What is Personal Information?
Personal information is information about an identifiable individual. Personal information includes information that relates to personal characteristics (e.g., gender, age, income, home address or phone number, family status), health (e.g., disabilities) or activities and views (e.g., religion, politics, opinions expressed by an individual, opinions about an individual).
Who We Are
Our Company provides property management services at our residential and commercial properties. Associated companies are involved in construction, land development and other related activities. To provide property management services, we hire employees and use a number of consultants and agencies that may, in the course of their duties, have access to personal information we hold. These include, but are not limited to, building superintendents and managers, security, cleaning and maintenance organizations, accountants, legal representatives, computer consultants, cleaners, and temporary workers. We restrict their access to any personal information we hold as much as is reasonably possible. We also have their assurance that they follow appropriate privacy principles.
Why Is Personal Information About You Collected?
We collect and use personal information to provide the services you have requested and to offer additional services we believe you might be interested in. Providing us with your personal information is always your choice. However, your decision to withhold certain personal information may prevent us from providing you with the services you require.
We Collect Personal Information: Primary Purposes
Prospective Tenants Prospective tenants are requested to complete a rental application form so that we can assess their eligibility criteria and have necessary basic information should they become tenants. This information would include, but not be limited to the following:
- Full name
- Date of birth
- Past and current tenancy information
- Employment information
- Business and personal telephone, email, and other contact information
- References and conduct history
- Social insurance number (The requirement to provide a social insurance number is optional for prospective tenants)
- Intended use of the premises
- Automobile Information
Confirmation of this information by ourselves, or our clients, will take place. This might include following up with other individuals identified as having relevant information (e.g., a person identified by a reference you provided to us). We, or our clients, may also contact a credit agency and/or a consumer reporting service for information about your suitability. We might also check appropriate public sources (e.g., public court record, criminal record, or any other public domain or sources). By signing a rental application form you agree to the collecting of this information about your suitability to be a tenant. Your information is subject to transfer to Third Parties in the same manner as that set out below in relation to Tenants.
We collect, use and disclose personal information in order to serve our tenants: to ensure tenants' safety, security and reasonable enjoyment; to ensure tenants have access to the premises, equipment and services that we have agreed to provide; to protect our property; and, to collect rents.
We also use the information collected to determine eligibility for the services requested and to provide those services, including the ongoing administration of the lease and the obligations thereunder; to verify identity and detect and prevent fraud; and, to compile statistics, conduct market research and report to regulatory and industry agencies.
Examples of the types of information we collect for these purposes includes the following:
- Full name
- Date of birth
- Business, personal and emergency contact information
- Previous address
- Marital status
- Place of employment
- Names of all occupants of the unit
- Dependent(s)' date of birth
- Use and intended uses of the property
- Payment, banking and other financial information
- Credit history (Unless reasonably necessary, digital credit history documents are sufficient, and no physical copy will be generated.)
- Any special needs of tenants (e.g., disability or health)
- Social insurance number (not mandatory)
- The amount of rent payable with respect to each rental unit
- The information described above can be collected or updated if the tenant is in arrears of rent or fees or wishes to renew a tenancy agreement.
In addition to the above sources of information, we may gather information from the following sources:
- From you on applications or on other forms filled out via telephone, e-mail or face-to-face interviews
- From agents, brokers, intermediaries, with whom you have or had a relationship
- From previous landlords, employers or references that you have provided to us
- From your interactions with us (i.e. through your payment history)
- From consumer reporting agencies (i.e. your credit history)
It would be rare for us to collect any personal information without the tenant's express consent, but this might occur in a case of urgency (e.g., the tenant is unavailable), where we believe the tenant would consent if asked and it is impractical to obtain consent (e.g., information provided by a relative about an absent tenant), appropriate public sources (e.g., government, court or tribunal records) or to investigate a breach of the tenancy agreement or contravention of the law.
We subscribe to a consumer reporting service. This service provides information to us about prospective tenants. In return, we provide information to the service in order for the service to maintain a databank on a tenant's credit history. We collect your full legal name and date of birth to ensure the accuracy of those records. We obtain your consent for using the consumer reporting service in the rental application form and tenancy agreement.
We disclose limited amounts of information to Third Parties who may have access to such personal information incidentally through their administration and servicing of software used by us in our business operations.
We disclose limited amounts of personal information to Third Party service suppliers, such as providers of any security alarm system, cable television, telephone, telecommunication, hydro-electricity, water/hot water, gas and/or other similar or related services. These Third Parties are restricted from using your personal information other than for the purpose of contacting you for the provision of such services (see attached Schedule "A" for full list of Third Parties).
