CANADIAN CONDOMINIUM INSTITUTE
Toronto and Area Chapter
The Canadian Condominium Institute, ("CCI"),
Toronto and Area Chapter, provides a broad range of services to our members. We
have a longstanding policy of protecting the privacy of our members in the
course of providing services to them. Our relationship with our members
is based upon trust and maintaining member privacy is, therefore, given
the utmost priority.
of principles and guidelines that we have adopted for the protection of
personal information, ("PI") we may collect for or on behalf of
responsible practices in the management of PI in accordance with the provisions
of the PI Protection and Electronic Documents Act, ("PIPEDA").
This policy is organized according to the principles of the Canadian Standard's
Associations Model Code, which forms the basis of that law.
The CCI Toronto and Area Chapter recognizes the importance
of privacy and the sensitivity of PI. We understand that we have an obligation
to keep confidential all PI we receive from our members. We are committed
your PI and safeguard your privacy.
2. Your Privacy Rights
From January 1, 2004, all organizations engaged
in commercial activities must comply with the PI Protection and Electronic
Documents Act and the Canadian Standards Association Model Code for
the Protection of PI which it incorporates. These obligations extend to
the CCI Toronto and Area Chapter. The Act gives you rights concerning the
privacy of your PI.
CCI Toronto and Area Chapter is responsible for the PI we collect
and hold. To ensure this accountability, we have developed this policy,
and trained our directors and support staff about our policies and practices.
3. Why Does CCI Toronto and Area Chapter Need PI
CCI Toronto and Area Chapter provides educational services and products
to a wide range of members. We require some PI to provide theses services
to you; create and maintain membership lists; and produce direct marketing
materials concerning our services and developments in the condominium community.
4. What PI do we collect?
PI is any information that identifies you, or by
which your identity could be deduced. If we did not collect and use your
PI we could not provide you with our services.
PI that we collect includes, but is not necessarily limited
to, the following:
- your name, home address, and home telephone and/or cell
- your e-mail address;
- your condominium name and address;
- credit card information;
- management firm, lawyer and auditor;
- banking information, (eg. from your membership fee cheques);
5. How do we collect your PI?
We collect information only by lawful and fair
means and not in an unreasonably intrusive way. Wherever possible we collect
your PI directly from you at the start of your membership and through annual
renewals. Additional information may be obtained through course registration
or through questionnaires on issues relating to condominium living.
Sometimes we may obtain information about you from other
sources, for example:
- your management firm;
- from a government agency or registry;
- from CCI chapters.
In most cases, we shall ask you to specifically
consent, if we collect, use, or disclose your PI. Normally, we ask for your
consent in writing but in some circumstances, we may accept your oral consent.
Sometimes, your consent may be implied through your conduct with us, for
example when you provide us with PI when completing your membership form
or annual renewal.
7. Use of Your Information
We use your PI to provide our services to you
and to include you in any direct mailings of information relating to condominium
living that we believe would be of some interest to you. We also will use
it for marketing activities such as notification of up-coming meetings,
courses, seminars, conferences and CCI products. If you tell us that you
no longer wish to receive information about our services, seminars or about
new developments in the law, we will not send any further material.
CCI Toronto and Area Chapter does not disclose your PI to any third
party, (other than CCI National) to enable them to market their
products and services. For example, we do not provide our client mailing
lists to other organizations or businesses. On occasion other organizations,
such as the Association of Condominium Managers of Ontario, ("ACMO")
will forward complimentary publications to us to distribute to our members
but they do not receive our membership list.
8. Disclosure of your PI
Under certain circumstances, CCI Toronto and Area Chapter
will disclose your PI:
- when we are required or authorized by law to do so, for
example, if a court issues a subpoena;
- when you have consented to the disclosure;
- o up-date CCI Chapters with your membership information;
- where it is necessary to establish or collect membership
- if we engage a third party to provide administrative
services to us (such as a mailing service or archival file storage) and
- if we retain agents or consultants to assist us in completing
research relating to CCI or condominium living;
- if the information is already publicly known.
