What is PIPEDA?
The Personal Information Protection and Electronic Documents Act (PIPEDA) sets out ground rules for how private sector organizations may collect, use or disclose personal information in the course of commercial activities. PIPEDA also applies to federal works, undertakings and businesses in respect of employee personal information. The law gives individuals the right to access and request correction of the personal information these organizations may have collected about them.


What is Personal Information?
Personal information includes any factual or subjective information, recorded or not, about an identifiable individual. This includes information in any form, such as:
• Age, name, ID numbers, income, ethnic origin, or blood type;
• Opinions, evaluations, comments, marital status, social status, or disciplinary actions; and
• Employee files, credit records, loan records, medical records, existence of a dispute between a consumer and a merchant, intentions (for example, to acquire goods or services, or change jobs).


What is Not Considered Personal Information?
Personal information does not include the name, title or business address or telephone number of an employee of an organization. In addition, information readily available on the public Internet sites (as opposed to internal web sites sometimes referred to as “intranet sites”), in the public domain, or accessible via the Access to Information Act, which gives Canadian citizens, permanent residents, or any person or corporation present in Canada a right to access information that is contained in government records.


Privacy Policy
Olaya Management and Accounting Inc. (“Olaya”) considers respecting your privacy an important principle of how we do business. We are committed to collecting, using and disclosing personal information responsibly and only to the extent necessary for the services we provide and to the extent required to comply with legislation. We are diligent in our efforts to respect privacy and are committed to always being open and transparent as to how we handle personal information. This document describes our company’s privacy policies.


Why Is Information Collected About You?
At Olaya, we gather and use personal information to provide the services that you have requested. Providing us with your personal information is always your choice. However, your decision to withhold certain personal information may prevent us from providing you with the services you require and this may compromise our ability to service our client in the case of managing a condominium corporation. In these cases, the Condominium Act, 1998 may provide Olaya, as agents of the corporation, with the right to access information, solely and exclusively for the purposes of managing the day-to-day operations of the corporation or to meet the statutory obligations of the condominium corporation.


What Type of Information Does Olaya Collect?
For residents, the type of information Olaya usually collects and maintains on file may include name, current address, previous address, telephone number(s), email address(es), social insurance number, date of birth, sex, place of employment, annual income, emergency contact information, credit history and bank information. For business clients, information recorded may include name(s) of Owner(s), Officer(s) and Director(s) and social insurance number(s). For contractors or suppliers, this information may include some or all of the above, but also trade certifications or licenses, Workplace Safety and Insurance Board and other insurance coverage information, price lists, etc.


Why Do We Collect, Use and Disclose Personal Information?
Personal information is collected to:
• Verify your identity;
• Determine your eligibility for the services you have requested or that you are able to provide the services, as quoted;
• Deliver the services you have requested;
• Deal with emergency situations;
• Comply with the municipal, provincial and federal laws, including tax requirements; and
• Within the condominium context, information needed to comply with the guiding legal framework as set out in each condominium corporation’s declaration, by-laws and rules.

Generally we will not ask to collect “sensitive” information about you. “Sensitive information” means information or an opinion about an individual's racial or ethnic origin, political opinions or memberships, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association or union, sexual preferences or practices, or health. We do not sell, rent or trade personal information about you to or with third parties, unless you consent, or this is required to provide services to you or your unit within a condominium corporation or to mitigate damages to the common elements.

Personal information may be shared between Olaya employees. In these cases, the purpose for which the information was originally collected will be taken into account.


How We Gather Information?
Olaya collects information from sources, such as:
• From you based on completed applications, forms, email messages, or face-to-face meetings or interactions;
• From registrations on web sites (intranet or extranet), or community portal sites;
• From security camera recordings where security equipment is installed in common areas and where signs have been posted advising of same;
• From previous landlords, employers or references that you have provided to us;
• From your interactions with us (e.g., through your payment history);
• From consumer reporting agencies (e.g., credit history).

Olaya will not collect personal information in an unfair, unlawful or unreasonably intrusive manner.


When Do We Disclose Information?
We keep your personal information confidential except when authorized by you or when required or permitted by law to disclose the information. This includes the day-to-day operation of a condominium corporation, which is Olaya’s primary business.

