Privacy Policy

The Canadian Condominium Institute, ("CCI"), London & Area Chapter ("CCI London"), provides a broad range of services to our members. We have a longstanding policy of protecting the privacy of our members in the course of providing services to them. Our relationship with our members is based upon trust and maintaining member privacy and is, therefore, given the utmost priority.

The CCI London Privacy Policy is a formal statement of principles and guidelines that we have adopted for the protection of personal information ("PI") we may collect for or on behalf of our members. Our objective in developing this Privacy Policy is to promote responsible practices in the management of PI in accordance with the provisions of the Personal Information Protection and Electronic Documents Act, ("PIPEDA"). This policy is organized according to the principles of the Canadian Standard's Associations Model Code, which forms the basis of that law.

1. Privacy Policy

The CCI London recognizes the importance of privacy and the sensitivity of PI. We understand that we have an obligation to keep confidential all PI we receive from our members and other individuals. We are committed to protecting any PI we hold. This Privacy Policy outlines how we manage an individual's PI and safeguard their privacy.

2. Your Privacy Rights

From January 1, 2004, all organizations engaged in commercial activities must comply with the PIPEDA and the Canadian Standards Association Model Code for the Protection of PI which it incorporates. These obligations extend to the CCI London. The Act gives individual's rights concerning the privacy of their PI.

CCI London is responsible for the PI we collect and hold. To ensure this accountability, we have developed this policy, and trained our directors and support staff about our policies and practices.

3. Why Does CCI London & Area Chapter Need PI

CCI London provides educational services and products to a wide range of members and some non-members. We require some PI to provide these services; to create and maintain membership lists; and to produce direct marketing materials concerning our services and developments in the condominium community.

4. What PI do we collect?

PI is any information that identifies an individual, or by which their identity could be deduced. If we did not collect and use PI we could not effectively provide our members with all our services.

PI collected from individuals include, but is not necessarily limited to, the following:

name, home address, and home telephone and/or cell phone numbers
e-mail address
condominium name and address
credit card information
management firm, lawyer and auditor
banking information, (eg. from your membership fee cheques)
photographs and video recordings

5. How do we collect your PI?

We collect information only by lawful and fair means and not in an unreasonably intrusive way. Wherever possible we collect PI directly from the member at the start of their membership and through annual renewals. Additional information may be obtained from individuals through course registration or through questionnaires on issues relating to condominium living.

Sometimes we may obtain information about individuals from other sources, for example:

a management firm;
a government agency or registry;
another CCI chapter;
the National offices of CCI

6. Consent

In most cases, we ask individuals to specifically consent in writing, if we collect, use, or disclose their PI. In some circumstances, we may accept an individual's oral consent, or an individual's consent may be implied through their conduct with us (for example, when a member provides us with PI when completing their membership form or annual renewal).

7. Use of Your Information

We use PI to provide our services to individuals and to include the individuals in any direct mailings of information relating to condominium living that we believe would be of some interest to our members. We also will use it for marketing activities such as notification of up-coming meetings, courses, seminars, conferences and CCI products. If an individual advises that they no longer wish to receive information about our services, seminars or about new developments in the law, we will not send any further material.

CCI London does not disclose an individual's PI to any third party, (other than to our National office) to enable them to market their products and services. For example, we do not provide our client mailing lists to other organizations or businesses. On occasion other organizations, such as the Association of Condominium Managers of Ontario, ("ACMO") will forward complimentary publications to us to distribute to our members but they do not receive our membership list.

8. Disclosure of your PI

Under certain circumstances, CCI London will disclose an individual's PI:

when we are required or authorized by law to do so, for example, if a court issues a subpoena
when you have consented to the disclosure
to up-date the National offices of CCI with your membership information
where it is necessary to establish or collect membership fees
if we engage a third party to provide administrative services to us (such as a mailing service or archival file storage). In these cases, the third party will be bound by our Privacy Policy
if we retain agents or consultants to assist us in completing research relating to CCI or condominium living
if the information is already publicly known

In these instances we will only disclose such PI as is required in the circumstances.

