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Privacy of personal information is an important principle to Sifton Properties Limited. We are committed to collecting, using and disclosing personal information responsibly and only to the extent necessary for providing the quality goods and services of our business to our customers. We also endeavour to be open and transparent as to how we handle personal information. This document describes our privacy policies.
Personal information is any information that can be used to identify an individual. This information includes information that relates to an individual’s personal data or characteristics, their health or their activities and views. In most circumstances, personal information does not include information that might appear on a business card, or information that is available in public records.
Sifton Properties Limited provides a variety of quality goods and services in the following areas:
We follow 10 principles when collecting, using and disclosing your personal information:
By providing us with your personal information, you consent to the collection, use and disclosure of that information. We will not, as a condition of supplying a product or service, require you to consent to the collection, use or disclosure of your personal information beyond that required to enable us to provide the products or services requested. The form of the consent that we will seek before collecting, using or disclosing personal information will vary depending upon the circumstances and the type of information, and includes express oral or written consent, implied consent or opt-out consent. We will consider the sensitivity of the information and the individual’s reasonable expectations in determining how consent must be given.
It would be rare for us to collect any personal information without the customer’s, tenant’s or resident’s express consent, but this might occur in a case of urgency where we believe the individual would consent if asked and it is impractical to obtain consent, appropriate public sources or if it is necessary to investigate a breach of the customer’s agreement or a contravention of the law, or enforce an agreement you have with us.
You may refuse to give personal information and may, subject to legal or contractual restrictions and reasonable notice, withdraw consent at any time to the continued use and disclosure of personal information previously collected. The period of reasonable notice will vary depending on the nature of the information and its’ purpose to the company. We will inform you of the implications of refusing or withdrawing consent, which may have legal consequences or preclude us from providing the services or other consideration requested.
We collect, use and disclose personal information in order to serve our customers, tenants and residents. For most of our customers, the primary purposes for collecting personal information as per PIPEDA are:
Examples of the type of information we collect may include the following:
Residential Rentals
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, but not be limited to, the following types of information:
We may then confirm this information and check references and the conduct history of the prospective tenants. This may include following up with other individuals identified during the course of these inquiries as having relevant information, including 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 may also check appropriate public sources such as 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.
Retirement Living
We collect, use and disclose and store personal information about residents at our retirement residences, in order to provide residential, recreational and health care services. This would include the following types of personal information:
We use this information to:
Details regarding how residents’ personal health care information is collected, used and disclosed within Retirement Living is available by accessing Sifton’s Personal Health Information Protection Act (PHIPA) Policy, at www.sifton.com.
New Home Purchases
Purchasers of new homes complete a written consent which details the collection, use and disclosure of personal information to financial institutions, marketing, insurance, trades/suppliers, solicitors, government agencies and any other third parties involved in Sifton new home sales and construction process.
Golf Community
Residents of the golf community and club members are advised of the requirements for the collection, use and disclosure of personal information within the gated community as it pertains to security, membership, fitness services, involvement and promotion of committees, special events and other activities, website access and available web services, fee collection, account information review and use of other products and services provided within the community. We may also require digital photos for identification and security purposes.
Commercial Leasing and Third Party Management
Prospective commercial tenants are required to provide detailed business and/or personal credit information when applying to lease commercial property. The application will include details of the collection, use and disclosure of the personal information requested that are required by any third parties involved in the property management, financing, amenities, construction and renovations of the leased property.
Express consent may be obtained from individuals in commercial properties to provide a digital photo, for identification and security purposes. Photos will be accessed exclusively by authorized personnel and will be electronically stored on the password protected security computer equipment.
Public Directories
As a service and convenience for tenants, residents, club members or other customers, we may maintain public directories such as front door directories, phone listings or membership directories. If you do not wish to be listed in any directories or wish to be described in a particular way, please let us know.