As a service and convenience, we may maintain public directories of tenants (e.g., by the front door). If you do not wish to be listed in any directories or wish to be described in a particular way, please disclose this information once your rental application has been approved.
Members of the General Public
For members of the public, our primary purpose for collecting personal information is to promote the safety of tenants and the security of the property. For example, we, or our clients, may operate security cameras and monitor the presence, vehicles and the conduct of visitors and non-tenants on our property. We believe that the collection of this information is implied by the private and residential nature of our client's property.
Secondly, we, or our clients, might gather personal information in the course of marketing our property to prospective tenants. This information is collected either from appropriate public sources (e.g., telephone directories) or directly from the individuals with their consent.
On our website, we only collect, with the exception of cookies (electronic marketing identifying computers that have previously visited our website), the personal information you provide and only use that information for the purpose you gave it to us (e.g. to respond to your e-mail message, to provided information about our services). Cookies are only used to help you navigate our website and are not used to monitor you.
Suppliers and Contractors
We often deal with suppliers and contractors who provide goods and services to the properties we manage. We monitor their performance, including their promptness, reliability, quality and value of services. Most of this information is business information and would not be covered by privacy legislation. However, occasionally, this information relates to the conduct of an individual (e.g., conduct of an employee of a supplier or contractor). We reserve the right to collect this information, use it in deciding upon future services and to disclose it to others involved in related or similar operations. We may also collect home contact information to reach them in case of emergencies.
For people who are contracted to do work for us (e.g., temporary workers), our primary purpose for collecting personal information is to ensure we can contact them in the future (e.g., for new assignments) and for necessary work-related communication (e.g., sending out paycheques, year-end tax receipts, tax filings). Examples of the type of personal information we collect for those purposes include home addresses and telephone numbers. It is rare for us to collect such information without prior consent, but it might happen in the case of an emergency (e.g., an outbreak of a contagious disease) or to investigate a possible breach of law (e.g., if a theft were to occur).
We may transfer your personal information to third parties and servers located within and outside of Canada for the purposes of storage and use with respect to their accounting and maintenance systems, and for the processing of payroll and on-line applications. While this information is outside of the country, it is subject to the laws of the country in which it is held. As such, it may be accessible to law enforcement and national security authorities of that jurisdiction
We Collect Personal Information: Related and Secondary Purposes
We also collect, use and disclose information for purposes related to or secondary to our primary purposes. The most common examples of our related and secondary purposes are as follows:
- To collect rents and other fees on behalf of related companies that we provide management services for (our "clients)
- To collect fees and accounts from our clients
- To advise clients and others of new developments in the area of landlord and tenant relations (e.g., a newsletter sent to a home address of a client)
- The review of tenant, client and other files for the purpose of ensuring that we provide high quality services
- Various government agencies (e.g., Canada Customs and Revenue Agency, Information and Privacy Commissioner, Human Rights Commission, etc.) have the authority to review our files and interview our staff as a part of their mandates. We also may report information suggesting serious illegal behaviour to the authorities. These reports could include personal information about a tenant or other individual to support the concern (e.g., illegal drug activity), although we try to keep this disclosure to a minimum.
- If a tenant's rent or fees are paid for by a third party (e.g., employer, your trustee, and the government) we may be asked to provide them with certain information.
- Tenants, clients or other individuals we deal with may have questions about the services they received. We also provide ongoing services for many tenants and clients over a period of months or years for which previous records are helpful. We retain tenant and client information for a minimum of seven years after the last contact to enable us to respond to those questions and provide these services
Protecting Personal Information
Breach of Security Safeguards
Despite the safeguards that we have put in place, we recognize that there may be breaches of those security safeguards. These breaches may be caused by human error, malicious attacks or another reason.
If a breach occurs, we will conduct a risk assessment to determine if the breach poses a real risk of significant harm to any individual whose information was involved. Significant harm includes bodily harm, humiliation, financial loss, identity theft, negative effects on the credit record, and damage to or loss of property. The risk assessment will consider the sensitivity of the information involved, and the probability that the information will be misused.
If we determine that the breach presents a real risk of significant harm we will report the breach to the Commission and to the affected individuals as soon as feasible. We will also notify any other organization or government institution that may be able to reduce the risk of harm to affected individuals.
We will keep a record of every breach for 24 months after the day on which we determine that the breach has occurred. Records shall be kept about all breaches, and not just those that pose a real risk of significant harm. Records shall include information about reports to the Commissioner and notification of affected individuals in accordance with this Policy and PIPEDA.