9. Use of Photographs and Video Recordings

We may take photographs or video recordings of individuals during CCI events or meetings. These photographs and/or video recordings are property of CCI London. An individual's picture, name and the captions referred to below may be used indefinitely by CCI London or anyone authorized by it, including but not limited to the National offices of CCI, in all materials pertaining to their business and/or the promotion of the CCI or condominium living.

The photographs may be cropped and re-sized as necessary to fit pre-defined formats and used in all forms of communications in any media, including but not limited to publicity, exhibitions, books, DVDs, television and web/digital media presentations.

Since participation in CCI London events and meetings is voluntary, individuals waive any payments or compensation for the use of photographs and video recordings.

10. Updating Your Information

Since we use an individual's PI to provide our services, it is important that the information be accurate and up-to-date.

If during the membership term any of the member's PI changes, please inform us so that we can make any necessary changes.

11. Is My PI Secure?

CCI London takes all reasonable precautions to ensure that all PI is kept safe from loss, unauthorized access, modification or disclosure. Among the steps taken to protect your information are:

premises security
employee training in the storage, safeguarding and use of PI
restricted file access to PI
deploying technological safeguards such as security software and firewalls to prevent hacking or unauthorized computer access; and
internal password and security policies.

If we use the services of any third parties to process or store PI, we will enter into an agreement that requires them to protect this PI in a manner acceptable to us. In entering into these agreements, we do not transfer any interest in this PI to them. This is done to ensure that the PI delivered to third parties is maintained at a level equivalent to that provided for under this Privacy Policy.

12. Access to Your PI

Individuals may ask for access to any PI we hold relating to that themselves.

Summary information is available on request. More detailed requests that require archive or other retrieval costs may be subject to a reasonable fee.

We also reserve the right to confirm the identity of the person seeking access to PI before complying with any access requests. Please submit your access request in writing or e-mail to our privacy officer as identified below.

13. Correcting Errors

If CCI London holds information about an individual and the individual can establish that it is not accurate, complete and up-to-date, and we will take reasonable steps to correct it.

14. Can I be Denied Access to My PI?

In most cases, a member of CCI London will have access to the personal PI we store about them. However, there may be rare occasions when a member's request to access their own PI is denied, for example the PIPEDA indicates that:

rights to access PI are not absolute
denial of access is required or authorized by law
when granting access would have an unreasonable impact on other people's privacy;
when to do so would prejudice negotiations with you
to protect CCI London and CCI National's rights and property; or
where the request is frivolous or vexatious

If we deny a request for access to, or refuse a request to correct information, we will endeavor to explain why.

15. Can I request anonymity.

Whenever it is legal and practicable, we may offer the opportunity to deal with general inquiries without providing a member's name (for example, by accessing general information on our website).

16. Credit Bureaus

On occasion we may request information about an individual from the files of consumer agencies or file complaints with those agencies, such as where an individual has failed to pay a debt owed to us.

17. Communicating with CCI London by E-Mail

Individuals should be aware that e-mail is not a 100 percent secure medium and use caution if sending personal or confidential information or requesting CCI London to respond by e-mail.

18. Changes to this Privacy Policy

Since CCI London regularly reviews all of its policies and procedures, we may change our Privacy Policy from time to time. These changes will be posted to our web-site as soon as is practical.

19. Requests for Information Access and/or Corrections

Individuals with questions or wishing to access their PI are to write to our Privacy Contact, Trish Kaplan, at:

CCI London & Area Chapter
P.O. Box 51022
1593 Adelaide Street North
London, ON N5X 4P9
Tel: (519) 453-0672
E-mail: ccisw@cci-sw.on.ca

If an individual is not satisfied with our response, the Privacy Commissioner of Canada can be reached at:

112 Kent Street
Ottawa Ontario, K1A 1H3
1-800-282-1376.

We may seek external advice, where appropriate, before providing a final response to individual complaints.

20. Employment Inquiries

If an individual applies to CCI London for a job, we need to consider their PI, as part of our review process. We normally retain information from candidates after a decision has been made, unless that candidate asks us not to retain the information. If a job is offered and accepted, the information will be retained in accordance with our privacy procedures for employee records.

21. Web Site

Our website contains links to other sites, which are not governed by this Privacy Policy.

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 PI.

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