General Public Information
For members of the general public, our primary purpose for collecting personal information is to promote the safety of customers, tenants and residents and the enhance the security of the property. For example we, or our clients, may operate security cameras, restrict entry, record license plate numbers, or monitor the presence of vehicles. Security cameras may also monitor the movement and conduct of visitors and others on and about our various properties. We believe that the collection of this information is necessary to support the provision of services and security of the properties and that of our residents, tenants and customers.
Secondly, we may gather personal information in the course of marketing and promoting our property or services to prospective customers, tenants or residents. This information is collected either from appropriate public sources including telephone or service directories, or directly from the individuals, with their consent. Personal information may also be collected through the operation of video cameras which monitor operations at our properties for marketing purposes.
Government Agencies
Various government agencies have the authority to review our files and interview our staff as a part of their mandates.
If a tenant’s or resident’s rent or fees are paid for by a third party such as an employer, trustee or government agency, we may be asked to provide them with certain information. These third party payers often have consent or legislative authority to direct us to collect and disclose to them certain information in order to demonstrate entitlement to and responsible use of this funding.
Website Information
When you access and use our website we may collect some personal information relative to activities, products and services shown on the website. You may also be providing us with information regarding your financial and employment status to facilitate financing or approval of an application or information about your purchase patterns, personal preferences and demographics. We will use and retain your personal information for the following purposes:
We prohibit the sale, transfer or sharing of personal information with third parties for any other purposes than those identified, without your consent, unless it is required by law.
When we collect personal information from you we will make you aware of the purpose(s) for collecting, using or disclosing the information and obtain your consent in an appropriate fashion consistent with the sensitivity of the information.
Applications for Employment
Personal information collected from resumes and applications for employment received by the Corporation will be used to facilitate the recruiting process. Candidates who apply electronically through the Corporation’s career site and submit documents must do so in PDF format. To facilitate this process, the candidate may choose to forward their resume to a third party via the career site, which will transfer the document to PDF format and forward it back to the Corporation for use with the application for employment.
Although there may or may not be current vacancies, resumes are kept for six months for future consideration.
Suppliers and Contractors
We often deal with agents, suppliers, contractors and sub-contractors who provide goods, care and services to our customers and assist with maintaining the properties we manage. We monitor their performance, including their promptness, reliability, quality and value of services.
The consultants we use have restricted access to any personal information we hold. We also have their assurance that they follow appropriate privacy principles.
We may disclose limited personal information to suppliers of various services, such as telecommunications service providers, so that they can make available their services to new and existing customers, tenants and residents.
We may also disclose personal information to insurers, lenders, or prospective purchasers of properties we own or manage.
We understand the importance of protecting personal information. For that reason, we have taken the following steps:
We need to retain personal information for some time to ensure that we can answer any questions regarding the goods or services provided and for our own accountability to external regulatory bodies.
Tenants, residents, clients or other individuals we deal with may have questions about the goods and services they received. We also provide ongoing services for many tenants, customers and clients over a period of months or years for which the retention of service records is necessary.
We retain information for as long as it is needed for the purposes for which it was collected. We may also be subject to legislative requirements regarding the length of time for retention of certain types of information.
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.
With some exceptions, you have the right to see what personal information we hold about you. 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. 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, we will make the correction.
Sifton Properties Limited reserves the right to change this Privacy Policy from time to time. We recommend that you periodically review this Privacy Policy, which is posted on our website at www.sifton.com, so that you are aware of any changes. Any amendments to the Sifton privacy Policy will be effective from the date that it is posted on the Sifton web site. 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.
If you have any questions or concerns about how we collect and share your information, please contact the senior manager at your local Sifton office or Seniors’ Living site.
Our Corporate Privacy Information Officer can be reached at:
Sifton Properties Limited,
1295 Riverbend Road
London, ON N6K 0G2
Phone 519-434-1000
Fax 519-434-1009
If you have any questions about this policy and the company’s handling of your personal information, please contact us. We will investigate and respond to your concerns.
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 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
www.privcom.gc.ca
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