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CANADIAN CONDOMINIUM INSTITUTE
LONDON & AREA CHAPTER
Privacy Policy
The Canadian Condominium Institute, ("CCI"),
London & 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 and
is, therefore, given the utmost priority.
The CCI London & Area Chapter Privacy Policy
is a formal statement of principles and guidelines that we have adopted
for the protection of personal information, ("PI") we may collect
for or on behalf of our members. Our objective in developing this Privacy
Policy is to promote 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.
1. Privacy Policy
The CCI London & 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 to protecting any PI we hold. This Privacy Policy outlines
how we manage 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 London & Area Chapter. The Act gives you rights concerning
the privacy of your PI.
CCI London & 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 London & Area Chapter Need
PI
CCI London & 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
phone numbers;
- 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 another CCI chapter; or
- from the National offices of CCI .
6. Consent
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 London & Area Chapter does not disclose
your 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 &
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;
- to up-date the National offices of CCI with your membership
information;
- where it is necessary to establish or collect membership
fees;
- if we engage a third party to provide administrative
services to us (such as
- a mailing service or archival file storage) and the third
party will be bound by our Privacy Policy;
- 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 London & 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, 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.
If we use the services of any third parties to process
or store PI, we will enter into an agreement that 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
to that provided for under this Privacy Policy.
11. Access to Your PI
You may ask for access to any PI we hold about you.
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 in paragraph 18.
12. Correcting Errors
If CCI London & 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 CCI London & Area 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 London & Area Chapter and CCI
National's 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
You should be aware that e-mail is 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.
17. Changes to this Privacy Policy
Since CCI London & Area Chapter regularly reviews all of its
policies and procedures, we may change our Privacy Policy from time 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, Gina Darlene, at:
CCI London & Area Chapter
P.O. Box 51022
1593 Adelaide Street North
London, ON N5X 4P9
Tel: (519) 453-0672
E-mail: ccisw@cci-sw.on.ca
If you are not satisfied with our response, the Privacy
Commissioner of Canada can be reached at:
112 Kent Street
Ottawa Ontario, K1A 1H3
1-800-282-1376.
We may seek external advice, where appropriate, before
providing a final response to individual complaints.
19. Employment Inquiries
If you apply to CCI London & 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 are not governed by this
Privacy Policy.
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 Privacy Policy.
CCI London & Area Chapter
"The Voice Of Condominiums"
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