ONTARIO ABORIGINAL HOUSING SUPPORT SERVICES CORPORATION
Policy On the Collection, Use and Disclosure Of Personal Information
1. Objective & Scope of Policy
Ontario Aboriginal Housing Support Services Corporation OAHS is committed to respecting your privacy and has prepared this Policy to inform you of our policy and practices concerning the collection, use and disclosure of Personal Information.
This Policy governs Personal Information collected from and about (i) individuals who are or may become Clients of OAHS and (ii) individuals or organizations with whom OAHS works with.
Using contractual or other arrangements, OAHS shall ensure that agents, contractors or third party service providers, who may receive Personal Information in the course of providing services to OAHS as part of our delivery of housing policy and property management services, protect that Personal Information in a manner consistent with the principles articulated in this Policy.
This Policy does not cover aggregated data from which the identity of an individual cannot be determined. OAHS retains the right to use aggregated data in any way that it determines appropriate.
In the event of questions about: (i) access to your Personal Information; (ii) OAHS’s collection, use, management or disclosure of Personal Information; or (iii) this Policy; please contact:
Don McBain, Executive Director
500 Bay Street
Sault Ste Marie, Ontario P6A 1X5
Toll Free: 866-391-1061
2. The Collection, Use & Disclosure of Personal Information
For the purposes of this Policy:
“Client” means an individual who may or has purchased services from OAHS or has applied for or become a residential tenant in an OAHS administered housing portfolio;
“Personal Information” means any information, recorded in any form, about an identified individual, or an individual whose identity may be inferred or determined from such information.
This office only collects personal information necessary to provide effective housing services and/or qualify individuals and families for tenancy required by existing or future housing programs. This information includes but is not limited to, credit/ financial information, family composition and family income information. As mutually agreed personal banking information is collected to facilitate direct payment transfer with that information being retained in accordance with Canadian Payments Association Regulations.
OAHS as a contracted provider of services is required by way of information transfer to provide personal information obtained from clients to Provincial Ministries, Federal Housing Corporations to ensure program guideline compliance. This personal information is subject to their individual privacy policies.
OAHS’s use of Personal Information is limited to these purposes. OAHS does not sell, trade, barter or exchange for consideration any Personal Information it has obtained. Unless permitted by law, no personal information is collected about an individual without first obtaining the consent of the individual to the collection, use and dissemination of that information.
Personal information will be collected, to the extent possible, directly from the individual concerned. Personal Information may also be transferred to another company in the event of a change of ownership of all or part of OAHS.
OAHS may disclose Personal Information of Clients to organizations that perform services on its behalf. This will only be done if such organizations agree to use such information solely for the purposes of providing services to OAHS and, with respect to that information, to act in a manner consistent with this Policy.
Please note that there are circumstances where the use and/or disclosure of Personal Information may be justified or permitted or where OAHS is obliged to disclose information without consent. Such circumstances may include:
- Where required by law or by order or requirement of a court, administrative agency or other governmental tribunal;
- Where OAHS believes, upon reasonable grounds, that it is necessary to protect the rights, privacy, safety or property of an identifiable person or group;
- Where it is necessary to establish or collect monies owning to OAHS;
- Where it is necessary to permit OAHS to pursue available remedies or limit any damages that OAHS may sustain; or
- Where the information is public.
Where obliged or permitted to disclose information without consent, OAHS will not disclose more information than is required.
OAHS endeavours to ensure that any Personal Information provided by Clients and in its possession is as accurate, current and complete as necessary for the purposes for which OAHS uses that data. Information contained in files that have been closed is not actively updated or maintained.
OAHS retains Personal Information as long as OAHS believes it is necessary to fulfil the purpose for which it was collected and Firm legal or business requirements.
OAHS endeavours to maintain adequate physical, procedural and technical security with respect to its offices and information storage facilities so as to prevent any loss, misuse, unauthorized access, disclosure, or modification of Personal Information.
OAHS further protects Personal Information by restricting access to it to those Employees and Contractors that the management of OAHS has determined need to know that information in order that OAHS may provide services to Clients.
6. Access to Personal information
OAHS permits access to and review of Personal Information held by OAHS about an individual by the individual concerned.
If an individual believes any Personal Information concerning that individual is not correct, that person may request an amendment of that information by sending a request to the person indicated in Section 1 of this Policy. OAHS reserves the right not to change any Personal Information but will append any alternative text the individual concerned believes appropriate. Where not required to be retained by the Firm, an individual may also request that OAHS delete an individual’s Personal Information from OAHS’s system and records. However, due to constraints of computer technology and the fact that OAHS backs up its systems, Personal Information may continue to reside in OAHS’s systems after deletion. Individuals, therefore, should not expect that their Personal Information would be completely removed from OAHS systems in response to an accepted request for deletion.
OAHS reserves the right to decline access to Personal Information where the information requested:
a) Would disclose the Personal Information of another individual or of a deceased individual;
b) Would disclose business confidential information that may harm OAHS or the competitive position of a third party;
c) Is subject to solicitor-client or litigation privilege;
d) Could reasonably result in: (i) serious harm to the treatment or recovery of the individual concerned; (ii) serious emotional harm to the individual or another individual; or (iii) serious bodily harm to another individual;
e) May harm, or interfere with, law enforcement activities and other investigative or regulatory functions of a body authorized by statute to perform such functions;
f) Is not readily retrievable and the burden or cost of providing would be disproportionate to the nature or value of the information; or
g) Does not exist, is not held, or cannot be found by OAHS.
Where information will not or cannot be disclosed, the individual making the request will be provided with the reasons for non-disclosure.
Where information will be disclosed, OAHS will endeavor to provide the information in question within a reasonable time and no later than 30 days following the request.
OAHS will not respond to repetitious or vexatious requests for access. In determining whether a request is repetitious or vexatious, it will consider such factors as the frequency with which information is amended, the purpose for which the information is used, and the nature of the information.
To guard against fraudulent requests for access, OAHS will require sufficient information to allow it to confirm the identity of the person making the request before granting access or making corrections.
7. Amendment of Practices and This Policy This statement is in effect as of January 1, 2004.
OAHS will from time to time review and revise its privacy practices and this Policy. In the event of any amendment, an appropriate notice will be communicated to Clients and others in an appropriate manner.