Retention and Destruction of Personal Information
We will retain your Personal Information for as long as it is necessary to fulfill the purpose for which it was collected and to comply with applicable laws. After the Personal Information is no longer necessary either for the purpose for which it was collected or to comply with any laws it will be destroyed, erased, or made anonymous.
We keep our client files for a period deemed reasonable by our clients, but will not be more than 7 years from the last month of tenancy. All records of all applicants for tenancy who are not accepted for tenancy are kept only for a reasonable length of time to meet our own obligations to external regulatory bodies, and are thereafter destroyed.
Unless reasonably necessary for the services we provide, no physical copies of credit history documentation are required. If physical copies are provided to us, or generated by us, such copies are kept only for a reasonable length and are thereafter destroyed.
Video and Audio Recordings
Video equipment may be installed and operating in common areas of the complex in which your rental unit is located. The video equipment may have special capabilities that will allow it to capture sound recordings along with images. Other special capabilities that the video equipment may possess includes, but is not limited to, zoom, facial recognition, or night-vision features.
The video equipment may be operating at all times. Surveillance of the video recordings may occur at any time.
The purpose of the use of such equipment is to ensure your safety, security and reasonable enjoyment and that of the other tenants, to ensure you have access to the premises, equipment and services that our clients have agreed to provide, to preserve our clients' property, and to deter crime.
Where required by law, signs will be posted informing you that video equipment is operating and recording personal information about you. If you have questions regarding the video recordings or if you wish to have access to recorded images of you please contact our Privacy Officer.
Your image, movements, actions, or other identifiable information about you, may be captured by the video equipment. Where video equipment captures audio recordings, any sounds or communications you make may be recorded.
The recordings captured by the video equipment along with the video equipment will be stored in a secured location. Access to the location and recordings is limited. Hardware is either under supervision or secured in a locked or restricted area. Recordings will be kept for a minimum of 5 days before being destroyed.
There are circumstances under which we may make audio recordings of our employees, contractors, or tenants. There are several purposes for making the recordings; they include: situations where there are work-related performance issues, to ensure the safety of the workplace, to ensure productivity, and to prevent harassment.
Audio recordings may be made during meetings, interviews, or telephone calls between us and an employee or us and a prospect or tenant. Audio equipment may be operating at other times. Information recorded by the audio equipment may capture communications of any of the following persons: the employer, employee, landlord, tenants, prospective tenants, contractors, and the general public.
Audio recordings will be kept for a minimum of 24 hours before being destroyed. The recordings may be kept for a longer period if there are on-going issues related to the employment relationship, if required by law, or if tenant or employee litigation is contemplated. The audio recordings will be stored in a secured location. Access to the location and recordings is limited. Hardware is either under supervision or secured in a locked or restricted area.
Voicemail messages left for us will be erased after they have been listened to by an employee. If a message contains personal information of an individual which we will rely upon when making a decision, that voicemail will be kept for a period of no more than 6 months. After that period has expired, the voicemail message will be erased, and thus will not be available for review.
Disclosure of Your Personal Information
We may disclose your personal information without your knowledge or consent under certain circumstances. Those circumstances include: if the disclosure is required by law, provided to our lawyers, for the purpose of collecting a debt you owe to us, in compliance with a subpoena, warrant, or issued order made by a court, person or body with jurisdiction to compel the production of information, or to comply with rules of court relating to the production of records.
Disclosure may also be made to a government institution that has made a request for the information, identified its lawful authority to obtain the information and indicated that: it suspects that the information relates to national security, the defence of Canada or the conduct of international affairs, the disclosure is requested for the purpose of carrying out any investigation relating to the enforcement, gathering intelligence for the purpose of enforcing, or enforcing any law of any jurisdiction, or the disclosure is requested for the purpose of administering any law of Canada or a province. Disclosure may be made by an investigative body if the disclosure is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province.
If information regarding an identifiable individual is disclosed to a person who needs the information because of an emergency that threatens the life, health or security of an individual and, if the individual whom the information is about is alive, we will inform that individual in writing of the disclosure without delay.
We rely upon applicants to provide us with accurate personal information, and notify us of any changes that may affect our tenant/landlord or employee/employer relations or communications.
Access to Your Personal Information
With some exceptions, you have the right to access, verify and amend your personal information. If you choose to exercise this right, we ask that you put your request in writing to our Privacy Officer. We will need to confirm your identity, if we do not know you, before providing you with this access. Your request will be responded to as quickly as possible. Upon request, an individual will be informed of the existence, use, and disclosure of his or her personal information and will be given access to that information. An individual will be able to challenge the accuracy and completeness of the information and have it amended as appropriate. Such a request must be made in writing. If you require our assistance with preparing your request, you must inform us of your need for assistance. We will respond to your request within thirty (30) days of its receipt. If there is a circumstance that prevents us from responding to your request within 30 days, we will provide you with notice of extension. If we cannot give you access, we will tell you the reason, as best we can, as to why we cannot give you access.
