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). Personal information is to be contrasted with business information (e.g., an individual's business address and telephone number), which is not protected by privacy legislation.
Why Is Personal Information About You Collected?
We gather 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 are requested to complete a rental application form so that we can assess their suitability as tenants and have necessary basic information should they become tenants. This information may include:
- Full name
- Date of birth
- Past and current tenancy history
- Employment history
- 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. If accepted for tenancy, applicants are required to provide their social insurance number. This information will only be retained with respect to successful applicants for tenancy and only used for enforcement and collection and for the purposes of issuing a tax receipt for interest on a rental deposit)
- Financial means and credit history (Unless reasonably necessary, digital credit history documents are sufficient and no physical copy will be generated)
- Automobile information
- Intended use of the premises
We, or our clients, will then confirm this information and check references and the conduct history of the prospective tenants. This might include following up with other individuals identified during the course of these inquiries 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, or our clients, might also check appropriate public sources (e.g., government, court or tribunal records). We or our clients may also provide the Applicant's name, new address and move in date to a third party telecommunications or service or utility provider, if the Applicant is accepted as a tenant, in order to enable that third party to contact the tenant in regard to the provision of en-suite services. By completing a rental application form and Consent to Disclosure form you agree to us, or our clients, collecting 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 above in relation to Tenants.
The type of information Greenwin collects and maintains on file with respect to tenants may include:
- 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 (The requirement to provide a social insurance number is optional for prospective tenants but required of applicants accepted for tenancy. Social insurance numbers are only retained with respect to enforcement and collection, and for purposes of issuing a tax receipt for interest on a rental deposit)
- 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)
We collect the information described above in order to:
- Ensure safety and security and to ensure access to the premises, equipment and Services
- Ensure reasonable enjoyment of tenants, preservation of property and to collect rents and other fees
- Determine eligibility for the services requested and to provide those services, including determining suitability for a lease and the ongoing administration of the lease and the obligations thereunder
- Verify identity and detect and prevent fraud
- Compile statistics, conduct market research and report to regulatory and industry agencies
- 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
- 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)
- Compile a record of tenant names and associated credit scores ("Record of Tenant Credit Scores") and ratings (only with respect to applicants accepted for tenancy)
- Process/request judgement orders of rent arrears, and damages
- Disclose such limited amounts of information to any additional individual or entity, where you consent to such disclosure
- Disclose such limited amounts of information when authorized by you or when required or permitted by law
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 let us know.
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.
Members of the General Public
For members of the general 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 client's 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 markers 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 email message, to provide 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 a particular 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 the landlord or 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 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)
- We review 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. Also, we believe that we should 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. In these circumstances, we may consult with professionals (e.g., lawyers, a private security service) who will investigate the matter and report back to us
- 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. These third party payers often have tenant consent or legislative authority to direct us to collect and disclose to them certain information in order to demonstrate tenant entitlement to and responsible use of this funding
- 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
You can choose not to be part of some of these related or secondary purposes (e.g., by not having a third party pay your rent). We do not, however, have much choice about some of these related or secondary purposes (e.g., external regulation)
Protecting Personal Information
Retention and Destruction of Personal Information
Your personal information is retained only as long as we need it to effectively provide services to you, and for a reasonable length of time thereafter to meet any potential obligations or legal or government requirements. However, we do not want to keep personal information too long in order to protect your privacy.
We keep our client files for a period deemed reasonable by our clients, but will not be less 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 of time to meet our own obligations to external regulatory bodies, and are thereafter destroyed.
Unless reasonably necessary for the services we provide, all physical or digital copies of credit history documentation (with the exception of information contained in the Record of Tenant Credit Scores) are kept only for a reasonable length of time to meet our own obligations to external regulatory bodies, and are thereafter destroyed.
Our clients, tenant and contact directories are much more difficult to systematically destroy, so we remove such information when we can if it does not appear that we will be contacting you again. However, if you ask, we will remove such contact information right away. We keep any personal information relating to our general correspondence with people who are not tenants for approximately 12 months.
We destroy paper files containing personal information by shredding. We destroy electronic information by deleting it and, when the hardware is discarded, we ensure that the hard drive is physically destroyed.
Video Surveillance and Recordings
Use of Video Surveillance and 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. Also posted on those signs will be the contact information for our Information Officer whom you can contact if you have questions regarding the video recordings or if you wish to have access to recorded images of you.
What is Captured by the Video Recordings
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.
Retention and Destruction of Personal Information Recorded by Video Equipment
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.
Use of Audio Equipment and Recordings
There are circumstances under which the employer may make audio recordings of its 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 the employer and an employee. 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, tenants, contractors, and the general public.
Retention and Destruction of Personal Information Recorded by Audio Equipment
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 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.
Retention and Destruction of Personal Information Recorded by Voicemail
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 24 hours. After that period has expired, the voicemail message will be erased, and thus will not be available for review.
Disclosure of Personal Information Recorded by Video or Audio Equipment
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.
Upon our initiative, we may disclose the information to an investigative body or a government institution if we have reasonable grounds to believe that the information relates to a breach of an agreement or a contravention of the laws of any jurisdiction that has been, is being or is about to be committed, or if we suspect that the information relates to national security, the defence of Canada or the conduct of international affairs.
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.
Use without Knowledge or Consent of Personal Information Recorded by Video or Audio Equipment
We may, without your knowledge or consent, use your personal information if: we become aware of information that we have reasonable grounds to believe could be useful in the investigation of a contravention of the laws of any jurisdiction that has been, is being, or is about to be committed, and the information is used for the purpose of investigating the contravention, it is used for the purpose of acting in respect of an emergency that threatens the life, health, or security of an individual, or has been collected under circumstances in which consent is not required.
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 Greenwin's Privacy Officer. Your request will be responded to as quickly as possible. If for some reason we cannot respond immediately, you will be advised. 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. We will need to confirm your identity, if we do not know you, before providing you with this access. 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. If we cannot give you access, we will tell you within 30 days if at all possible and 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. We will also try to help you understand any information you do not understand (e.g., short forms, technical language, etc.).
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.
For more information, to make enquiries or to file a complaint, please contact:
19 Lesmill Road
Toronto, Ontario, M3B 2T3
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
Toll Free: 800-282-1376
Schedule "A": Third Party Disclosure List
Below is the list of Third Parties that Greenwin provides personal information to.
Rogers Cable Communications Inc.
855 York Mills Rd.
Toronto, Ontario, M3B 1Z1
100 Wynford Drive
Don Mills, Ontario, M3C 4B4
Yardi Systems Inc.
430 S. Fairview Avenue
Goleta, CA, 93117
8133 Warden Avenue, Suite 601
Markham, Ontario, L6B 1B3