Effective January 1, 2014
At Compass Commercial Realty Limited (Compass), we are committed to providing our clients and customers with exceptional service. As providing this service involves the collection, use and disclosure of some personal information about our clients and customers protecting their personal information is one of our highest priorities.
We will inform our clients and customers of why and how we collect, use and disclose their personal information, obtain their consent where required, and only handle their personal information in a manner that a reasonable person would consider appropriate in the circumstances.
Collection of Information
Unless the purposes for collecting personal information are obvious and the client or customer voluntarily provides his or her personal information for those purposes, we will communicate the purposes for which personal information is being collected, either orally or in writing, before or at the time of collection.
We will only collect client and customer information that is necessary to fulfill the following purposes:
- To verify identity;
- To verify creditworthiness;
- To identify the client/customer preferences;
- To understand the financial, banking, insurance needs of our clients and customers
- To deliver requested products and services
- To ensure a high standard of service to our clients and customers
- To meet regulatory requirements;
- To assess suitability for tenancy;
- To collect and process rent payments;
- We will obtain client/customer consent to collect, use or disclose personal information (except where, as noted below, we are authorized to do so without consent).
- Consent can be provided orally, in writing, or electronically through an authorized representative of Compass Commercial Realty or it can be implied where the purpose for collecting using or disclosing the personal information would be considered obvious and the client/customer voluntarily provides personal information for that purpose.
- Consent may also be implied where a client/customer is given notice and a reasonable opportunity to opt-out of his or her personal information being used for mail-outs, the marketing of new services or products, fundraising and the client/customer does not opt-out.
- Subject to certain exceptions (e.g., the personal information is necessary to provide the service or product, or the withdrawal of consent would frustrate the performance of a legal obligation), clients and customers can withhold or withdraw their consent for Compass to use their personal information in certain ways. A client/customer’s decision to withhold or withdraw their consent to certain uses of personal information may restrict our ability to provide a particular service or product. If so, we will explain the situation to assist the client/customer in making the decision.
- We may collect, use or disclose personal information without the client/customer’s knowledge or consent in the following limited circumstances:
- When the collection, use or disclosure of personal information is permitted or required by law;
- In an emergency that threatens an individual’s life, health, or personal security;
- When the personal information is available from a public source (e.g., a telephone directory);
- When we require legal advice from a lawyer;
- For the purposes of collecting a debt;
- To protect ourselves from fraud;
- To investigate an anticipated breach of an agreement or a contravention of law
Using and Disclosing Personal Information
- We will only use or disclose client and customer personal information where necessary to fulfill the purposes identified at the time of collection such as:
- To conduct client/customer surveys in order to enhance the provision of our services;
- To contact our clients and customers directly about products and services that may be of interest;
- We will not use or disclose client/customer personal information for any additional purpose unless we obtain consent to do so
- We will not sell client or customer lists or personal information to other parties.
Retaining Personal Information
- If we use client or customer personal information to make a decision that directly affects the client or customer, we will retain that personal information for at least one year so that the client or customer has a reasonable opportunity to request access to it.
- We will retain client or customer personal information only as long as necessary to fulfill the identified purposes or a legal or business purpose.
Ensuring Accuracy of Personal Information
- We will make reasonable efforts to ensure that client or customer personal information is accurate and complete where it may be used to make a decision about the client or customer or disclosed to another organization.
- Clients and Customers may request correction to their personal information in order to ensure its accuracy and completeness. A request to correct personal information must be made in writing and provide sufficient detail to identify the personal information and the correction being sought.
- If the personal information is demonstrated to be inaccurate or incomplete, we will correct the information as required and send the corrected information to any organization to which we disclosed the personal information in the previous year. If the correction is not made, we will note the clients’ or customers’ correction request in the file.
Securing Personal Information
- We are committed to ensuring the security of client and customer personal information in order to protect it from unauthorized access, collection, use, disclosure, copying, modification or disposal or similar risks.
- We will use appropriate security measures when destroying clients or customers personal information such as shredding documents and deleting electronically stored information.
- We will continually review and update our security policies and controls as technology changes to ensure ongoing personal information security.
Providing Clients and Customers Access to Personal Information
- Clients and Customers have a right to access their personal information, subject to limited exceptions.
- A request to access personal information must be made in writing and provide sufficient detail to identify the personal information being sought.
- Upon request, we will also tell clients and customers how we use their personal information and to whom it has been disclosed if applicable.
- We will make the requested information available within 30 business days, or provide written notice of an extension where additional time is required to fulfill the request.
- If a request is refused in full or in part, we will notify the client or customer in writing, providing the reasons for refusal and the recourse available to the client or customer.
Questions and Complaints: The Role of the Privacy Officer or designated individual
- The Privacy Officer or designated individual is responsible for ensuring Compass’ compliance with this policy and the Personal Information Protection Act.
- Clients and Customers should direct any complaints, concerns or questions regarding Compass’ compliance in writing to the following designated individual:
Anne Marie Byrne