We reserve the right to charge a nominal fee for such requests. We can help you identify what records we might have about you.
If you believe there has been an unauthorized disclosure of your personal information, we ask that you put your complaint in writing and direct it to our Information Officer.
We may obtain information about your general internet usage by using a cookie file that is typically stored on the hard drive of your computer or on your mobile device.
Cookies contain information that is transferred to your computer's hard drive or mobile device. For instance, when you return to our website after logging in, cookies provide information to our website so that the website remembers you. Cookies help us to improve our website, and to deliver a better, more personalised service. You can change your web browser settings so your computer warns you each time a cookie is sent, or to turn off all cookies. Each browser is a little different, so look at your browser "help menu" to learn the correct way to modify your cookies. If you turn off all cookies, you won't have access to many features that may make your browsing of our website smoother, and some of our services may not function properly.
What types of Cookies do we use?
We use temporary "session" cookies which enable a visitor's web browser to remember which pages on our website have already been visited, your current location, historical search preferences and/or user 'favourited' lists. This information may be used to help us to improve, administer and diagnose problems with our website and server, and provide a relevant, easy to use customer experience. Cookie data may also be used by our website content management system. Our website may also use other technical methods to track visitor usage, including web beacons. ("Web beacons" are small pieces of data that are embedded in images on the pages of a website.) We may also use these technical methods to analyse the traffic patterns on our website, such as the frequency with which our users visit various parts of our website. These technical methods may involve the transmission of information either directly to us, or to another party authorised by us to collect information on our behalf. Our website uses Google Analytics a web analytics service provided by Google, Inc. ("Google") to collect anonymous traffic data to our website to help us analyse how users use it and providing other services relating to website activity and internet usage. The information stored in the cookie is transmitted to and stored by Google on servers in the United States and then used to evaluate visitors' use of our website and to compile statistical reports on website activity for us. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. Google will not associate your IP address with any other data held by Google. By using our website, you consent to the processing of data about you by Google in the manner and for the purposes set out above. We will not (nor will we enable third parties to) use this analytics tool to track or collect any personally identifiable information about users of our website. For further information on the privacy of Google Analytics data please visit http://www.google.com/analytics/learn/privacy.html. We may also use these technical methods in HTML e-mails that we send in reply to visitor queries and users of our website to determine whether such visitors have opened those e-mails and/or clicked on links in those e-mails. We may collect the information from use of these technical methods in a form that is personally identifiable.
Third Party Cookies
Some cookies that have been set on our website may not be related to or controlled by us. When you visit a page with content embedded from, for example, Twitter or Facebook, these service providers may set their own cookies on your web browser. We do not control the use of these cookies and cannot access them due to the way that cookies work, as cookies can only be accessed by the party which originally set them. You should check the third party websites for more information about these cookies.
We do not control these third parties' tracking technologies or how they are used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.
For more information, to make enquiries or to file a complaint, please contact:
Sterling Karamar Property Management Inc.
53 The Links Road
Toronto, Ontario, M2P 1T7
For general inquiries, the Information and Privacy Commissioner of Canada oversees the administration of privacy legislation in the private sector and acts as an ombudsman for privacy disputes. The Information and Privacy Commissioner can be reached at:
112 Kent Street
Ottawa, Ontario, K1A 1H3
Accessible formats of the document are available free upon request at the above-noted phone number or email address
Schedule "A": Third Party Disclosure List
Below is the list of Third Parties that Sterling Karamar Property Management may provide personal information to:
|Rogers Cable Communications Inc.
855 York Mills Rd.
Toronto, Ontario, M3B 1Z1
8133 Warden Avenue, Suite 601
Markham, Ontario, L6B 1B3
100 Wynford Drive
Don Mills, Ontario, M3C 4B4
Yardi Systems Inc.
430 S. Fairview Avenue
Goleta, CA, 93117
271B Merritt St Unit 4,
St. Catharines, ON L2T 1K1
Wyse Meter Solutions
2100 Matheson Blvd E #201
Mississauga, Ontario, L4W 5E1
7 Grand Ave S
Cambridge, ON N1S 2L3
14 Carlton Street
Toronto, ON M5B 1K5
500 Consumers Rd
North York, ON M2J 1P8
111 Horton Street
London, ON N6A 4H6
3280 Bloor St W #1410
Etobicoke, ON M8X 2X3