Privacy of personal information about the unit owners, tenants and residents of the properties we manage is a fundamental cornerstone of our role as property managers and agents for condominium corporations, absentee owners of condominium units and landlords. We understand an individual’s right to privacy and we are committed to collecting, using, disclosing and securing your personal information responsibly and for no other purposes beyond the need to efficiently and effectively provide management services to you and to our clients.
CityTowers Property Management Inc. has adopted the following privacy policy to meet this commitment.
Introduction
CityTowers Property Management Inc. (hereinafter called “CityTowers”) is a company that provides property management services to condominium corporations, non-resident owners of condominium units and landlords of rental residential properties (hereinafter called “Clients”). In the course of servicing these Clients, CityTowers may collect certain personal information from condominium unit owners, tenants in condominium units and tenants or prospective tenants in rental residential properties (hereinafter called “Individuals”) necessary to carry on its activities as a managing agent for its Clients.
“Personal Information” means information that is personally identifiable to individuals. This may include, without limitation, the Individual’s name, address, telephone number, e-mail address, bank account number, payment histories and other information about his or her family in the case of a condominium unit owner and may further include, without limitation, age, income, employment status, credit history and debts and liabilities in the case of a tenant or a prospective tenant in condominium units or rental apartment buildings managed by CityTowers.
This Privacy Policy is based on, and complies with, Canada’s Personal Information Protection and Electronic Documents Act (“PIPEDA”), which includes the Ten Privacy Principles outlined in the National Standard of Canada entitled Model Code for the Protection of Personal Information and similar provincial legislation.
This Privacy Policy sets out the ten principles that CityTowers follows to ensure that we protect Individuals’ personal information when we collect, use or disclose it in the course of carrying on
business activities in Canada. These correspond to similar principles contained in PIPEDA. All of our employees who have access to personal information must adhere to the CityTowers Privacy Policy and related procedures.
CityTowers’ Dedication to the Following Nine Principles of Privacy
Principle 1 – Accountability
CityTowers is accountable for all personal information in its possession or custody, including personal information disclosed to third parties for purposes of providing services requested by our Clients, prospective Clients or others. To this end, CityTowers has appointed a Privacy Officer who has ultimate responsibility for ensuring compliance within CityTowers and by all CityTowers employees. Through its policies and procedures, CityTowers will strive to implement this Privacy Policy throughout all of its operations.
CityTowers will seek to include in contractual arrangements with suppliers provisions requiring them to provide an appropriate level of protection for information transferred to them by CityTowers.
Principle 2 – Identifying Purposes
CityTowers will identify the purposes for which it is collecting any personal information by such means as is appropriate in the circumstances. This may include providing disclosure orally, by telephone, or in person, providing disclosure in a contract or in other written information given to an Individual, posting a notice on CityTowers’ website or any other means deemed appropriate in the circumstances.
In some instances, where the purpose for collecting information is reasonably evident to the person providing the information, the purpose will be implied but not explicitly stated (for instance, on rental applications, when a potential tenant provides us with his or her income and banking information or on Pre-Authorized Payment applications when a unit owner authorizes the condominium corporation to withdraw monthly common charges from an Individual’s bank account).
Principle 3 – Consent
CityTowers will seek to obtain consent from an Individual before or when it collects, uses or discloses personal information except as described below. CityTowers will strive to ensure that Individuals understand how their personal information will be used or disclosed.
Consent can be expressed (i.e. given orally, electronically or in writing), implied or given through an authorized representative. Consent may be implicit when the purposes are not stated expressly but are implied by the circumstances of the transaction or follow logically from other expressly stated purposes). You can withdraw consent at any time, with certain exceptions (for example, subject to any legal or contractual restrictions) and upon reasonable notice to CityTowers. CityTowers will strive to inform an Individual of all implications of withdrawing
his or her consent. You may contact CityTowers’ Privacy Officer respecting the withdrawal of any previously given consent or any change in the purposes for which information held by CityTowers may be used, disclosed or retained. Note that information may be retained by CityTowers for audit or archival purposes notwithstanding any withdrawal of consent otherwise applicable but the fact that consent has been withdrawn will be noted so as to prevent an unauthorized use.
