Ontario Home Builders’ Association Personal Information Protection Policy

Protecting the privacy and confidentiality of personal information is an important aspect of the way that Ontario Home Builders Association (OHBA) conducts its business. Collecting, using, and disclosing personal information in an appropriate, responsible, and ethical manner is also important to Ontario Home Builders Association’s daily operations.

OHBA strives to protect and respect the personal information of its customers, employees, business partners, and others who engage with the association.

OHBA’s collection and use of personal information is governed by the Personal Information Protection and Electronic Documents Act, 2001, c. 5 (the “PIPEDA”), which grants rights concerning the privacy of user’s personal information. This Privacy Policy applies to all personal information within Ontario Home Builders Association’s possession and control.

In compliance with PIPEDA, this Privacy Policy complies with Schedule 1 of PIPEDA, and its 10 principles of fair information practices. The Government of Ontario’s overall Privacy Statement can be found at http://www.ontario.ca/government/privacy-statement.

Definitions

Personal information is defined as any identifying information about an individual or group of individuals.

Contact information refers to information that would enable an individual to be contacted at a place of business, including business address, business telephone number, name(s) of owner(s), executive officer(s), and director(s), job titles, business registration numbers, and financial status. Contact information is treated and handled with the same level of confidentiality, privacy, and respect as personal information.

Privacy Officer is the designated individual responsible for ensuring that OHBA complies with this Privacy Policy and PIPEDA.

PRINCIPLES

OHBA’s Privacy Policy is based upon and applies the 10 principles of PIPEDA:

  1. Accountability

OHBA is responsible for the personal information collected within its control, and has designated Sajida Jiwani as the Privacy Officer, to whom questions about this Privacy Policy can be directed to. The Privacy Officer can be reached at the OHBA office:

Sajida Jiwani, Business Manager
20 Upjohn Road, North York ON M3B 2V9
1-800-387-0109 ext. 222

To fulfil OHBA’s responsibility for personal information under its control, the following policies and practices to have been implemented, including:

a) Implementing procedures to protect personal information, as discussed in section 7 below on “Safeguards”;

b) Developing information to explain the organization’s policies and procedures, as discussed in section 8 below on “Openness”; establishing procedures to receive and respond to complaints and inquiries, as discussed in sections 9 and 10 below on “Individual Access” and “Recourse”; and

c) Training OHBA employees and communicating information about OHBA’s policies and practices to employees.

  1. Identifying the Purpose

OHBA will endeavor to identify the purpose of why personal information is needed and utilized, before or when any personal information is collected.  OHBA will also document the purposes for which personal information is collected.

OHBA collects and uses personal information solely for the purpose of conducting business and developing an understanding of its members and users. OHBA hereby asserts that personal information will only be used for the following purposes:

  1. To carry out transactions, such as event registration, process a magazine subscription
  2. To send information about industry and association news and updates
  3. To provide user feedback and the opportunity to respond to a questions from users

OHBA obtains personal information directly from the individual to whom the information belongs. Individuals are entitled to know how OHBA uses personal information and this organization will limit the use of any personal information collected only to what is needed for those stated purposes.

OHBA does not sell, distribute, or otherwise disclose personal information or contact lists to third parties. However, limited disclosure may be required as part of OHBA fulfilling its stated business duties and day-to-day operations. This may include consultants, suppliers, or business partners of Ontario Home Builders Association, but only with the understanding that these parties obey and abide by the Canadian Anti-Spam Legislation (CASL), to the extent necessary for fulfilling their own business duties and day-to-day operations.

In addition, OHBA may provide links to other websites managed by third parties/may permit third parties to offer users subscriptions/registration-based services through its website. As such, OHBA cannot control or be responsible for the actions or policies of such third parties.

By becoming a member or customer, requesting information, or registering for events or purchasing courses offered, users are giving OHBA permission to contact them at the address, email and/or phone number provided, to the extent permitted by other applicable laws, including CASL. In compliance with CASL, OHBA offers individuals with the option to opt-in, opt-out or modify how they receive various electronic communications, and at any time.

Access to personal information will be authorized only for the employees and other agents of OHBA who require the information to perform their job duties, and to those otherwise authorized by law.

  1. Consent

Consent occurs and is obtained when an individual signs an application or other form containing personal information, thereby authorizing OHBA to collect, use, and disclose the individual’s personal information for the purposes stated on the form or in the Appropriate Use section of this policy. This includes new member registrations, member renewals, course enrolments, awards and events registration.

