Principle 11 - Accountability
Brookfield will seek to include in contractual arrangements with suppliers provisions requiring them to provide an appropriate level of protection for information transferred to them by Brookfield.
Brookfield will seek to include in contractual
arrangements with suppliers provisions requiring them to provide an appropriate
level of protection for information transferred to them by Brookfield.
Principle 2 — Identifying Purposes
Brookfield will identify the purposes for which it is collecting any personal information by such means as is appropriate in the circumstances. This may include providing disclosure orally, by telephone, or in person, providing disclosure in a contract or in other written information given to an Individual, posting a notice on Brookfield’s website or any other means deemed appropriate in the circumstances.
In some instances, where the purpose for collecting information is reasonably evident to the person providing the information, the purpose will be implied but not explicitly stated (for instance, on rental applications, when a potential tenant provides us with his or her income and banking information or on Pre-Authorized Payment applications when a unit owner authorizes the condominium corporation to withdraw monthly common charges from an Individual’s bank account).
Principle 3 — Consent
Brookfield will seek to obtain consent from an Individual before or when it collects, uses or discloses personal information except as described below. Brookfield will strive to ensure that Individuals understand how their personal information will be used or disclosed.
Consent can be expressed (i.e. given orally, electronically or in writing), implied or given through an authorized representative. Consent may be implicit when the purposes are not stated expressly but are implied by the circumstances of the transaction or follow logically from other expressly stated purposes). You can withdraw consent at any time, with certain exceptions (for example, subject to any legal or contractual restrictions) and upon reasonable notice to Brookfield. Brookfield will strive to inform an Individual of all implications of withdrawing his or her consent. You may contact Brookfield’s Privacy Officer respecting the withdrawal of any previously given consent or any change in the purposes for which information held by Brookfield may be used, disclosed or retained. Note that information may be retained by Brookfield for audit or archival purposes notwithstanding any withdrawal of consent otherwise applicable but the fact that consent has been withdrawn will be noted so as to prevent an unauthorized use.
Brookfield, however, may collect, use or disclose personal information without the an Individual’s knowledge or consent in exceptional circumstances where such collection, use or disclosure is permitted or required by law.
Principle 4 — Limiting Collection
Brookfield will only collect information that is
reasonably necessary for the purposes identified. Information will be collected
by fair and lawful means.
Principle 5 — Limiting Use, Disclosure and Retention
Personal information will only be used or disclosed for the purpose for which it was collected unless an Individual has otherwise consented, or when it is required or permitted by law. Personal information may only be retained for the amount of time needed to fulfill the purpose for which it was collected. In certain exceptional circumstances, Brookfield may have a legal duty or right to disclose personal information without an Individual’s knowledge or consent with respect to matters that concern the public’s interest.
Principle 6 — Accuracy
Brookfield will keep personal information as accurate, complete and current as necessary to fulfill the identified purposes for which it was collected. Brookfield will update or correct any personal information held by it if the individual concerned provides Brookfield with particulars, satisfactory to it, of any required updating or correction.
Principle 7 — Safeguarding Personal Information
Personal information is safeguarded to protect against loss, theft or unauthorized access, disclosure, use or modification of information using measures appropriate to the sensitivity, amount, format, nature and storage of the information and will involve, as applicable, physical, organizational and electronic security measures.
Brookfield has controls in place to maintain the security of its information and information systems. Files are stored according to the sensitivity of the information contained therein. Appropriate controls (such as restricted access) using user I.D.’s and passwords are placed on our computer systems and data processing procedures. Physical access to areas where personal information is gathered, processed or stored is limited to authorized employees.
Brookfield has controls in place to maintain the
security of its information and information systems. Files are stored according
to the sensitivity of the information contained therein. Appropriate controls
(such as restricted access) using user I.D.’s and passwords are placed on our
computer systems and data processing procedures. Physical access to areas where
personal information is gathered, processed or stored is limited to authorized
Principle 8 — Openness
Brookfield will make information available to
Individuals and its Clients and others about the policies and procedures
Brookfield uses to manage personal information. Individuals and Clients have
access to much of this information through our web site, or through written
correspondence with Brookfield’s Privacy Officer.
Principle 9 — Individual Access
As an Individual, you have the right to access the
personal information we keep in your file and you have the right to verify or
amend the information if it is shown to be inaccurate.
If you would like to view the personal information
held in your file, please make a written request to Brookfield’s Privacy
Officer. Brookfield will respond to your request as efficiently as possible and
will advise of the individual cost, if any, prior to the retrieval of such
records. Brookfield will not respond to frivolous or vexatious requests for
access to information. If Brookfield is prohibited from providing such access it
will explain the reasons, except where prohibited by law. To make a change to
your personal information (as discussed under “Accuracy” above), please make a
similar request in writing to the Privacy Officer.
