we may not be able to contact you in an emergency at your place of residence if we do not have your contact information away from your residence or if you withdraw your consent to disclose your contact information to our Clients or their employees or contractors who provide some of the products or services you have requested.
The nature of our relationship with you will determine the kind of personal information we might ask for.
Information that is typically required to provide you and the Clients we service with our products and services includes, but is not limited to:
Condominium Unit Owners
Name
Address
Phone Number(s)
E-mail Address
Name of Mortgagee on the unit
Bank Account Number
Persons Residing with you
Address of Seasonal Property
Other Phone Number
Name of Emergency Contact and Contact Information
Vehicle Information Including License Plate Number
Any Special Needs of Owners
Tenants
Name
Address
Phone Number(s)
Social Insurance Number
Employment Status
Credit History
Past Tenancy History
Bank Account Number
Income
Co-occupant Information (name, date of birth, relationship to prospective tenant)
Vehicle Information Including License Plate Number
Intended Use of Premises
Any Special Needs of Tenants
In addition, information other than as set out in the definition of personal information (above), may also be collected from time to time.
Special Note for Tenants or Prospective Tenants Only
Crossbridge subscribes to a consumer reporting service. This service provides information to Crossbridge about prospective tenants. In return, on behalf of our Clients, we provide information to the service for the purpose of assessing your credit worthiness and checking references. We obtain your consent for using the consumer reporting service in the rental application form. If you have an existing tenancy agreement with us and you wish to renew the agreement, it is assumed that the consent you gave to us when signing the tenancy agreement remains in effect. If you sign an application to rent for your family or anyone else, you are representing that you have obtained their consent for the collection , use and disclosure of their personal information for the purposes set out in this Policy.
When Do We Disclose or Share Your Personal Information?
(i) When Authorized By You
Many of the services offered by Crossbridge and/or its Clients require us to obtain personal information about you in order to perform the services we have been engaged by you to provide. We will use and disclose this information to provide programs to meet your needs and objectives.
ii) To Crossbridge’s Clients, their Employees and Agents
We act as agents for our condominium corporations and landlords. Thus, we may periodically share or transfer any personal information we collect relevant to a particular Individual with that Client or with that Client’s employees, third party suppliers or contractors. Out Clients use a number of employees, third party service providers, consultants and other agents that may in the course of their duties have limited access to personal information we retain. These include building superintendents, maintenance staff, recreation centre attendants, concierge, security staff, housekeeping staff, consultants, temporary employees or employees of third party suppliers, auditors, lawyers and others. We restrict their access to any personal information we hold except to the extent necessary for them to reasonably perform their role on behalf of our Client. The purpose of disclosing personal information to our Clients or their agents and employees is to ensure an Individual’s safety, security and reasonable enjoyment of their place of residence, to ensure Individuals have access to their premises and services that our Clients have agreed to provide, to preserve our Client’s property and to collect monies owing to those Clients for the provision of services to Individuals. Suppliers and Client employees are contractually bound to protect the confidentiality of your personal information, and they are prohibited from doing anything with this information that we have not authorized them to do. They are required to treat your personal information in a manner consistent with the Crossbridge Privacy Policy.
Suppliers and Client employees are contractually bound to protect the confidentiality of your personal information, and they are prohibited from doing anything with this information that we have not authorized them to do. They are required to treat your personal information in a manner consistent with the Crossbridge Privacy Policy
(iii) When Required or Permitted By Law
The type of information we are legally required to disclose usually relates to government tax reporting requirements. However in some cases, such as under a court order, we may be required to disclose certain information to persons specified in the court order. We will only provide the specific information requested and only upon being satisfied that the authorities have legitimate grounds to obtain the information. Crossbridge may also disclose information without your consent when permitted by law including in situations involving medical emergencies, collection of a debt and suspicion of illegal activities.
Web Site (Security)
In order to serve you better, Crossbridge Clients have access to certain information through its web site www.crossbridgecs.com which provides general information about the Company and the products and services it offers.
Crossbridge is committed to your privacy and strives to ensure that any information you access or provide through this site remains secure.
Anonymous Information
Crossbridge may collect anonymous information about you. This means that the information collected cannot be traced back to a specific person. For example, our web servers may record certain information automatically when you visit our web site. This information is collected using “cookies” and might include the pages you visited, your Internet Protocol address and other site usage statistics. This anonymous information is used for research and analytical purposes only (ie. evaluating how many visitors our web sites receive or which pages they visit most often). It does not reveal any personal information about you, the user. This aggregate data may be disclosed to third parties, but never with personally identifying information.
Contact Information (Questions, Concerns and Complaints)
If you have any questions or concerns about your personal information, or about the Crossbridge Condominium Services Ltd. Privacy Policy, please contact our Privacy Officer using the contact information below:
Contact Information:
Privacy Officer, Crossbridge Condominium Services Ltd., 111 Gordon Baker Road, Suite 700, North York, ON, M2H 3R1; privacyofficer@crossbridgecs.com.