Consent can be provided orally, in writing, electronically, through an authorized representative or it can be implied where the purpose for collecting using or disclosing the personal information would be considered obvious and the member voluntarily provides personal information for that purpose.

Consent may also be implied where a member is given notice and a reasonable opportunity to opt-out of his or her personal information being used for mail-outs, the marketing of new services or products, and the member does not opt-out.

Consent (also known as “opting out”) can also be withdrawn at any time by contacting OHBA’s Privacy Officer or the individual specifically identified. An individual’s decision to withhold or withdraw their consent to certain uses of personal information may restrict OHBA’s ability to provide a particular service or product.

Exceptions to consent occur when OHBA may collect, use or disclose personal information in the following, limited circumstances:

  • When the collection, use or disclosure of personal information is permitted or required by law;
  • In an emergency that threatens an individual’s life, health, or personal security;
  • When the personal information is available from a public source (e.g., a telephone directory or the Internet);
  • When OHBA requires legal advice from a lawyer;
  • For the purposes of collecting a debt;
  • To protect ourselves from fraud;
  • To investigate an anticipated breach of an agreement or a contravention of law
  1. Limiting Collection

OHBA limits the collection of personal information for the aforementioned purposes and use, and does not collect personal information indiscriminately. Both the amount and the type of information OHBA collects is limited to that which is necessary to fulfil the general purposes.

OHBA monitors website traffic patterns, site usage, and related digital information (social media, email) in order to optimize OHBA’s online services. This information may also be used for statistical analysis and may be provided to third parties, but this does not include any identifiable personal information.

  1. Limiting Use, Disclosure and Retention

OHBA does not use or disclose personal information for purposes other than those for which it was originally collected, except with user consent or as otherwise permitted by law. In addition, OHBA retains personal information only as long as necessary for the fulfilment of those purposes.

OHBA also does not disclose email addresses on published platforms, such as the online member directory or printed member directory. It only discloses the same type of company information that would appear in standard marketing practices.

  1. Accuracy

OHBA strives to keep accurate records of personal information, and asks for and applies updates to information, as users disclose new updates.

  1. Safeguards

OHBA has developed the following safeguards to help ensure compliance to PIPEDA and its policies:

  • Protect personal information against loss or theft by only storing information on a secured server, which is password protected, encrypted, and backed up.
  • Safeguard the information from unauthorized access, disclosure, copying, use or modification, and protect personal information, regardless of the format in which it is held, by training staff to adhere to this Privacy Policy.
  1. Openness

OHBA will inform members, employees, and other users of the policies and practices in place for the responsible management of personal information.

This information will be easy to understand and accessible by including

    • The name and contact information of the Privacy Officer, who is responsible for OHBA’s compliance to this Privacy Policy (see section 1)
    • A description of the purpose for collecting personal information, and its use
    • Personal information that is made available to related organizations
  1. Individual Access

OHBA respects the individual’s right to access their personal information within OHBA’s collection.

Upon receipt of written request, OHBA will provide an account of personal information about the individual and show how it has been used and any other related organizations that have their information. OHBA will grant access to users’ personal information at minimal or no cost to the individual. OHBA will correct or amend any personal information in order to keep records most accurate and up-to-date, and send amended information to any third parties who have access to the information, where appropriate. OHBA will also endeavour to make the information understandable (i.e. explain acronyms and codes).

In certain situations, OHBA may not be able to provide access to all the personal information held about a user. Exceptions may include information that is prohibitively costly to provide, information that contains references to other individuals, information that cannot be disclosed for legal, security or commercial proprietary reasons, and information that is subject to solicitor-client or litigation privilege. The reasons for denying access will be provided to the individual upon request, along with any recourse that you may have under PIPEDA.

  1. Recourse

The Privacy Officer is responsible for OHBA’s compliance to this Privacy Act and PIPEDA.

Members can direct any complaints or concerns concerning OHBA’s compliance to this Privacy Act in writing to the Privacy Officer, as identified in Principle 1. OHBA reserves the right to seek legal advice where appropriate.

The Privacy Officer will investigate all complaints received and take appropriate measures to correct information handling practices and policies. If the Privacy Officer is unable to resolve the concern, members can also write to the Information and Privacy Commissioner of Ontario.

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