Personal Information Protection
Private Sector Privacy Legislation
Personal Information Protection Policy
Rental Housing Council DBA: IPOANS
Personal Information Protection Policy
At IPOANS, we are committed to providing our customers and members with exceptional service. As providing this service involves the collection, use and disclosure of some personal information about our customers and members, protecting their personal information is one of our highest priorities.
While we have always respected our customers and members privacy and safeguarded their personal information, we have strengthened our commitment to protecting personal information as a result of Nova Scotia’s Personal Information Protection Act (PIPA). PIPA, which came into effect on January 1, 2004, sets out the ground rules for how N.S. businesses and not-for-profit organizations may collect, use and disclose personal information.
We will inform our customers and members 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.
This Personal Information Protection Policy, in compliance with PIPA, outlines the principles and practices we will follow in protecting customers’ and members’ personal information. Our privacy commitment includes ensuring the accuracy, confidentiality, and security of our customers’ and members’ personal information and allowing our customers and members to request access to, and correction of, their personal information.
Policy 1 – Collecting Personal Information
1.1 Unless the purposes for collecting personal information are obvious and the customers and members 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.
1.2 We will only collect customers and members information that is necessary to fulfill the following purposes:
- To verify identity;
- To open and manage an account;
- To deliver requested products and services
- To process a magazine subscription;
- To enrol the client in a program;
- To send out association membership information;
- To contact our [clients, customers, members] for fundraising;
- To ensure a high standard of service to our [clients, customers, members];
- To meet regulatory requirements;
- To collect and process payments;
- To create and maintain industry related reports
Policy 2 – Consent
2.1 We will obtain customers and members consent to collect, use or disclose personal information (except where, as noted below, we are authorized to do so without consent).
2.2 Consent can be provided in writing or electronically or it can be implied where the purpose for collecting using or disclosing the personal information would be considered obvious and the customers and members voluntarily provides personal information for that purpose.
2.3 Consent may also be implied where a customer or member 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 customer or member does not opt-out.
2.4 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), customers and members can withhold or withdraw their consent for IPOANS to use their personal information in certain ways. A customer’s and member’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 customer and member in making the decision.
2.5 We may collect, use or disclose personal information without the customer’s or member’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
Policy 3 – Using and Disclosing Personal Information
3.1 We will only use or disclose customer or members personal information where necessary to fulfill the purposes identified at the time of collection or for a purpose reasonably related to those purposes such as:
- To conduct customer or member surveys in order to enhance the provision of our services;
- To contact our customers and members] directly about products and services that may be of interest;
- For the purposes outlined in policies 1.2 and 2.5 above;
3.2 We will not use or disclose customer or member personal information for any additional purpose unless we obtain express consent to do so.
3.3 We will not sell customer or member lists or personal information to other parties unless we have express consent to do so.
Policy 4 – Retaining Personal Information
4.1 If we use customer or member personal information to make a decision that directly affects the customer or member we will retain that personal information for at least one year so that the customer or member has a reasonable opportunity to request access to it.
4.2 Subject to policy 4.1, we will retain customer or member personal information only as long as necessary to fulfill the identified purposes or a legal or business purpose.
Policy 5 – Ensuring Accuracy of Personal Information
5.1 We will make reasonable efforts to ensure that customer or member personal information is accurate and complete where it may be used to make a decision about the customer or member or disclosed to another organization.
5.2 Customer or members 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.
5.3 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 where it is reasonably practicable to do so. If the correction is not made, we will note the customer’s or members’ correction request in the file.
Policy 6 – Securing Personal Information
6.1 We are committed to ensuring the security of customer and member personal information in order to protect it from unauthorized access, collection, use, disclosure, copying, modification or disposal or similar risks.
6.2 The following security measures will be followed to ensure that customer and member personal information is appropriately protected: the use of locked filing cabinets; physically securing offices where personal information is held; the use of user IDs, passwords, and firewalls.
6.3 We will use appropriate security measures when destroying customer’s and member’s personal information such as shredding documents and deleting electronically stored information.
6.4 We will continually review and update our security policies and controls as technology changes to ensure ongoing personal information security.
Policy 7 – Providing Customers and Members Access to Personal Information
7.1 Customers and Members have a right to access their personal information, subject to limited exceptions.
7.2 A request to access personal information must be made in writing and provide sufficient detail to identify the personal information being sought.
7.3 Upon request, we will also tell customers and members how we use their personal information and to whom it has been disclosed if applicable.
7.4 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.
7.5 A minimal fee may be charged for providing access to personal information. Where a fee may apply, we will inform the customer or member of the cost and request further direction from the customer or member on whether or not we should proceed with the request.
7.6 If a request is refused in full or in part, we will notify the customer or member in writing, providing the reasons for refusal and the recourse available to the customer or member.
Policy 8 – Questions and Complaints: The Role of the Privacy Officer or designated individual
8.1 The Privacy Officer is responsible for ensuring IPOANS’ compliance with this policy and the Personal Information Protection Act.
8.2 Customers and members should direct any complaints, concerns or questions regarding IPOANS’ compliance in writing to the Privacy Officer. If the Privacy Officer is unable to resolve the concern, the customer or member may also write to the Information and Privacy Commissioner of Nova Scotia.
Contact information for IPOANS’ Privacy Officer: