Privacy Policy
Privacy Policy
What does this Privacy Policy encompass?
Homestead Land Holdings Limited ("Homestead") is committed to protecting Personal Information in its possession.
Homestead is also committed to providing an environment free of discrimination and harassment, in which all individuals are treated with respect and dignity.
This Privacy Policy (the “Policy”), any applicable terms of your agreements with us, and the privacy notices we give you where appropriate describe our privacy practices. This Policy explains how Homestead collects, uses, and discloses Personal Information while doing business in Canada. It further explains our responsibilities regarding handling and protecting Personal Information and informs you about your privacy rights and choices under applicable law.
We encourage you to periodically review this Policy and our other privacy-related documents, as we may update them from time to time.
What is Personal Information?
Personal Information is information about an identifiable or identified individual, such as gender, age, income, date of birth, driver’s license number, current and previous home address, email address, phone number, family status, credit score, names of former landlords, social insurance number, income, the name of your employer and other employment details, names of family members and monthly rent.
How to read this Policy?
This Policy is organized based on the principles listed in the Canadian Standards Association’s Model Code found in Schedule 1 to PIPEDA, under which the Homestead’s privacy responsibilities are defined.
• Accountability
• Identifying Purposes
• Consent
• Limiting Collection
• Limiting Use, Disclosure, and Retention
• Accuracy
• Safeguards
• Openness
• Individual Access
• Challenging Compliance
This Policy also applies to all individuals whose Personal Information is collected by Homestead including, without limitation, applicants for residency and tenants, or users of Homestead’s websites and platforms.
For clarity, this Policy does not apply to information that is not Personal Information.
This Policy should be read and understood in conjunction with Homestead’s Human Right Policies available on our website.
Accountability
The responsibility for the Personal Information under Homestead's control rests with its Privacy Officer. The individual designated as Privacy Officer may change from time to time, and their contact details will be updated in this policy when required.
Protecting your privacy is a top priority of Homestead. Accordingly, we have developed and are continuously reviewing procedures to give effect to this Policy. This includes Homestead's employees receiving training concerning this Policy and the procedures in place to implement it.
Homestead may transfer your Personal Information outside of Canada. While this information is outside of the country, Homestead is committed to ensuring an adequate level of protection as if it were in Canada. However, it is subject to the laws of the country in which it is held. As such, it may, without limitation, be accessible to law enforcement and national security authorities of that jurisdiction or subject to other legally required disclosure.
Identifying Purposes
Leasing and Business Operations
Personal Information is collected in order for Homestead to operate its business as a rental housing provider. This includes activities indicated in the lease agreement, other activities incidental to tenancy in the building (e.g., responding to tenant inquiries, bringing or defending Landlord and Tenant Board claims, collecting rent or other amounts due, or informing tenants about various building rules and policies, collaborating with third-party providers and contractors, etc.) and activities common to the running of all businesses such as collecting and retaining records for income tax purposes or providing receipts. Personal Information is also collected for the purposes of enforcing any terms of the Tenancy Agreement or Tenancy Application or to act in respect of an emergency that threatens the life, health or security of the tenant.
Business Operations also include the electronic interaction and communication with you using digital channels such as our website, applicant portal, resident portal, career portal, or social media platforms.
Management Company
Homestead may use a management company to operate its leasing business. The management company may differ depending on the building, and it may change from time to time. When a management company is used for a building, the Personal Information of tenants in and applicants for tenancy in the building will be exchanged between the management company and Homestead and may be collected, used and disclosed by either the management company and/or Homestead for any appropriate purposes.
Co-ownership
Homestead may own one or more buildings in a co-tenancy with one or more co-owners. The Co-owner may differ depending on the building, and it may change from time to time. When a building is owned in a co-tenancy, the Personal Information of tenants in and applicants for tenancy in the building will be exchanged between the co-owner or co-owners and Homestead and may be collected, used and disclosed by either the co-owner(s) and/or Homestead for any appropriate purposes.
Business Transactions including Selling or Financing a Building
When Homestead enters into business transactions including, without limitation, for the purpose of selling a building, or financing it, the Personal Information of the tenants of the building will be disclosed to parties involved in the transaction including the potential buyer or financer. The rent roll contains Personal Information including the location and size of leased premises, the amount of rent paid, if there are rental arrears or ever have been, and other similar information. The rent roll is used to calculate the value of a building. Disclosure of it to an involved party including buyers or financers is essential to assess the risk involved in buying or financing the building and adequate privacy and data protection safeguards are followed.
