Privacy of personal information is an important principle to Wolverine Property Management. We are committed to collecting, using and disclosing personal information responsibly and only to the extent necessary for the premises, goods and services we provide. We also try to be open and transparent as to how we handle personal information. This document describes our privacy policies. We collect personal information on behalf of ourselves and the owners whose properties we manage. In this policy, when we use the terms "we", "our", and "us", the intention is to refer collectively to ourselves and our clients.
Personal information is information about an identifiable individual. Personal information includes information that related to their personal characteristics (e.g. gender, age, income, home address or phone number, family status), their health (e.g. disabilities) or their activities and views (e.g. religion, politics, opinions expressed by an individual, opinions about 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.
As of January 1st, 2004, all Canadian organizations engaged in commercial activities must comply with the Personal Information Protection and Electronic Documents Act ("PIPEDA")and the Canadian Standards Association Model Code for the Protection of Personal Information incorporated by reference into PIPEDA. These obligations extend to property management companies, including Wolverine Property Management.
Personal Information at Wolverine Property Management
Our organization, Wolverine Property Management, is dedicated to property management with integrity. In doing so, we often collect and use personal information.
Collecting Personal Information: Primary Purpose
We collect, use and disclose personal information fairly and in accordance with the law. The primary purpose for collecting personal information is to ensure our tenants’ safety, security and reasonable enjoyment and that of the other tenants, to ensure they have access to the premises, equipment and services that we have agreed to provide, to preserve the property and to collect rents and other fees. Examples of the type of information we collect for these purposes includes the following:
Names of all occupants of the unit
• Business and emergency contact information
• Use and intended uses of the property
• Compliance with the tenancy agreement and our client’s rules and regulations
• Payment, banking and other financial information
• Any special needs of tenants (e.g. disability or health)
• The amount of rent payable with respect to each rental unit
• Social insurance number, but only for the purpose of issuing a tax receipt where applicable for interest on the rental deposit (last month’s rent) and
• Photo identification such as a Driver’s License
As a service and convenience for tenants 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 in writing.
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 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 landlords about prospective tenants to us. In return, we provide information to the service in order for the service to maintain a databank of the tenant’s history. We collect your full legal name and date of birth to ensure the accuracy of these records. Having a good tenant history filed with the service will make it easier for you to be accepted as a tenant at other properties in the future. We obtain your consent for using the consumer reporting service in the rental application form and tenancy agreement.
The information described above and the information set out below about prospective tenants can be collected or updated if the tenant is in arrears of rent or fees or wishes to renew a tenancy agreement.
About Prospective Tenants
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 would include the following types of information:
Past tenancy history
• Employment history
• References and conduct history
• Financial means and credit history
• Automobile information
• Intended use of the premises and
• Photo Identification such as a Driver’s License
We 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 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., government, court, tribunal or criminal records). By completing a rental application form you agree to us collecting this information about your suitability to be a tenant.
About 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 may operate security cameras and monitor the presence, vehicles and the conduct of visitors and non-tenants on our property.
The collection of information about tenants or persons by way of video surveillance will be communicated by way of signage at the property advising that the premises are subject to video monitoring and images collected will be stored securely and reviewed and released only for the purposes of investigating and documenting security breaches or property offences. Our placement of equipment and monitoring of persons is designed to maximize security and to minimize intrusions in areas where persons may reasonably expect privacy.
We believe that the collection of this information is implied by the private and residential nature of our property. Secondly, we 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 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.
On our website, like most other commercial websites, we may monitor traffic patterns, site usage and related site information in order to optimize our web service. We may provide aggregated information to third parties, but these statistics do not include any identifiable personal information.
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. skill of a particular employee of a supplier or contractor, inappropriate behaviour or comments by a particular representative). 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.
About Contract Staff
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).
Collect Personal Information: Related and Secondary Purposes
Like most property managers, 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, including assessing the performance of our consultants, suppliers and staff. In addition, external consultants (e.g. auditors, lawyers, business consultants) may on our behalf do audits and continuing quality improvement reviews of our operations, including reviewing tenant or client files and interviewing our staff.
• 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, or 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 those services.
• If Wolverine Property Management or its assets were to be sold, managed or financed, the purchaser would want to conduct a "due diligence" review of the organization’s records to ensure that it is a viable business that has been honestly portrayed to the purchaser. This due diligence may involve some review of our accounting and service files. The purchaser would not be able to remove or record personal information. Before being provided access to the files, the purchaser must provide a written promise to keep all personal information confidential. Only reputable purchasers who have already agreed to buy the organization’s business or its assets would be provided access to personal information, and only for the purpose of completing their due diligence search prior to closing the purchase.
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 many choices about some of the secondary purposes (e.g. external regulation).
Protecting Personal Information
We understand the importance of protecting personal information. For that reason, we have taken the following steps:
Paper information is either under supervision or secured in a locked or restricted area.
• Electronic hardware is either under supervision or secured in a locked or restricted area at all times. In addition, passwords are used on computers. All of our cell phones are digital, which signals are more difficult to intercept (however, we still are careful on cell phones because sometimes they switch over to an analog service).
• Paper information is transmitted through sealed, addressed envelopes or boxes by reputable companies.
• Electronic information is transmitted either through a direct line or is anonymized or encrypted.
• External consultants and agencies with access to personal information must provide us with appropriate privacy assurances.
Retention and Destruction of Personal Information
We need to retain personal information for some time to ensure that we can answer any questions you might have about the services provided and for our own accountability to external regulatory bodies. 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. 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 3 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 or completely reformatted.
Accessing Personal Information
You may ask for access to the personal information we hold about you. Detailed requests which require archive or other retrieval costs may be subject to our normal professional and disbursement fees.
If we collected personal information on behalf of a landlord client we may have conveyed that information directly to the landlord. If so, we may not have it as a part of our own files and you will have to go to the landlord to look at the information.
Your rights to access your personal information are not absolute. There are a number of situations where we may deny access. If we deny your request for access to or refuse a request to correct personal information, we will provide a reason or reasons for doing so.
Questions and Requests for Access
If you have any questions or wish to access your personal information, please contact our Corporate Privacy Officer at:
Corporate Privacy Officer
Wolverine Property Management
PO Box 423,
St Jacobs, Ontario N0B 2N0
If you are not satisfied with our response, the Privacy Commissioner of Canada can be reached at:
112 Kent Street
Ottawa, Ontario, K1A 1H3
Updating Your Information
It is important that the information be accurate and up-to-date. If during the course of your tenancy, any of your information changes, please inform us that we can make any necessary changes.