ENFHS/SPAHS Applicant / Tenant Privacy Policy

Purpose and Scope:

Entre Nous Femmes Housing Society (ENF) & SPAHS (1997) Ltd. respect and uphold an individual’s right to privacy and to protection of his/her personal information.  ENF/SPAHS is committed to ensuring compliance with applicable privacy legislation.  
This document sets out the policy of ENF/SPAHS with respect tothe protection of the personal privacy of our applicants/tenants.

Definitions

“Personal information” for the purposes of this policy means information about an individual.  It does not include aggregate information, which cannot be associated with a specific individual, and it does not include the name, title, business address, business e-mail address, or business telephone number of an individual. 
“Third party” for the purposes of this policy is an individual or an organization other than ENF/SPAHS and the applicant/tenant.

Our Responsibilities:

1. Accountability

ENF/SPAHS are accountable for the personal information in their possession or control, including information that has been transferred to a third party for processing.  ENF/SPAHS have appointed a Privacy Officer who is responsible for the organization’s compliance with this Policy.
All staff are obligated to protect the personal privacy of applicants /tenants with regard to all personal information collected by ENF/SPAHS.  Staff is required to follow the procedures of this Policy regarding the management of personal information.
Staff will be adequately trained and provided with information about the privacy laws applying to the organization.

2.  Purposes for Collection, Use & Disclosure

ENF/SPAHS collects and uses personal information about applicants and/or tenants for the following purposes:

  • to assess the need for housing;
  • to determine eligibility for housing provided by our organization;
  • to assess any special needs an applicant may have with respect to housing, such as a need for accommodation of certain disabilities, and to determine our ability to accommodate these special needs;
  • to determine eligibility for a housing subsidy;
  • to assist applicants in filling out a rental, or a subsidy application, if assistance is required;
  • to verify information provided in the rental application or the subsidy application (for example, calling the FAW to confirm income);
  • to process payments for services provided, such as rental payments;
  • to enable us to collect payments owing to us which are overdue;
  • to enable us to communicate with applicants/tenants; and
  • to enable us to protect the safety and security of the rental accommodation for our tenants [and staff ].
  • to enable us to provide statistical information for funding purposes

ENF/SPAHS will not collect, use or disclose information beyond that required to fulfill the specified purposes.
When personal information that has been collected is to be used for a purpose not previously identified, the new purpose will be identified prior to use. 

3. Consent

Unless we hear otherwise from you, your use of ENF ‘s/SPAHS' services and facilities constitutes consent for us to collect, use, and disclose personal information for the purposes stated in this Policy.
You may refuse or withdraw consent at any time, subject to legal and contractual restrictions and reasonable notice.  Refusal or withdrawal of consent may prevent us from providing to you a service or access to our facilities. 
You may refuse or withdraw your consent by contacting us at (604) 451-4412 .  Our staff will explain your options and any consequences of refusing or withdrawing consent, and will record your choices.

4. Disclosure of Information to Third Parties

The only circumstances under which personal information may be disclosed to third parties is for the fulfillment of any purposes identified above, with express consent, or as required by law.  If personal information is disclosed to third parties for the fulfillment of any purposes identified above, ENF/SPAHS will ensure that appropriate security undertakings, such as confidentiality clauses in contractual agreements, are employed to protect the transfer and use of personal information.  ENF/SPAHS do not sell, trade, or rent information to third parties.

5. Limiting Collection

We collect personal information only for the purposes identified above.

6. Limiting Use, Disclosure, and Retention

We do not use or disclose personal information for any purpose other than those for which it was collected, except as required by law, or with consent.
Personal information is retained only as long as is necessary for the fulfillment of the purposes for which it was collected, or as required by law.

7. Accuracy

ENF/SPAHS will make all reasonable efforts to ensure that personal information is as accurate, complete, and current as required for the purposes for which it was collected.  ENF/SPAHS rely on applicants/tenants to ensure that certain information about them, such as their emergency contact and reference information, income and family composition, is current, complete, and accurate.
ENF/SPAHS will not routinely update personal information, unless such a process is necessary to fulfill the purposes for which the information was collected.

8. Safeguards

ENF/SPAHS uses security safeguards to protect personal information.  These safeguards are appropriate to the sensitivity of the information. 
ENF/SPAHS will make all reasonable efforts to protect personal information against loss or theft, as well as unauthorized access, disclosure, copying, use, or modification.
The security safeguards include:

  • Physical measures (ie.: off-site back ups; locked offices and/or filing cabinets; alarmed offices)
  • Administrative measures (ie. filing of all application forms; timely destruction of old files; protection of files in use from access by unauthorized persons; Records Management & Retention Policy which states how and when records are to be destroyed)
  • Technological measures (ie. the use of passwords; the implementation of firewalls for all computers accessing the Internet)

9. Individual Access

Individuals have the right to access their personal information under the control of ENF/SPAHS.  The Privacy Officer will assist them with their access requests.  Access requests will be dealt with within 30 days.
Access requests should be made, in writing, to the Privacy Officer at #21, 3550 S.E. Marine Drive, Vancouver, B.C.  V5S 4R3.   In certain exceptional situations, further to privacy legislation, we may not be able to provide access to certain personal information that we hold about applicants/tenants.  Examples of where we may not provide access include, but are not limited to, the following:

  • where provision may reveal personal information about another individual;
  • where the information is subject to solicitor-client privilege;
  • where the information was collected in relation to the investigation of a breach of an agreement or a contravention of a federal or provincial law; or
  • where provision could reasonably be expected to threaten the health or safety of an individual.

If access cannot be provided, ENF/SPAHS will notify the individual making the request, in writing, of the reasons for the refusal.

10. Openess Concerning Policies and Practices

ENF/SPAHS will make available specific information about its policies and practices regarding the management of personal information. To contact us to obtain further information regarding our policies and practices, please refer to section 12 below.

11. Revisions To This Privacy Policy

The development of ENF’s/SPAHS' policies and procedures for the protection of personal information is an ongoing process.  Due to changes in technology and legal requirements we may revise this Policy from time to time.  Please ensure that you refer to the current version of ENF‘s/SPAHS' Privacy Policy. The current version will be updated in the Tenant Handbook which is always available from the Property Managers or from the head office of the Society.

12. Concerns or Questions Regarding Compliance

An individual may address a concern or question about compliance with this policy to ENF‘s Privacy Officer, at #21, 3550 S.E. Marine Drive, Vancouver, B.C. V5S 4R3.   
ENF/SPAHS will investigate any complaints received in writing. If a complaint is found to be justified, ENF/SPAHS will take appropriate measures to resolve the complaint including, if necessary, amending its policies and procedures.  An individual will be informed, in writing, of the outcomes of the investigation regarding his or her compliant.

Dated at Vancouver, this 1st day of January, 2004 (Updated July, 2008)