Principle 10 — Questions or Concerns
Brookfield has policies and procedures to receive,
investigate and respond to any questions or concerns respecting this Privacy
Policy or the personal information that we hold. Individuals may contact the
Brookfield’s Privacy Officer with any questions or concerns or to request access
to their personal information. Specific Information about our Use and Disclosure
of Your Personal Information:
The Kind of Information We Collect:
Brookfield gathers and uses personal information as
described below. Providing us with your personal information is your choice;
however, we may not be able to provide you with certain products or services if
you do not provide us with certain information nor will we be able to fulfill
contractual obligations to third parties. For example, we may not be able to
contact you in an emergency at your place of residence if we do not have your
contact information away from your residence or if you withdraw your consent to
disclose your contact information to our Clients or their employees or
contractors who provide some of the products or services you have requested.
The nature of our relationship with you will determine
the kind of personal information we might ask for.
Information that is typically required to provide you
and the Clients we service with our products and services includes, but is not
CONDOMINIUM UNIT OWNERS
Name of Mortgagee on the unit
Bank Account Number
Residing with you
Address of Seasonal Property
Other Phone Number
Name of Emergency Contact and Contact Information
Including License Plate Number
Any Special Needs of Owners
Bank Account Number
Co-occupant Information (name,
date of birth, relationship to prospective tenant)
Including License Plate Number
Intended Use of Premises
Needs of Tenants
In addition, information other than as set out in the
definition of personal information (above), may also be collected from time to
SPECIAL NOTE FOR TENANTS OR PROSPECTIVE TENANTS ONLY
Brookfield subscribes to a consumer reporting service.
This service provides information to Brookfield about prospective tenants. In
return, on behalf of our Clients, we provide information to the service for the
purpose of assessing your credit worthiness and checking references. We obtain
your consent for using the consumer reporting service in the rental application
form. If you have an existing tenancy agreement with us and you wish to renew
the agreement, it is assumed that the consent you gave to us when signing the
tenancy agreement remains in effect. If you sign an application to rent for your
family or anyone else, you are representing that you have obtained their consent
for the collection , use and disclosure of their personal information for the
purposes set out in this Policy.
When Do We Disclose or Share Your Personal
(i) When Authorized By You
Many of the services offered by Brookfield and/or its
Clients require us to obtain personal information about you in order to perform
the services we have been engaged by you to provide. We will use and disclose
this information to provide programs to meet your needs and objectives.
ii) To Brookfield’s Clients, their Employees and
We act as agents for our condominium corporations and
landlords. Thus, we may periodically share or transfer any personal information
we collect relevant to a particular Individual with that Client or with that
Client’s employees, third party suppliers or contractors. Out Clients use a
number of employees, third party service providers, consultants and other agents
that may in the course of their duties have limited access to personal
information we retain. These include building superintendents, maintenance
staff, recreation centre attendants, concierge, security staff, housekeeping
staff, consultants, temporary employees or employees of third party suppliers,
auditors, lawyers and others. We restrict their access to any personal
information we hold except to the extent necessary for them to reasonably
perform their role on behalf of our Client. The purpose of disclosing personal
information to our Clients or their agents and employees is to ensure an
Individual’s safety, security and reasonable enjoyment of their place of
residence, to ensure Individuals have access to their premises and services that
our Clients have agreed to provide, to preserve our Client’s property and to
collect monies owing to those Clients for the provision of services to
Individuals. Suppliers and Client employees are contractually bound to protect
the confidentiality of your personal information, and they are prohibited from
doing anything with this information that we have not authorized them to do.
They are required to treat your personal information in a manner consistent with
Suppliers and Client employees are contractually bound
to protect the confidentiality of your personal information, and they are
prohibited from doing anything with this information that we have not authorized
them to do. They are required to treat your personal information in a manner
(iii) When Required or Permitted By Law
The type of information we are legally required to
disclose usually relates to government tax reporting requirements. However in
some cases, such as under a court order, we may be required to disclose certain
information to persons specified in the court order. We will only provide the
specific information requested and only upon being satisfied that the
authorities have legitimate grounds to obtain the information. Brookfield may
also disclose information without your consent when permitted by law including
in situations involving medical emergencies, collection of a debt and suspicion
of illegal activities.
Web Site (Security)
In order to serve you better, Brookfield Clients have
access to certain information through its web site www.brookfieldresidential.com
which provides general information about the Company and the products and
services it offers.
Brookfield is committed to your privacy and strives to
ensure that any information you access or provide through this site remains
Brookfield may collect anonymous information about
you. This means that the information collected cannot be traced back to a
specific person. For example, our web servers may record certain information
automatically when you visit our web site. This information is collected using
“cookies” and might include the pages you visited, your Internet Protocol
address and other site usage statistics. This anonymous information is used for
research and analytical purposes only (ie. evaluating how many visitors our web
sites receive or which pages they visit most often). It does not reveal any
personal information about you, the user. This aggregate data may be disclosed
to third parties, but never with personally identifying information.
Contact Information (Questions, Concerns and
If you have any questions or concerns about your
contact our Privacy Officer using the contact information below:
Contact Information: Privacy Officer, Brookfield
Homes, 181 Bay Street, Suite 330, P.O. Box 763, Toronto, ON, M5J 2T3; (e-mail)