The Canadian Condominium Institute, ("CCI"), London & Area Chapter ("CCI London"), 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 and is, therefore, given the utmost priority.
2. Your Privacy Rights
From January 1, 2004, all organizations engaged in commercial activities must comply with the PIPEDA and the Canadian Standards Association Model Code for the Protection of PI which it incorporates. These obligations extend to the CCI London. The Act gives individual's rights concerning the privacy of their PI.
CCI London 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 London & Area Chapter Need PI
CCI London provides educational services and products to a wide range of members and some non-members. We require some PI to provide these services; to create and maintain membership lists; and to 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 an individual, or by which their identity could be deduced. If we did not collect and use PI we could not effectively provide our members with all our services.
PI collected from individuals include, but is not necessarily limited to, the following:
- name, home address, and home telephone and/or cell phone numbers
- e-mail address
- condominium name and address
- credit card information
- management firm, lawyer and auditor
- banking information, (eg. from your membership fee cheques)
- photographs and video recordings
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 PI directly from the member at the start of their membership and through annual renewals. Additional information may be obtained from individuals through course registration or through questionnaires on issues relating to condominium living.
Sometimes we may obtain information about individuals from other sources, for example:
- a management firm;
- a government agency or registry;
- another CCI chapter;
- the National offices of CCI
In most cases, we ask individuals to specifically consent in writing, if we collect, use, or disclose their PI. In some circumstances, we may accept an individual's oral consent, or an individual's consent may be implied through their conduct with us (for example, when a member provides us with PI when completing their membership form or annual renewal).
7. Use of Your Information
We use PI to provide our services to individuals and to include the individuals in any direct mailings of information relating to condominium living that we believe would be of some interest to our members. We also will use it for marketing activities such as notification of up-coming meetings, courses, seminars, conferences and CCI products. If an individual advises that they 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 London does not disclose an individual's PI to any third party, (other than to our National office) 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 London will disclose an individual's 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
- to up-date the National offices of CCI with your membership information
- where it is necessary to establish or collect membership fees
- 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. Use of Photographs and Video Recordings
We may take photographs or video recordings of individuals during CCI events or meetings. These photographs and/or video recordings are property of CCI London. An individual's picture, name and the captions referred to below may be used indefinitely by CCI London or anyone authorized by it, including but not limited to the National offices of CCI, in all materials pertaining to their business and/or the promotion of the CCI or condominium living.
The photographs may be cropped and re-sized as necessary to fit pre-defined formats and used in all forms of communications in any media, including but not limited to publicity, exhibitions, books, DVDs, television and web/digital media presentations.
Since participation in CCI London events and meetings is voluntary, individuals waive any payments or compensation for the use of photographs and video recordings.
10. Updating Your Information
Since we use an individual's PI to provide our services, it is important that the information be accurate and up-to-date.
If during the membership term any of the member's PI changes, please inform us so that we can make any necessary changes.
11. Is My PI Secure?
CCI London takes all reasonable precautions to ensure that all 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, safeguarding and use of PI
- 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.
12. Access to Your PI
Individuals may ask for access to any PI we hold relating to that themselves.
Summary information is available on request. More detailed requests that 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 below.
13. Correcting Errors
If CCI London holds information about an individual and the individual can establish that it is not accurate, complete and up-to-date, and we will take reasonable steps to correct it.
14. Can I be Denied Access to My PI?
In most cases, a member of CCI London will have access to the personal PI we store about them. However, there may be rare occasions when a member's request to access their own PI is denied, for example the PIPEDA indicates that:
- rights to access PI are not absolute
- denial of access is required or authorized by law
- when granting access would have an unreasonable impact on other people's privacy;
- when to do so would prejudice negotiations with you
- to protect CCI London and CCI National's rights and property; or
- where the request is frivolous or vexatious
If we deny a request for access to, or refuse a request to correct information, we will endeavor to explain why.
15. Can I request anonymity.
Whenever it is legal and practicable, we may offer the opportunity to deal with general inquiries without providing a member's name (for example, by accessing general information on our website).
16. Credit Bureaus
On occasion we may request information about an individual from the files of consumer agencies or file complaints with those agencies, such as where an individual has failed to pay a debt owed to us.
17. Communicating with CCI London by E-Mail
Individuals should be aware that e-mail is not a 100 percent secure medium and use caution if sending personal or confidential information or requesting CCI London to respond by e-mail.
19. Requests for Information Access and/or Corrections
Individuals with questions or wishing to access their PI are to write to our Privacy Contact, Trish Kaplan, at:
CCI London & Area Chapter
P.O. Box 51022
1593 Adelaide Street North
London, ON N5X 4P9
Tel: (519) 453-0672
If an individual is 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.
20. Employment Inquiries
If an individual applies to CCI London for a job, we need to consider their PI, as part of our review process. We normally retain information from candidates after a decision has been made, unless that candidate asks us not to retain the information. If a job is offered and accepted, the information will be retained in accordance with our privacy procedures for employee records.
21. Web Site
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.
CCI London & Area Chapter