Privacy Policy for the Collection, Use, Disclosure and Security of
Personal Information for Condominiums
ICC Property Management Ltd.
Last Updated: June, 2024
Introduction
ICC Property Management Ltd. (hereinafter called “the Manager”) is a Corporation created under the laws of Ontario for the purpose of carrying on business as a property management firm administering and managing multi-residential, industrial and commercial condominiums and providing services to its residents.
In the process of operating and managing multi-residential condominium corporations, the Manager collects certain personal information from unit owners, tenants and employees (hereinafter called “Individuals”) and may employ or contract third party services from a variety of individuals, companies and professionals who may need access to this personal information.
Personal Information means information that is personally identifiable to Individuals. This may include, without limitation, addresses, telephone numbers, email addresses, bank account numbers, payment histories, information about their family, seasonal address, emergency contact names and any special needs.It does not include de-identified or aggregate information or certain publicly available information.
This Privacy Policy is based on, and complies with, Canada’s Personal Information Protection and Electronic Documents Act (“PIPEDA”). It sets out principles that the Manager follows to ensure that it protects Individual’s personal information when it collects, uses or discloses it in the course of carrying on its activities. All of the Manager’s Employees, Contracted Employees and its Directors who have access to personal information must adhere to this Policy and related procedures.
The Manager shall use this policy and the guidelines of Section 55 of the Condominium Act, 1998 in its handling of the collection, use and disclosure of information.
No part of this policy shall contravene any part of the Condominium Act, 1998.
Collection
The Manager shall collect information necessary to maintain an accurate Owners Register as required by the Condominium Act, 1998. The Manager shall only collect information that is reasonably necessary for the purposes identified. The information will be collected by fair and lawful means.
Information that is typically collected includes, but is not limited to the following:
- Name
- Address – Current and Seasonal
- Telephone Numbers
- E-mail Address
- Name of Mortgagee on the unit
- Financial Institution and Bank Account Number
- Tenant Names
- Persons residing in unit
- Emergency Contact and Contact Information
- Vehicle Information including License Plate Numbers
- Special Needs of Owners
In addition, information other than as set out above may also be collected from time to time including, but not limited to:
- Video surveillance cameras are located throughout the building for security purposes and to record pedestrian and vehicular access to and within the property;
- Registration of visitors, including name, time of entry, license plate number and unit being visited;
- Computerized registration of access cards or fobs recording access point, time of use and registered user of access device;
- Listing of residents who would require special assistance during a fire emergency and;
- Other similar lists related to security, pre-authorized access to the building by relatives, guests or service individuals.
Use and Disclosure
BY PROVIDING YOUR PERSONAL INFORMATION TO US, YOU ARE CONSENTING TO THE COLLECTION, USE AND DISCLOSURE OF YOUR PERSONAL INFORMATION AS SET OUT IN THIS PRIVACY POLICY.
We may use and disclose your Personal Information in accordance with the consents that you provide, whether explicit or implied, as well as may be set out in this Privacy Policy.
The Manager shall not authorize the use of personal information for purposes other than those in keeping with the effective operation and management of the Condominium Corporation without the written consent of the individual.
The Manager periodically shares or transfers any personal information collected with its Clients (Board Members). The Manager also uses a number of employees, third party service providers, consultants and other agents that may in the course of their duties have limited access to personal information retained. These include building superintendents, maintenance staff, concierge, security staff, housekeeping staff, consultants, temporary employees or employees of third party suppliers, auditors, lawyers and others. We restrict their access to any personal information we hold except to the extent necessary for them to reasonably perform their role on the Owner’s behalf. The purpose of disclosing personal information to these parties is to ensure an Individual’s safety, security and reasonable enjoyment of their place of residence, to ensure Individual’s have access to their premises and services that the Manager provides, to preserve the property and to collect monies owing for the provision of services to Individuals.
Personal information will only be used or disclosed for the purpose for which it was collected unless an Individual has otherwise consented, or when it is required or permitted by law. In certain exceptional circumstances, the Manager may have a legal duty or right to disclose personal information without an Individual’s knowledge or consent with respect to matters that concern the public’s interest or in complying with the Condominium Act, 1998 or a court order.
The Manager shall not disclose matters of a financial nature concerning its relationship with any owner or resident with any person except the registered unit owner named in the Manager’s Owner Registry, unless the Manager has received written authorization from the owner or resident authorizing the disclosure of such information to an individual named in writing, or in the event that the Manager is presented with a Power of Attorney signed by the registered unit owner.
The Manager may also disclose information without the Owners’ consent when permitted by law including in situations involving medical emergencies, collection of debt and suspicion of illegal activities.
The Manager shall release information of a financial nature regarding their relationship with an owner as necessary in the preparation and distribution of a Status Certificate required by the Condominium Act, 1998.
