Condominium Home Owners Association of B.C. (CHOA)
Personal Information Protection Policy
At the Condominium Home Owners Association of B.C. (herein referred to as CHOA), we are committed to providing our members with exceptional service and our employees with respect. As providing this service involves the collection, use and disclosure of some personal information about our members, protecting their personal information is one of our highest priorities.
While we have always respected our members and employees privacy and safeguarded their personal information, we have strengthened our commitment to protecting personal information as a result of British Columbia’s Personal Information Protection Act (PIPA). PIPA, which came into effect on January 1, 2004, sets out the ground rules for how B.C. businesses and not-for-profit organizations may collect, use and disclose personal information.
We will inform our members and employees 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 members’ and employees personal information. Our privacy commitment includes ensuring the accuracy, confidentiality, and security of our members’ and employees’ personal information and allowing our members and employees to request access to, and correction of, their personal information.
Scope of this Policy
This Personal Information Protection Policy applies to CHOA. This policy also applies to any service providers collecting, using or disclosing personal information on behalf of CHOA.
Personal Information – means information about an identifiable individual including name, age, home address, phone number, email address, marital status, income, banking information, education and social insurance number. Personal information does not include contact information (described below).
Contact information – means information that would enable an individual to be contacted at a place of business and includes name, position name or title, business telephone number, business address, business email or business fax number. Contact information is not covered by this policy or PIPA.
Privacy Officer – means the individual designated responsibility for ensuring that CHOA complies with this policy and PIPA.
Policy 1 – Collecting Personal Information
1.1 Unless the purposes for collecting personal information are obvious and the member or employee 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 member and employee information that is necessary to fulfill the following purposes:
- To verify identity;
- To identify the member or employees preferences;
- To understand the needs [such as financial, banking, insurance] of our members and employees;
- To open and manage a membership with CHOA;
- To deliver requested products and services;
- To guarantee a travel or hotel reservation;
- To enrol the member in CHOA;
- To send out association membership information;
- To ensure a high standard of service to our members and staff;
- To meet regulatory requirements;
Policy 2 – Consent
2.1 We will obtain member and employee 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 by a variety of methods including but not limited to: orally, in writing, electronically, through an authorized representative or it can be implied where the purpose for collecting using or disclosing the personal information would be considered obvious and the member or employee voluntarily provides personal information for that purpose.
2.3 Consent may also be implied where a member or employee is given notice and a reasonable opportunity to opt-out of his or her personal information being used for mail-outs and dissemination of information and the member or employee 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), members and employees can withhold or withdraw their consent for CHOA to use their personal information in certain ways. A member or employees 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 member or employee in making the decision.
2.5 We may collect, use or disclose personal information without the member or employees 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
- The personal information is collected by observation at a public performance and/or seminar at which the individual voluntarily appeared
- The disclosure is to a public body or a law enforcement agency in Canada, concerning an offence under the laws of Canada or a province, to assist in an investigation, or in the making of a decision to undertake an investigation
Policy 3 – Using and Disclosing Personal Information
3.1 We will only use or disclose member and employee 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 provide answers to queries made;
- To conduct member surveys in order to enhance the provision of our services;
- To contact our members and employees directly about a services that may be of interest;
- To provide information and updates regarding legislative changes and/or changes within the strata industry that may be of interest to our members and employees
3.2 We will not use or disclose member or employee personal information for any additional purpose unless we obtain consent to do so.
3.3 We will not sell member or employee lists or personal information to other parties unless we have consent to do so.
3.4 Private and/or personal information regarding an associate member, business member or a strata corporation (including either a strata council or a member of the strata corporation) that identifies either party will not be released from CHOA without the prior written consent of the person relating to that information.
Policy 4 – Retaining Personal Information
4.1 If we use member or employee personal information to make a decision that directly affects the member or employee, we will retain that personal information for at least one year so that the member or employee has a reasonable opportunity to request access to it.
4.2 Subject to policy 4.1, we will retain member or employee 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 member or employee personal information is accurate and complete where it may be used to make a decision about the member or employee or disclosed to another organization.
5.2 Members or employees 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.
A request to correct personal information should be forwarded to the Privacy Officer.
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. If the correction is not made, we will note the member or employees’ correction request in the file.
Policy 6 – Securing Personal Information
6.1 We are committed to ensuring the security of the member or employees’ 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 member or employees personal information is appropriately protected by:
- the use of locked filing cabinets;
- physically securing offices where personal information is held;
- the use of passwords, encryption, firewalls;
- restricting employee access to personal information as appropriate (i.e., only those that need to know will have access);
- contractually requiring any service providers to provide comparable security measures.
6.3 We will use appropriate security measures when destroying member and employee personal
information such as:
- shredding documents,
- 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 Members and Employees Access to Personal Information
7.1 Members and employees 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. A request to access personal information should be forwarded to the Privacy Officer.
7.3 Upon request, we will also advise members and employees 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 member or employee of the cost and request further direction from the member or employee 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 member or employee in writing, providing the reasons for refusal and the recourse available to the member or employee.
Policy 8 – Questions and Complaints: The Role of the Privacy Officer or designated individual
8.1 The Privacy Officer is responsible for ensuring CHOA’s compliance with this policy and the
Personal Information Protection Act.
8.2 Members or employees should direct any complaints, concerns or questions regarding CHOA compliance in writing to the Privacy Officer. If the Privacy Officer is unable to resolve the concern, the member or employee may also write to the Information and Privacy Commissioner of British Columbia.
Contact information for CHOA Privacy Officer:
Communications, Privacy and Strata Advisor
Suite 222- 1175 Cook St.
Victoria, BC V8V 4A1
Direct phone: 250-381-9088