Privacy Policy.
January 4, 2008
Introduction
This Privacy Policy (the "Policy") describes the practices of Canadian Apartment Properties Real Estate Investment Trust (“CAP REIT”) in connection with its collection, use and disclosure of Personal Information (as defined below). At CAP REIT, we are committed to protecting your privacy through practices that limit the collection, use and disclosure of Personal Information to what is necessary for lease applications and approvals. This Policy was created to inform you of our commitment to protecting your Personal Information and is based on the general principles in Schedule 1 of the federal Personal Information Protection and Electronic Documents Act.
Definition of Personal Information.
Personal Information includes any information about an identifiable individual. Some examples of Personal Information which CAP REIT may collect from you are:
- gender
- age
- name
- home address
- phone number
- family status
- income
Purpose for the collection and use of your Personal Information
CAP REIT collects Personal Information from individuals applying for a lease and its tenants. CAP REIT uses the Personal Information in connection with the services requested and/or provided, including (i) determining your suitability for a lease and (ii) the ongoing administration of your lease and your obligations thereunder. Examples of the manner in which your Personal Information may be used include: confirming your income, contacting you should matters relevant to your tenancy arise, and providing your information to utility companies in connection with the provision of utilities to your unit.
CAP REIT may also disclose your Personal Information as may be necessary in connection with a disposition of your building, an assignment of your lease agreement or obtaining financing. In all such circumstances CAP REIT shall require the recipient of your Personal Information to maintain it in confidence and only use it as permitted by law.
Consenting to our collection, use and disclosure of your Personal Information
The collection, use or disclosure of your Personal Information by CAP REIT requires your knowledge and consent. At certain times, your consent for the collection, use and disclosure of your Personal Information may be implied from the manner in which it is collected. For example, when you provide us with your Personal Information in connection with a lease, you have implicitly consented to CAP REIT collecting, utilizing and disclosing your Personal Information in a manner necessary to determine your suitability for, and administer, your lease as further described in the paragraph above. Your consent may also be expressly provided by you. If CAP REIT collects, uses or discloses Personal Information for purposes other than those described above, prior to the collection, use and/or disclosure of such Personal Information you will be informed of CAP REIT’s intended collection, use and/or disclosure of that Personal Information and, have an ability to opt out of any collection, use and/or disclosure that is not necessary under law or in connection with your tenancy. If we intend to use and/or disclose Personal Information that we previously collected for a new purpose which is not authorized under applicable laws, your consent will always be obtained before we use and/or disclose it for that new purpose.
In all cases where Personal Information is disclosed to third parties, the third party will be contractually required to maintain the confidentiality of your Personal Information. Where you have indicated your consent, CAP REIT may disclose tenant contact information to service providers offering our tenants special discounts. Even if you have consented to such practice, you may always opt out by contacting our Chief Privacy Officer.
There are certain situations defined by law where your knowledge of or consent to disclosure of your Personal Information is either not required or considered inappropriate. One example would be if CAP REIT must disclose your Personal Information in order to comply with a subpoena or court order.
You may always choose not to supply CAP REIT with your Personal Information. However, if you choose not to supply us with your Personal Information, it may impact our ability to offer you services or respond to your needs.
Retention of your Personal Information
CAP REIT 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.
Protection of your Personal Information.
CAP REIT will protect your Personal Information in a manner that is consistent with and appropriate to the sensitivity of that Personal Information. Our handling of your Personal Information will respect its confidential nature at all times from the time of its collection until its ultimate disposal or destruction.
Accessing your Personal Information
Access to your Personal Information held by CAP REIT may be requested by contacting the Chief Privacy Officer in writing. We will respond to any access request within thirty days of receiving your request. Any questions with regard to requesting access to Personal Information may be addressed to the Chief Privacy Officer.
Responsibility for compliance with our Privacy Policy
Our Chief Privacy Officer is responsible for overseeing CAP REIT’s compliance with this Policy and may be contacted at the following address:
Chief Privacy Officer
Canadian Apartment Properties Real Estate Investment Trust
11 Church Street
Suite 401
Toronto, ON M5E 1W1
(416) 861-5771
Questions or concerns about our privacy practices
Please address any questions or concerns about our compliance with this Policy or our privacy practices generally to the Chief Privacy Officer.
If you remain unsatisfied after discussing the matter with our Chief Privacy Officer, please contact the Privacy Commissioner of Canada at www.privcom.gc.ca or at the following address:
112 Kent Street
Ottawa, Ontario
K1A 1H3
Telephone: (613) 995-8210
Toll-free: 1-800-282-1376
Fax: (613) 947-6850
E-mail: info@privcom.gc.ca