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Privacy Policy
The Canadian Condominium Institute, ("CCI"),
Manitoba Chapter, 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 is, therefore, given
the utmost priority.
The CCI Manitoba 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 PI 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 Manitoba 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. We are committed to protecting
any PI we hold. This Privacy Policy outlines how we manage your PI and safeguard
your privacy.
2. Your Privacy Rights
From January 1, 2004, all organizations engaged in commercial
activities must comply with the PI Protection and Electronic Documents Act
and the Canadian Standards Association Model Code for the Protection
of PI which it incorporates. These obligations extend to the CCI Manitoba.
The Act gives you rights concerning the privacy of your PI.
CCI Manitoba 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 Manitoba Need PI
CCI Manitoba provides educational services and products
to a wide range of members. We require some PI to provide theses services
to you; create and maintain membership lists; and 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 you, or by which
your identity could be deduced. If we did not collect and use your PI we
could not provide you with our services.
PI that we collect includes, but is not necessarily limited
to, the following:
- your name, home address, and home telephone and/or cell
phone numbers;
- your e-mail address;
- your condominium name and address;
- credit card information;
- management firm, lawyer and auditor;
- banking information, (eg. from your membership fee cheques);
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 your
PI directly from you at the start of your membership and through annual
renewals. Additional information may be obtained through course registration
or through questionnaires on issues relating to condominium living.
Sometimes we may obtain information about you from other
sources, for example:
- your management firm;
- from a government agency or registry;
- from another CCI chapter; or
- from the National offices of CCI .
6. Consent
In most cases, we shall ask you to specifically consent,
if we collect, use, or disclose your PI. Normally, we ask for your consent
in writing but in some circumstances, we may accept your oral consent. Sometimes,
your consent may be implied through your conduct with us, for example when
you provide us with PI when completing your membership form or annual renewal.
7. Use of Your Information
We use your PI to provide our services to you and to include
you in any direct mailings of information relating to condominium living
that we believe would be of some interest to you. We also will use it for
marketing activities such as notification of up-coming meetings, courses,
seminars, conferences and CCI products. If you tell us that you 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 Manitoba does not disclose your 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 Manitoba will disclose
your 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) and
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. Updating Your Information
Since we use your PI to provide our services to you, it
is important that the information be accurate and up-to-date.
If during the course of your membership any of your PI
changes, please inform us so that we can make any necessary changes.
10. Is My PI Secure?
CCI Manitoba takes all reasonable precautions to
ensure that your 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, safe guarding 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 which 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.
11. Access to Your PI
You may ask for access to any PI we hold about you.
Summary information is available on request. More detailed
requests which 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 in paragraph 18.
12. Correcting Errors
If CCI Manitoba holds information about you
and you can establish that it is not accurate, complete and up-to-date,
and we will take reasonable steps to correct it.
13. Can I be Denied Access to My PI?
In most cases, a member of CCI Manitoba will have access
to the PI we store about you. However, there may be rare occasions when
your rights to access your PI are denied, for example the PIPEDA indicates
that:
- your rights to access your PI are not absolute;
- denial of access is required or authorized by law;
- when granting you access would have an unreasonable impact
on other people's privacy;
- when to do so would prejudice negotiations with you;
- to protect CCI Manitoba and CCI National's rights
and property; or
- where the request is frivolous or vexatious.
If we deny your request for access to, or refuse a request
to correct information, we will endeavor to explain why.
14. Can I request anonymity.
Whenever it is legal and practicable, we may offer the
opportunity to deal with general inquiries without providing your name (for
example, by accessing general information on our website).
15. Credit Bureaus
On occasion we may request information about you from the
files of consumer agencies or file complaints with those agencies, such
as where a member has failed to pay a debt owed to us.
16. Communicating with Us By E-Mail and/or Fax
You should be aware that e-mail and fax are not a 100%
secure medium, and you should be aware of this when contacting us to send
personal or confidential information or requesting us to respond to you
by e-mail.
17. Changes to this Privacy Policy
Since CCI Manitoba 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.
18. Requests for Information Access and/or Corrections
If you have any questions, or wish to access your PI, please
write to our Privacy Contact, at:
CCI Manitoba
P.O. Box 2517
Winnipeg, Manitoba
R3C 4A7
Attention: Privacy Officer
Telephone: 204.944.8954
E-mail: ccimanitoba@cci.ca
If you are 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.
19. Employment Inquiries
If you apply to CCI Manitoba for a job, we need to consider
your PI, as part of our review process. We normally retain information from
candidates after a decision has been made, unless you ask us not to retain
the information If we offer you a job, which you accept, the information
will be retained in accordance with our privacy procedures for employee
records.
20. 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.
Thank you for taking the time to review our
Privacy Policy.
CCI Manitoba
"The Voice Of Condominiums"
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