Secondary Marketing Purposes
Homestead will disclose limited Personal Information to third party suppliers of services, such as telecommunications and utility service providers, so that they can market and make available their services to new and existing tenants. Homestead may also disclose Personal Information to insurers. A complete list of persons or business entities to whom your Personal Information may be provided and who may, in turn, send Commercial Electronic Messages (CEMs) to you can be requested from the Privacy Officer.
Credit Bureaus
Personal Information is collected for the purpose of conducting a credit check with credit bureaus on applicants for tenancy. The credit check is a risk assessment tool used to ensure that you will be able to make the monthly payments required to lease the premises. Homestead may also do this to verify your identity and to protect us against fraud. Consent to collect Personal Information for the purpose of conducting a credit check will be requested on the application for accommodation or offer to lease the premises. Your refusal to provide information and consent to its use and disclosure for the purposes of conducting a credit check is grounds for the Homestead to refuse rental accommodation. Homestead may also obtain a credit check in the event that the tenant is in arrears of rent or wishes to renew his/her tenancy agreement. This is common practice for rental housing providers.
References
Your Personal Information may be used to provide credit or rental-history references to third parties. Further, your Personal Information is collected in order for Homestead to conduct a reference check during the application process. The reference check will include references concerning rental payments, cleanliness, noise violations and complaint history (the "Factors"). The reference check is an assessment tool used to determine your suitability to be a tenant of Homestead based on the Factors. Your refusal to provide reference names and telephone numbers and consent to their use and disclosure for the purposes of conducting a reference check is grounds for Homestead to refuse rental accommodation.
Identification
Personal Information is collected for the purposes of identification when the need arises.
Assessments
Your Personal Information may be wholly or in part disclosed to federal, provincial, or municipal government, any of the specified entities in applicable law and supporting regulations, or any third-party that supports Homestead with the assessments, for the purpose of assessing the value for taxation. This includes the Assessment Act (Ontario) and the Municipal Government Act (Alberta) and disclosure to the respective body in each province responsible for assessments
Use of Video Surveillance and Recordings
Video equipment may be installed and operating in common areas of the complex in which your rental unit is located. The video equipment may be operating at all times. Surveillance of the video recordings may occur at any time.
Your Personal Information that might be captured includes, without limitation, your image, movements and movement patterns, actions, or other identified or identifiable information about you.
The use of this equipment is to assist in ensuring your safety, security and reasonable enjoyment and that of the other residents, to ensure you have access to the premises, , to preserve Homestead property, and to deter crime.
Where required by law, signs will be posted informing you that video equipment is operating and recording Personal Information about you.
• Retention and Destruction of Personal Information Recorded by Video Equipment
The recordings captured by the video equipment along with the video equipment will be stored in a secured location. Access to the location and recordings is limited. Hardware is either under supervision or secured in a locked or restricted area. Recordings are kept for up to 60 days before being destroyed unless permitted or required to be kept by applicable law (e.g., as evidence for investigative purposes).
• Disclosure of Personal Information Recorded by Video Equipment or Voice Mail
We may disclose your Personal Information without your knowledge or consent under certain circumstances. Those circumstances include: if the disclosure is required by law, provided to our lawyers, for the purpose of collecting a debt you owe to us, in compliance with a subpoena, warrant, or issued order made by a court, person or body with jurisdiction to compel the production of information, or to comply with rules of court relating to the production of records.
Disclosure may also be made to a government institution that has made a request for the information, identified its lawful authority to obtain the information and indicated that: it suspects that the information relates to national security, the defense of Canada or the conduct of international affairs, the disclosure is requested for the purpose of carrying out any investigation relating to the enforcement, gathering intelligence for the purpose of enforcing, or enforcing any law of any jurisdiction, or the disclosure is requested for the purpose of administering any law of Canada or a province. Disclosure may be made by an investigative body if the disclosure is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province.
Upon our initiative, we may disclose the information to an investigative body or a government institution if we have reasonable grounds to believe that the information relates to a breach of an agreement or a contravention of the laws of any jurisdiction that has been, is being or is about to be committed, or if we suspect that the information relates to national security, the defence of Canada or the conduct of international affairs.
If information regarding an identifiable individual is disclosed to a person who needs the information because of an emergency that threatens the life, health or security of an individual and, if the individual whom the information is about is alive, we will inform that individual in writing of the disclosure without delay.
• Use Without Knowledge or Consent of Personal Information Recorded by Video Equipment
We may, without your knowledge or consent, use your Personal Information if: we become aware of information that we have reasonable grounds to believe could be useful in the investigation of a contravention of the laws of any jurisdiction that has been, is being, or is about to be committed, and the information is used for the purpose of investigating the contravention, it is used for the purpose of acting in respect of an emergency that threatens the life, health, or security of an individual, or has been collected under circumstances in which consent is not required.