The Manager shall allow an owner access to their information within a reasonable time upon receipt of a written request to view the information.
Certain Personal Information We Collect, From Where We Collect It, Why We Collect It, and With Whom We Share It
The chart below outlines various categories of Personal Information that we may collect from you, along with the sources, purposes of collection, and the types of entities we may share your information with. By providing us with your Personal Information, you are consenting to its collection, use, and disclosure as detailed in the chart, unless you notify us otherwise.
| Categories of Personal Information | Categories of Sources | Purpose(s) for Collection of Personal Information | Categories of Third Parties with Which Personal Information is Shared for a Business Purpose |
| Personal Identifiers – such as name, postal address, Internet Protocol address, email address, social insurance numbers, emergency contact information, or other similar identifiers | Individuals directly Your association | Providing products and services Responding to inquiries Security processes Human resources functions Recruiting Property management Assisting your association with its operations | Service providers (vendors that provide services to us in connection with the operation of our business, and can include vendors that process payments, perform human resources functions, verify information, manage information, provide security services, cloud-based data storage, host our webpage and assist with other IT-related functions, provide analytics information, facilitate conferencing, legal and accounting services, among other business functions). Your association. Employee benefits administrators and providers. |
| Information related to you, your vehicle and your property Payment and financial information | Individuals directly Your association Onsite assessment | Property management, including as it may relate to your vehicle and the management and maintenance of your property as well as common areas Processing payments such as rent and condo fees | Service providers including accounting, inspection, cleaning, maintenance, repair, construction and security services Financial institutions and credit card companies |
| Video and audio recordings of you and your vehicle in the public areas where security cameras are in operation | CCTV cameras | Security and management of the property | Service providers including monitoring and security services Police and other government authorities |
| Audio recordings of you when you call our call center | Individuals directly | Management of the property Answer inquiries and address concerns | Service providers |
| Sensitive information – such as gender, age, disability status, pregnancy status, citizenship, medical condition, physical or mental disability | Employees | Human resources functions | Service providers |
| Professional or Employment information- such as information about past employers, work history, skills, educational background, and references | Job applicants Employees Recruiting agencies or platforms Referral sources | Human resources functions Recruiting | Service providers |
| Internet or other electronic network activity information, including browsing and search history | Individuals interacting with our website and mobile apps Employees | Security processes Providing products and services Internet marketing | Service providers |
| Education information | Job applicants Employees Recruiting agencies or platforms Referral sources | Human resources functions Recruiting | Service providers |
| Audio information | Individuals who call our customer service line | Quality assurance and training |
Service Providers
We may engage certain service providers to assist us in our activities or to provide services directly to you at our request. Consequently, it may be necessary to disclose your Personal Information to these service providers. Specific instances where we may share your Personal Information with a service provider are detailed in the chart above.
We will take measures to ensure that these service providers use and disclose your Personal Information solely as required to deliver the services and that they comply with the terms of this Privacy Policy.
Storage and Processing Information Outside Canada
Some of our affiliated companies are located in the United States, and certain service providers are situated outside of Canada. Therefore, we may transmit your Personal Information to our affiliated companies and third parties outside of Canada to support our business operations. By providing us with your Personal Information, you consent to its transfer, storage, processing, and handling outside of Canada. Please note that various governments worldwide may require organizations under their jurisdiction to provide information, including Personal Information, to the government without notice or consent from the affected individual.
Marketing
For each category of Personal Information we collect, as detailed in the chart above, we may use your Personal Information to market products and services that we believe may interest you. This includes our own products and services, those of our affiliates, and products and services from third parties.
Additional Information Regarding Our Collection, Use, and Sharing of Personal Information
Privacy laws may permit or require the collection, use, and disclosure of Personal Information without the individual’s knowledge or consent in specific circumstances. We reserve the right to collect, use, and disclose your Personal Information in these instances without your knowledge or consent, including but not limited to the following circumstances:
- To comply with legal obligations.
- When we believe in good faith that an applicable law requires it.
- At the request of governmental authorities or other third parties conducting an investigation.
- To detect and protect against fraud, technical or security vulnerabilities.
- To respond to an emergency.
- To protect the rights, property, safety, or security of our business, third parties, visitors to our websites and mobile apps, or the public.
We may monitor your use of our websites and mobile applications to ensure proper use and operation, compliance with any related terms of use or agreements, and to protect the security and safety of our business, computer systems, software, Personal Information, and data.
We may also share Personal Information with any individual or entity to whom we transfer our rights or obligations under any agreement, in connection with a sale, merger, or consolidation of our business, or other asset transfer, whether voluntarily or by operation of law. This includes anyone deemed to be our successor or transferee.