Our employees, in the course of daily operations, may be required to access your personal information. As a condition of their employment, all Olaya employees are required to maintain the confidentiality of personal information at all times and failing to do so will result in disciplinary actions that may ultimately include dismissal.

Outside service providers may, in the course of performing services, require access to personal information. These service providers may include, but are not limited to, banks and credit reporting agencies. When we communicate with these suppliers, they are given only the information necessary to perform those services.


How Do We Protect Your Personal Information?
We understand the importance of protecting personal information. For that reason, paper information and electronic data back-ups are retained either under supervision or secured in a locked or restricted area at all times. In addition, passwords are used on computers. We use reputable companies (primarily Canada Post) to transmit personal information in paper format through sealed, addressed envelopes or boxes.


How Long Do We Retain Personal Information?
Your personal information is retained only as long as we need it to effectively provide services to you, or the condominium corporations we manage, and for a reasonable length of time thereafter to meet any potential obligations or legal or government requirements. We destroy paper files containing personal information by shredding. We destroy electronic information by deleting it and, when the hardware is discarded, we ensure that the hard drive or other memory devices are physically destroyed (for computers, laptops, cameras, “smart phones,” photocopiers, scanners and all other electronic devices with storage capabilities).


Accessing Personal Information?
You have the right to access, verify and amend your personal information, except in limited circumstances which may include:
• The information is protected by solicitor-client privilege;
• The information is part of an in-process police or insurance claim investigation;
• The information forms part of a pending legal action in Court, Tribunal, or similar legal government or governmental entity;
• The information was collected for purposes related to the detection and prevention of fraud;
• The information was generated in the course of a formal dispute resolution process;
• The information would likely reveal personal information about another individual.

Should you wish access to your personal information, we would ask that you make your request in writing to Olaya's Privacy Officer, stating specifically which information you are requesting. We will try to respond to your request as soon as possible. We may charge you a reasonable fee (or as permitted by statute) for administering your request, but only after first advising you of the approximate cost. Every effort will be made to respond to your request in a timely manner.


Olaya protects all of the personal information we hold from misuse and loss and from unauthorized access, modification or disclosure. This protection applies in relation to information stored in both electronic and hard copy form. Access to electronic information held by Olaya is password-protected, which are changed on a regular basis as standard procedure.


Back-ups are made daily, weekly and monthly. Daily Back-ups are kept for 1 month, Weekly Back-ups are kept for 3 months and Monthly Back-ups are kept for 7 years. All Back-ups are stored in the main server which is password-protected and in an encrypted external drive that is also password-protected, plus it uses 256-bit encryption provided by TRUECRYPT (for more information on this type of encryption, please visit www.truecrypt.org).

The Olaya Privacy Policy may change from time to time.


How to Contact Our Privacy Officer?
For more information, to make enquiries or to file a privacy-related complaint, please contact:

Olaya Management and Accounting Inc.
30 Coronado Crt.
Toronto, ON
M9M 1S7

TEL: (647) 928-7473
FAX: (888) 877-3988

For more general inquiries, the Information and Privacy Commissioner of Canada oversees the administration of privacy legislation in the private sector. The Commissioner also acts as a kind of ombudsman for privacy disputes.


For More Information…
To report privacy breach incidents you can either call the Office of the Privacy Commissioner of Canada’s General Inquiries line at 1-800-282-1376, or by writing to the main address noted below. If you would like to submit a privacy concern, please do not use email.


You may contact the Office of the Privacy Commissioner of Canada, as follows:
• (613) 947-1698
• (613) 994-6850 FAX
• (613) 992.9190 TTY
• Notification Officer:
Office of the Privacy Commissioner of Canada
112 Kent Street
Place de Ville
Tower B, 3rd Floor
Ottawa, Ontario
K1A 1H3

Note: Hours of service are Monday to Friday from 8:30 a.m. to 4:30 p.m. (excluding statutory holidays).


Office of the Privacy Commissioner of Canada web site at www.priv.gc.ca;
PIPEDA: A Guide for Business and Organizations (published by the Office of the Privacy Commissioner of Canada, February 2010, ISBN: 0-662-68004-9);
Treasury Board of Canada Secretariat web site at www.tbs-sct.gc.ca.