Co-Tenant's Access Requests
Your Personal Information may be wholly or in part disclosed to a tenant with whom you have co-signed your lease if a request is made by that tenant to access his or her Personal Information. The disclosure will be assessed on a case-by-case basis.
Consent
Consent is generally required for the collection, use, and disclosure of Personal Information. This includes the above purposes, or any new purposes that Homestead identifies, except where inappropriate, where permitted by applicable law, where required by applicable law, or where Homestead relies on an applicable exception (e.g., Homestead may disclose Personal Information to a collecting agency for the purpose of collecting any rent that is owed by the tenant).
The form of consent required by Homestead varies depending on the sensitivity of the information requested and the reasonable expectations of the tenant. Consent shall be implied for all purposes unless the purpose indicates that express consent will be collected.
Limiting Collection
Homestead does not collect Personal Information indefinitely. Homestead limits the collection of Personal Information to that which is necessary for purposes it identifies.
Homestead primarily collects Personal Information directly from you; however, Personal Information may also be collected from other sources including credit bureaus, employers, previous landlords, referees, other tenants or other people who represent that they have the right to disclose information.
The Personal Information that Homestead collects directly from you; may be disclosed by you to Homestead, generated by your transactions with Homestead, or from Homestead's observations.
The types of Personal Information collected include:
(i) Personal Information related to facilitating the tenancy including your name, proposed occupants, address, email address, amount of rent paid, payment history, complaints, requests, etc.;
(ii) Personal Information necessary to have a credit check conducted on you, including your social insurance number;
(iii) Personal Information necessary to evaluate potential tenancy such as current and past employment information, banking information and references from prior Homesteads; and
(iv) Personal Information necessary to identify you as well as telephone numbers, persons to contact in case of emergency, vehicle information, posted information and email addresses.
Limiting Use, Disclosure and Retention
Homestead only uses and discloses Personal Information for the purposes for which, it was collected, or otherwise in accordance with applicable laws. Any new purpose for which the information is to be used or disclosed shall be documented, and consent will be obtained for it if and to the extent required.
Depending on the circumstances, Homestead will occasionally disclose Personal Information under its control to third parties, but only for an identified purpose. When disclosing Personal Information, Homestead uses contractual means to ensure that it is treated in accordance with applicable law by the third party. Please find listed below third parties that Personal Information would be disclosed to:
- Government Organizations (Municipal/Provincial/Federal)
- Collection Agencies
- Telecommunication Providers
- Auditors/Accountants
- Canada Life
- Financial Institutions
- Insurance Providers
- Authorized legal representatives
- Real Estate Agents
- Appraisers
- Contractors and Consultants
- Utility Providers
- Technology and Service Providers (such as UKG, Yardi, DocuSign)
Unless indicated otherwise, Homestead retains Personal Information for as long as necessary for the identified purpose or required by applicable law, such as statutory retention for a period of seven years. Personal Information will be disposed of by appropriate means, such as purging, shredding, or otherwise destroying it. Third party services may be retained to destroy Personal Information; however, that third party will be required to enter into an agreement with Homestead in order to protect the Personal Information.
Accuracy
Personal Information will be kept as accurate, complete and up to date as necessary for the purposes for which it is to be used. You are responsible for informing Homestead about changes to your Personal Information as appropriate. Homestead encourages you to examine your lease agreement, application for lease and any other documents that you submit to Homestead that contain the Personal Information in order to ensure that the information is accurate. If you have concerns about the accuracy of your Personal Information collected by Homestead, contact Homestead at the relevant phone number or address indicated at the end of this document.
Safeguards
Homestead protects Personal Information against loss or theft; as well as unauthorized access, disclosure, copying use or modification; with technical, organizational, and administrative safeguards appropriate to the sensitivity of the Personal Information. Physical files are protected by keeping them in areas restricted to employees, and/or in locked filing cabinets or rooms. Homestead's employees have been made aware of the need to safeguard Personal Information and they only access Personal Information on an as-needed basis.
Openness
Homestead's policies and practices related to the management of Personal Information are contained in this Policy. The Policy as well as additional information and documents are available from the Privacy Officer on request or online at www.homestead.ca They include:
- A Personal Information Request Form to be used to inquire about or gain access to Personal Information held by Homestead; and
- A Privacy Complaint Form used to complain about Homestead's treatment of Personal Information.
Both forms can be found at the bottom of this web page.