CityTowers, however, may collect, use or disclose personal information without the an Individual’s knowledge or consent in exceptional circumstances where such collection, use or disclosure is permitted or required by law.
Principle 4 – Limiting Collection
CityTowers will only collect information that is reasonably necessary for the purposes identified. Information will be collected by fair and lawful means.
Principle 5 – Limiting Use, Disclosure and Retention
Personal information will only be used or disclosed for the purpose for which it was collected unless an Individual has otherwise consented, or when it is required or permitted by law. Personal information may only be retained for the amount of time needed to fulfill the purpose for which it was collected. In certain exceptional circumstances, CityTowers may have a legal duty or right to disclose personal information without an Individual’s knowledge or consent with respect to matters that concern the public’s interest.
Principle 6 – Accuracy
CityTowers will keep personal information as accurate, complete and current as necessary to fulfill the identified purposes for which it was collected. CityTowers will update or correct any personal information held by it if the individual concerned provides CityTowers with particulars, satisfactory to it, of any required updating or correction.
Principle 7 – Safeguarding Personal Information
Personal information is safeguarded to protect against loss, theft or unauthorized access, disclosure, use or modification of information using measures appropriate to the sensitivity, amount, format, nature and storage of the information and will involve, as applicable, physical, organizational and electronic security measures.
CityTowers has controls in place to maintain the security of its information and information systems. Files are stored according to the sensitivity of the information contained therein. Appropriate controls (such as restricted access) using user I.D.’s and passwords are placed on our computer systems and data processing procedures. Physical access to areas where personal information is gathered, processed or stored is limited to authorized employees.
Principle 8 – Openness
CityTowers will make information available to Individuals and its Clients and others about the policies and procedures CityTowers uses to manage personal information. Individuals and Clients have access to much of this information through our web site, or through written correspondence with CityTowers’ Privacy Officer.
Principle 9 – Questions or Concerns
CityTowers has policies and procedures to receive, investigate and respond to any questions or concerns respecting this Privacy Policy or the personal information that we hold. Individuals may contact the CityTowers’ Privacy Officer with any questions or concerns or to request access to their personal information.
Specific Information about our Use and Disclosure of Your Personal Information
The Kind of Information We Collect
CityTowers gathers and uses personal information as described below. Providing us with your personal information is your choice; however, we may not be able to provide you with certain products or services if you do not provide us with certain information nor will we be able to fulfil contractual obligations to third parties. For example, we may not be able to contact you in an emergency at your place of residence if we do not have your contact information away from your residence or if you withdraw your consent to disclose your contact information to our Clients or their employees or contractors who provide some of the products or services you have requested.
The nature of our relationship with you will determine the kind of personal information we might ask for.
Information that is typically required to provide you and the Clients we service with our products and services includes, but is not limited to:
Condominium Unit Owners:
- Name
- Address
- Phone Number(s)
- E-mail Address
- Name of Mortgagee on the unit
- Bank Account Number
- Persons Residing with you
- Address of Seasonal Property
- Other Phone Number
- Name of Emergency Contact and Contact Information
- Vehicle Information Including Licence Plate Number
- Any Special Needs of Owners
Tenants:
- Name
- Address
- Phone Number(s)
- Employment Status
- Credit History
- Past Tenancy History
- Bank Account Number
- Income
- Co-occupant Information (name, date of birth, relationship to prospective tenant)
- Vehicle Information Including Licence Plate Number
- Intended Use of Premises
- Any Special Needs of Tenants
For purposes related to our residential management (including tenancy) services, we may also collect certain other information, such as:
- Financial Information including institution and personal account number (for pre authorized payments only) (hereinafter “Financial Information”)
- Vehicle Information (for condominium management purposes, as applicable) (hereinafter “Vehicle Information”)
- Credit Check Information
In addition, information other than as set out in the definition of personal information (above), may also be collected from time to time.
