Application / Tenant Privacy Policy

Purpose and Scope

Elk Valley Family Society respects and upholds an individual’s right to privacy and to protection of his/her personal information. Elk Valley Family Society is committed to ensuring compliance with applicable privacy legislation. This document sets out the policy of Elk Valley Family Society with respect to the protection of the personal privacy of our applicants/tenants.

Definitions

"Personal information" for the purposes of this policy means information about an individual. It does not include aggregate information which cannot be associated with a specific individual and it does not include the name, title, business address, business e-mail address, or business telephone number of an individual.

"Third party" for the purposes of this policy is an individual or an organization other than the Elk Valley Family Society and the applicant/tenant.

Our Responsibilities

1. Accountability

Elk Valley Family Society is accountable for the personal information in its possession or control, including information that has been transferred to a third party for processing. Elk Valley Family Society has appointed a Privacy Officer who is responsible for the organization’s compliance with this Policy.

All staff are obligated to protect the personal privacy of applicants /tenants with regard to all personal information collected by Elk Valley Family Society. Staff are required to follow the procedures of this Policy regarding the management of personal information.

Staff will be adequately trained and provided with information about the privacy laws applying to the organization.

2. Purposes for Collection, Use & Disclosure

Elk Valley Family Society collects and uses personal information about applicants and/or tenants for the following purposes:
  1. to assess the need for housing;
  2. to determine eligibility for housing provided by our organization;
  3. to assess any special needs an applicant may have with respect to housing, such as a need for accommodation of certain disabilities, and to determine our ability to accommodate these special needs;
  4. to determine eligibility for a housing subsidy;
  5. to assist applicants in filling out a rental accommodation application, or an application for a subsidy, if assistance is required;
  6. to verify information provided in the rental accommodation application or the subsidy application;
  7. to provide for housing needs;
  8. to process payments for services provided, such as rental payments;
  9. to enable us to collect payments owing to us which are overdue;
  10. to enable us to communicate with applicants/tenants;
  11. to enable us to provide statistical information to potential funding organizations; and
  12. to enable us to protect the safety and security of the rental accommodation for our tenants [and staff].

Elk Valley Family Society will not collect, use or disclose information beyond that required to fulfill the specified purposes. When personal information that has been collected is to be used for a purpose not previously identified, the new purpose will be identified prior to use.

3. Consent

Unless we hear otherwise from you, your use of the Elk Valley Family Society‘s services and facilities constitutes consent for us to collect, use, and disclose personal information for the purposes stated in this Policy.

You may refuse or withdraw consent at any time, subject to legal and contractual restrictions and reasonable notice. Refusal or withdrawal of consent may prevent us from providing to you a service or access to our facilities.

You may refuse or withdraw your consent by contacting us at Elk Valley Family Society, P.O. Box 2169, Fernie, B.C., V0B 1M0 (phone 250-423- 4213 or by fax 250-423- 4179). Our staff will explain your options and any consequences of refusing or withdrawing consent, and will record your choices.

4. Disclosure of Information to Third Parties

The only circumstances under which personal information may be disclosed to third parties is for the fulfillment of any purposes identified above, with express consent, or as required by law. If personal information is disclosed to third parties for the fulfillment of any purposes identified above, Elk Valley Family Society will ensure that appropriate security undertakings, such as confidentiality clauses in contractual agreements, are employed to protect the transfer and use of personal information. Elk Valley Family Society does not sell, trade, or rent information to third parties.

5. Limiting Collection

We collect personal information only for the purposes identified above.

6. Limiting Use, Disclosure, and Retention

We do not use or disclose personal information for any purpose other than those for which it was collected, except as required by law, or with consent. Personal information is retained only as long as is necessary for the fulfillment of the purposes for which it was collected, or as required by law.

7. Accuracy

The Elk Valley Family Society will make all reasonable efforts to ensure that personal information is as accurate, complete, and current as required for the purposes for which it was collected. The Elk Valley Family Society relies on applicants/tenants to ensure that certain information about them, such as their contact and reference information, is current, complete, and accurate. It is the applicant’s/tenant’s responsibility to inform Elk Valley Family Society if their personal information changes.

Elk Valley Family Society will not routinely update personal information, unless such a process is necessary to fulfill the purposes for which the information was collected.

8. Safeguards

Elk Valley Family Society uses security safeguards to protect personal information. These safeguards are appropriate to the sensitivity of the information.

Elk Valley Family Society will make all reasonable efforts to protect personal information against loss or theft, as well as unauthorized access, disclosure, copying, use, or modification.

The security safeguards include:
  1. Physical measures (ie.: archiving; locked offices and filing cabinets; monitored and alarmed office)
  2. Administrative measures (ie. immediate filing of all application forms; timely destruction of old files; protection of files in use from access by unauthorized persons; Records Retention Policy which states how and when records are to be destroyed)
  3. Technological measures (ie. the use of passwords; the implementation of firewalls for all computers accessing the Internet where personal information is stored)

9. Individual Access

Individuals have the right to access their personal information under the control of Elk Valley Family Society. The Privacy Officer will assist them with their access requests. We will deal with access requests within 30 days of the request being made.

Access requests should be made, in writing, to the Privacy Officer at Elk Valley Family Society, P.O. Box 2169, Fernie, B.C., V0B 1M0 (or by fax at 250-423- 4179). In certain exceptional situations, further to privacy legislation, we may not be able to provide access to certain personal information that we hold about applicants/tenants. Examples of where we may not provide access include, but are not limited to, the following:
  • where provision may reveal personal information about another individual;
  • where the information is subject to solicitor-client privilege;
  • where the information was collected in relation to the investigation of a breach of an agreement or a contravention of a federal or provincial law; or
  • where provision could reasonably be expected to threaten the health or safety of an individual.

If access cannot be provided, Elk Valley Family Society will notify the individual making the request, in writing, of the reasons for the refusal.

10. Openess Concerning Policies and Practices

The Elk Valley Family Society will make available specific information about its policies and practices regarding the management of personal information. To contact us to obtain further information regarding our policies and practices, please refer to section 12 below.

11. Revisions To This Privacy Policy

The development of the Elk Valley Family Society’s policies and procedures for the protection of personal information is an ongoing process. Due to changes in technology and legal requirements we may revise this Policy from time to time. Please ensure that you refer to the current version of the Elk Valley Family Society‘s Privacy Policy. The current version will be filed in the Elk Valley Family Society Policy Manual.