Individual Access
Upon written request, Homestead will divulge the existence, use and any disclosure made of Personal Information and will give you access to your Personal Information. Written requests should be delivered to the Branch Offices or the Privacy Officer at the address at the end of this Policy. Personal Information Request Forms and Privacy Complaint Forms are referenced above as well as available at the Homestead's Branch Offices and online at www.homestead.ca. If assistance is needed with the request, please contact the Privacy Officer. Specifically, if you have a sensory disability, please contact the Privacy Officer to agree on an alternative suitable format for our response.
Homestead will respond to an access request within thirty (30) days, unless an extension of time is required, in which case the response may take up to an additional thirty (30) days. A fee for reasonable costs incurred pursuant to the request may be charged to the requestor by Homestead, provided that you are informed of the fee in advance and do not withdraw your request.
Homestead may occasionally require additional information from you in order to verify your identity, answer your request appropriately, or locate certain Personal Information. If this is the case, the additional information will not be used for any purpose other than responding to your request.
Should your Personal Information on file with Homestead prove to be incomplete or incorrect, it will be amended as required. Where necessary, the amended information will be transmitted to third parties using the information in question.
There may be limits to your right to access your Personal Information. For example, if the Personal Information is subject to legal privilege, contains confidential commercial information, relates to an investigation of a breach of an agreement or law, or contains information about other individuals that cannot be separated except for as described for the purpose of co-tenant access requests. If Homestead does wholly or in part refuse to respond to an access request, it will inform you of the reasons for such refusal.
Challenging Compliance
Any concerns respecting Homestead's compliance with applicable privacy laws should be addressed to the Privacy Officer. A Privacy Complaint Form or Personal Information Request Form is referenced above as well as available from our Branch offices or at www.homestead.ca for making complaints. Homestead will investigate and respond to written complaints within thirty (30) business days of receiving a complaint. If a complaint is found to be justified Homestead will take appropriate measures, including, if necessary, amending its policies and procedures.
Privacy Officer
Mitch Noonan, Vice President - Human Resources
80 Johnson Street
Kingston, Ontario, K7L 1X7
(Telephone): (613) 546-3146
Homestead Branch Offices
Homestead Land Holdings Limited (Head Office)
80 Johnson Street
Kingston, Ontario, K7L 1X7
Phone (613) 546-3146 Fax (613) 546-5206
Homestead Land Holdings Limited
2001 Carling Avenue
Ottawa, Ontario, K2A 3W5
Phone (613) 729-4115
Homestead Land Holdings Limited
1000 Mount Pleasant Road, Suite 100
Toronto, Ontario, M4P 2M2
Phone (416) 322-0265
Homestead Land Holdings Limited (Hamilton/Guelph/Burlington/Oakville/Mississauga/Etobicoke/St. Catharines)
5555 North Service Road, Suite 200
Burlington, Ontario, L7L 5H7
Phone (905) 335-8700
Homestead Land Holdings Limited
(London/Kitchener/Brantford/Sarnia/Cambridge/Waterloo)
Executive Centre
1950 Oxford Street East, Suite 2
London, Ontario, N5V 2Z8
Phone (519) 433-1560
For more general inquiries, the Information and Privacy Commissioner of Canada oversees the administration of the privacy legislation in the private sector. The Commissioner also acts as a kind of ombudsman for privacy disputes. The Information and Privacy Commissioner can be reached at:
30, Victoria Street
Gatineau, Quebec
K1A 1H3
Toll-Free: 1-800-282-1376
Phone: (819) 994-5444
TTY: (819) 994-6591
Homestead ("us", "we" or "our") operates this website. By using the website, you agree to the collection and use of information in accordance with this policy.
Information Collection & Use
While using our website, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you. Personally identifiable information may include, but is not limited to your name and email address ("Personal Information").
Log Data
Like many website operators, we collect information that your browser sends whenever you visit our site ("Log Data"). This Log Data may include information such as your computer's Internet Protocol ("IP") address, browser type, browser version, the pages of our website that you visit, the time and date of your visit, the time spent on those pages and other statistics. In addition, we may use third party services such as Google Analytics that collect, monitor and analyze the above.
Communications
We may use your Personal Information to contact you with newsletters, marketing or promotional materials and other information that would be applicable to our business and/or services.
Cookies
Cookies are files with small amounts of data, which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your computer's hard drive. Like many websites, we use "cookies" to collect information. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our website.
Changes to this Privacy Policy
This Privacy Policy is effective as of the last updated date and will remain in effect except with respect to any changes in its provisions in the future, which will be in effect immediately after being posted on this page. We reserve the right to update or change our Privacy Policy at any time and you should check this Privacy Policy periodically. Your continued use of the service after we post any modifications to the Privacy Policy on this page, will constitute your acknowledgement of the modifications and your consent to abide and be bound by the modified Privacy Policy.
Forms