Our Use of Cookies
We may send text files (such as “cookies” or other cached files) or images to your web browser for technical convenience, storing information on your computer. For example, we might use a cookie to save form information you’ve entered so you don’t have to re-enter it. Information stored in these text files and images can be used to customize your experience on our website and to monitor its usage. You can set your browser to notify you when you receive a cookie, and many web browsers also allow you to block cookies. However, blocking cookies may prevent you from accessing certain parts of our website.
Additionally, we allow third parties to set cookies and other trackers when you use our services, which may collect information about your online activities over time and across different websites, applications, or other online platforms. These third parties may use this information to provide analytics or offer products and services that may interest you. They may also combine information about your activities across different websites, applications, or other online platforms.
Do Not Track
“Do Not Track” is a privacy preference that users can set in certain web browsers. However, we do not comply with automated browser signals regarding tracking mechanisms, which may include “do not track” instructions.
Personal Information of Minors
Our products and services are not directed to minors under the age of 13, and we do not knowingly collect or sell the Personal Information of minors under 16.
Personal Information of Others
You may not provide us with any Personal Information of others unless you have their consent or are otherwise permitted by law to do so.
Requests for Access to Personal Information
Upon your written request, we will provide you with:
- Access to your Personal Information (if any) under our custody or control.
- Information about the purposes for which your Personal Information has been and is being used by us.
- The names of persons to whom, and the circumstances under which, your Personal Information has been and is being disclosed by us.
All requests may be subject to reasonable fees and disbursements. Where appropriate, we may require advance payment of a deposit or the entire costs of responding to a request for access to Personal Information.
Requests Must Be in Writing
All requests for access must be in writing and signed by the requester. We require sufficient information and detail from the requester to verify their identity, properly locate the information, and respond to the request.
Limits on Individual Rights to Information
An individual’s ability to access their Personal Information under our control is not absolute. We reserve the right not to disclose Personal Information, or its existence, in certain circumstances. For example, we may not disclose Personal Information where:
- The disclosure could reasonably be expected to threaten the safety or physical or mental health of an individual.
- The disclosure would reveal Personal Information about another individual.
- The disclosure would reveal confidential commercial information.
- The Personal Information was collected by us for an investigation or legal proceeding.
Requests for Correction of Personal Information
Upon your request, we will correct errors or omissions in your Personal Information where that information is in our custody or control. All such requests must be in writing and signed by you. We may require sufficient information and detail from you to verify your identity, properly locate the information, and respond.
If you make such a request, we will either:
- Correct the Personal Information and, if reasonable to do so, send correction notifications to any third party to whom we disclosed the incorrect information.
- Decide not to correct the Personal Information but will retain a record that a correction was requested but not made.
Corrections or amendments will rarely, if ever, be made to opinions, including expert or professional opinions, as opposed to factual information, which may be corrected if in error.
Our Commitment to Honoring Your Rights
If you exercise any of your rights described in this Privacy Policy, we will continue to treat you fairly.
Changes to This Privacy Policy
We will review and update this Privacy Policy as necessary to stay current with rules and regulations, new technologies and security standards, and changes to our business and privacy practices. We will post the updated Privacy Policy on our website and update the modification date at the top of the policy. If the changes are material, we will post a notice of the changed Privacy Policy on our website and may notify you by email if we have your email address.
Limited Nature of This Privacy Policy
Nothing contained in this Privacy Policy is intended to create a contract or agreement between you and us, and you may not rely on it as such.
Accuracy & Security
The Manager will keep all personal information as accurately and as current as necessary to fulfill the identified purposes for which it was collected. The Manager will update or correct any personal information held by it if the individual concerned provides the Manager with particulars of any information which requires updating or correction.
The Manager acknowledges the responsibility of safely maintaining accurate records for the purpose of operating the Condominium Corporations. All information kept in the on-site management offices will be stored out of site of visitors or guests to the on-site management offices.
Personal information is safeguarded to protect against loss, theft or unauthorized access, disclosure, use or modification of information using physical, organizational and electronic security measures.
Accountability
A copy of this policy and Section 55 of the Condominium Act, 1998 shall be kept available in the offices of the Manager and will be made available for review upon request.
Owners or residents may address specific concerns regarding the use or distribution of personal information to their on-site Property Manager.
The Manager will ensure that their employees strictly comply with the Policy.
Questions or Concerns
The Manager has policies and procedures to receive, investigate and respond to any questions or concerns respecting this Privacy Policy or the personal information that is held. Individuals may contact the Manager’s Privacy Officer with any questions or concerns or to request access to their personal information.
Privacy Officer
The Privacy Office of the Manager is Mr. Steven Christodoulou, c/o ICC Property Management Ltd., 2875 14th Avenue, Suite 300, Markham, Ontario L3R 5H8