Special Note For Tenants or Prospective Tenants Only
CityTowers subscribes to a consumer reporting service. This service provides information to CityTowers about prospective tenants. In return, on behalf of our Clients, we provide information to the service for the purpose of assessing your credit worthiness and checking references. We obtain your consent for using the consumer reporting service in the rental application form. If you have an existing tenancy agreement with us and you wish to renew the agreement, it is assumed that the consent you gave to us when signing the tenancy agreement remains in effect. If you sign an application to rent for your family or anyone else, you are representing that you have obtained their consent for the collection , use and disclosure of their personal information for the purposes set out in this Policy.
How Your Information is Used
CityTowers uses your personal information to enable us to provide superior financial, operational and administrative management services to our Clients. These uses include, without restriction:
- Property management and tenancy administration;
- Monthly financial reporting, budgeting operations, reserve fund study reviews, bookkeeping, accounting and financial management services;
- Contract tendering, administration and supervision;
- Purchasing, development of products and services, property inspections, development and maintenance of programs and manuals;
- Record keeping, rules and rule enforcement, general monthly reporting, status certificates, customer service and resident relations.
CityTowers will keep a record of the purposes for which any information is collected and will not use, retain or disclose that information for other purposes. If it proposes to use, retain or disclose the information for different purposes, it will identify those purposes to the person who has provided the information and will obtain his or her consent before using the information for such purpose.
When Do We Disclose or Share Your Personal Information?
When Authorized By You
Many of the services offered by CityTowers and/or its Clients require us to obtain personal information about you in order to perform the services we have been engaged by you to provide. We will use and disclose this information to provide programs to meet your needs and objectives.
To CityTowers’ Clients, their Employees and Agents
We act as agents for our condominium corporations and landlords. Thus, we may periodically share or transfer any personal information we collect relevant to a particular Individual with that Client or with that Client’s employees, third party suppliers or contractors. Our Clients use a number of employees, third party service providers, consultants and other agents that may in the course of their duties have limited access to personal information we retain. These include building superintendents, maintenance staff, recreation centre attendants, concierge, security staff, housekeeping staff, consultants, temporary employees or employees of third party suppliers, auditors, lawyers and others. We restrict their access to any personal information we hold except to the extent necessary for them to reasonably perform their role on behalf of our Client. The purpose of disclosing personal information to our Clients or their agents and employees is to ensure an Individual’s safety, security and reasonable enjoyment of their place of residence, to ensure Individuals have access to their premises and services that our Clients have agreed to provide, to preserve our Client’s property and to collect monies owing to those Clients for the provision of services to Individuals.
Suppliers and Client employees are required to protect the confidentiality of your personal information, and are prohibited from doing anything with this information that we have not authorized them to do. They are required to treat your personal information in a manner consistent with the CityTowers Privacy Policy.
When Required or Permitted By Law
The type of information we are legally required to disclose usually relates to government tax reporting requirements. However in some cases, such as under a court order, we may be required to disclose certain information to persons specified in the court order. We will only provide the specific information requested and only upon being satisfied that the authorities have legitimate grounds to obtain the information. CityTowers may also disclose information without your consent when permitted by law including in situations involving medical emergencies, collection of a debt and suspicion of illegal activities.
Web Site (Security)
CityTowers is committed to your privacy and strives to ensure that any information you access or provide through this site remains secure and may be used only in accordance with this Privacy Policy.
Contact Information (Questions, Concerns, Access to Your Information)
If you have any questions or concerns about your personal information, or about the CityTowers Privacy Policy, or wish to review your information, please contact our Privacy Officer using the contact information below:
Contact Information:
Privacy Officer, Natalie Palyga
Phone: 416-800-4010
npalyga@citytowersinc.com
Address:
5045 Orbitor Drive,
Building 12 – Unit 201
Misississaug, Ontario, L4W 4Y4