In these instances we will only disclose such PI as is
required in the circumstances.
9. Updating Your Information
Since we use your PI to provide our services to
you, it is important that the information be accurate and up-to-date.
If during the course of your membership any of your PI
changes, please inform us so that we can make any necessary changes.
10. Is My PI Secure?
CCI Toronto and Area Chapter takes all reasonable precautions
to ensure that your PI is kept safe from loss, unauthorized access, modification
or disclosure. Among the steps taken to protect your information are:
- premises security;
- employee training in the storage, safe guarding and use
- restricted file access to PI;
- deploying technological safeguards such as security software
and firewalls to prevent hacking or unauthorized computer access; and
- internal password and security policies.
If we use the services of any third parties to process
or store PI, we will enter into an agreement which requires them to protect
this PI in a manner acceptable to us. In entering into these agreements,
we do not transfer any interest in this PI to them. This is done to ensure
that the PI delivered to third parties is maintained at a level equivalent
11. Access to Your PI
You may ask for access to any PI we hold about
Summary information is available on request. More detailed
requests which require archive or other retrieval costs may be subject to
a reasonable fee.
We also reserve the right to confirm the identity of the
person seeking access to PI before complying with any access requests.
Please submit your access request in writing or e-mail to our privacy officer
as identified in paragraph 18.
12. Correcting Errors
If CCI Toronto and Area Chapter holds information about
you and you can establish that it is not accurate, complete and up-to-date,
and we will take reasonable steps to correct it.
13. Can I be Denied Access to My PI?
In most cases, a member of a CCI chapter will have access to the PI we store
about you. However, there may be rare occasions when your rights to access
your PI are denied, for example the PIPEDA indicates that:
- your rights to access your PI are not absolute;
- denial of access is required or authorized by law;
- when granting you access would have an unreasonable impact
on other people's privacy;
- when to do so would prejudice negotiations with you;
- to protect CCI Toronto and Area Chapter and CCI Chapters' rights
and property; or
- where the request is frivolous or vexatious.
If we deny your request for access to, or refuse a request
to correct information, we will endeavor to explain why.
14. Can I request anonymity.
Whenever it is legal and practicable, we may offer
the opportunity to deal with general inquiries without providing your name
(for example, by accessing general information on our website).
15. Credit Bureaus
On occasion we may request information about you
from the files of consumer agencies or file complaints with those agencies,
such as where a member has failed to pay a debt owed to us.
16. Communicating with Us By E-Mail and/or Fax
You should be aware that e-mail and fax are not
a 100% secure medium, and you should be aware of this when contacting us
to send personal or confidential information or requesting us to respond
to you by e-mail.
Since CCI Toronto and Area Chapter regularly reviews all
to time. These changes will be posted to our web-site as soon as is practical.
18. Requests for Information Access and/or Corrections
If you have any questions, or wish to access your
PI, please write to our Privacy Contact, Ms Diane Gaunt at:
CCI Toronto and Area Chapter
2175 Sheppard Ave. E., Suite 310
Toronto, ON M2J 1W8
Tel: (416) 491-6216
If you are not satisfied with our response, the Privacy
Commissioner of Canada can be reached at:
112 Kent Street
Ottawa Ontario, K1A 1H3
We may seek external advice, where appropriate, before
providing a final response to individual complaints.
19. Employment Inquiries
If you apply to CCI Toronto and Area Chapter for a job,
we need to consider your PI, as part of our review process. We normally
retain information from candidates after a decision has been made, unless
you ask us not to retain the information If we offer you a job, which you
accept, the information will be retained in accordance with our privacy
procedures for employee records.
20. Web Site
Our website contains links to other sites, which
On our website, like most other commercial websites, we
may monitor traffic patterns, site usage and related site information in
order to optimize our web service. We may provide aggregated information
to third parties, but these statistics do not include any identifiable PI.
Thank you for taking the time to review our
CCI Toronto and Area Chapter
"The Voice Of Condominiums"