Odyssey Homes’ collection, use, and disclosure of your personal information is governed by Canada’s Personal Information Protection and Electronic Documents Act S.C. 2000, c. 5 (“PIPEDA”). Generally, organizations covered by PIPEDA must obtain an individual’s consent when they collect, use, or disclose that individual’s personal information. Personal information can only be used for the purposes for which it was collected. Personal information must be protected by appropriate safeguards and people have the right to access their personal information held by an organization.
The Ten Principles of PIPEDA Summarized
- Accountability: organizations are accountable for the personal information they collect, use, retain and disclose in the course of their commercial activities, including, but not limited to, appointing an individual to be responsible for the organization’s compliance with PIPEDA;
- Identifying Purposes: organizations are to explain the purposes for which the information is being used at the time of collection, and personal information can only be used for those purposes;
- Consent: organizations must obtain an Individual’s express or implied consent when they collect, use, or disclose the individual’s personal information and (subject to legal or contractual restrictions and reasonable notice) individuals can withdraw consent at any time;
- Limiting Collection: the collection of personal information must be limited to only the amount and type that is reasonably necessary for the identified purposes;
- Limiting Use, Disclosure and Retention: personal information must be used for only the identified purposes, and must not be disclosed to third parties unless the Individual consents to the alternative use or disclosure;
- Accuracy: organizations are required to keep personal information in active files accurate and up-to-date, taking into account its use and the interests of the individual;
- Safeguards: organizations are to use physical, organizational, and technological safeguards to protect personal information from unauthorized access or disclosure, in a way that is appropriate to the sensitivity of the information;
- Openness: organizations must inform their clients and train their employees about their privacy policies and procedures, and ensure such policies and procedures are accessible and easy to understand;
- Individual Access: an individual has a right to access his or her personal information held by an organization, and if necessary, to challenge the accuracy of such information; and
- Provide Recourse: organizations are to inform clients and employees of how to bring a request for access, or a complaint, and must respond promptly to a request or complaint by the individual.
Personal information held by Odyssey Homes, including any personal information transferred to a third party, is appropriately protected by ensuring confidentiality measures are in place for any persons with access to personal information.
2. PURPOSES OF COLLECTING PERSONAL INFORMATION
Personal information is collected to develop the advertising and marketing materials on the website and to use to connect parties to each other.
3. CONSENT FOR COLLECTING PERSONAL INFORMATION
- Odyssey Homes will obtain consent before or at the time of collecting personal information;
- At the time consent is sought, the purposes for the collection, use or disclosure of the personal information will be explained to the individual;
- After consent has been obtained to use an individual’s personal information for those purposes, Odyssey Homes has the individual’s implied consent to collect or receive any supplementary information that is necessary to fulfil the same purposes;
- If or when a new purpose is identified for collecting an individual’s personal information, Odyssey Homes will obtain the individual’s express consent for the new purpose(s).
4. LIMITING COLLECTION
5. LIMITING USE, DISCLOSURE AND RETENTION
Limiting Use of Personal Information
Personal Information is only used for the purpose(s) to which the individual has consented; with the following exceptions, as permitted under PIPEDA:
- The organization has reasonable grounds to believe the information could be useful when investigating a contravention of a federal, provincial, or foreign law and the information is used for that investigation;
- The information is for statistical study or research;
- The information is publicly available;
- The use is clearly in the Individual’s interest, and consent is not available in a timely way;
- Knowledge and consent would compromise the availability or accuracy of the information; and,
- Collection is required to investigate a breach of an agreement.
Disclosure of Personal Information
Personal Information will be disclosed to only those representatives of Odyssey Homes that need to know the information for the purposes of their performance of the services provided by Odyssey Homes.
We do not sell, trade, or otherwise transfer to third parties your personally identifiable information, including your banking/credit card information. This does not include trusted third parties who assist in operating our website, conducting our business, or servicing you, so long as those parties agree to keep this information confidential. Non-personally identifiable information may be provided to third parties for marketing, advertising, or other uses. However, personal information may be disclosed to third parties from time to time without an individual’s knowledge and consent when it is permitted by PIPEDA.
Retention of Personal Information
Personal information will be retained as long as the client’s file is active and for such periods of time as may be prescribed by applicable laws and regulations.
Odyssey Homes ensures that personal information retained in an individual’s active file(s) is accurate, current, and complete as is necessary to fulfill the purpose(s) for which the information has been collected, used, retained, and/or disclosed. Individuals are requested to notify Odyssey Homes of any change in personal information.
Odyssey Homes uses the following physical, organizational, and technological measures to safeguard personal information:
Physical Safeguards: Active files are stored in locked filing cabinets and/or offices when unattended by Odyssey Homes. Inactive files or personal information no longer required are shredded prior to disposal to prevent inadvertent disclosure.
Organizational Safeguards: Access to personal information is limited to the representatives of Odyssey Homes.
Technological Safeguards: Personal information contained in Odyssey Homes’ computers and electronic databases are password protected. Access to any of Odyssey Homes’ computers is also password protected.
If at any time Odyssey Homes determines that there has been a loss, or unauthorized access to, use or disclosure of personal information, a representative of Odyssey Homes will notify affected individuals of any breaches with a real risk of significant harm; and keep records of all breaches, regardless of whether a breach presents a real risk of significant harm.
9. INDIVIDUAL ACCESS
An individual who wishes to review or verify what Personal Information is held by Odyssey Homes or to whom the information has been disclosed, may make a request for access, in writing, to Odyssey Homes. Upon verification of the individual’s identity, a representative of Odyssey Homes will respond to the request within thirty (30) days:
The 30-day response time limit for access requests may be extended by an additional 30 days, if:
- responding to the request within the original 30 days would unreasonably interfere with the activities of Odyssey Homes;
- Odyssey Homes needs additional time to conduct consultations; or
- Odyssey Homes needs additional time to convert Personal Information to an alternate format.
An individual can file a complaint about Odyssey Homes’ personal information handling practices, by providing a complaint in writing to Odyssey Homes at firstname.lastname@example.org
Upon verification of the individual’s identity, Odyssey Homes will investigate the complaint and provide a written report of the investigation’s findings to the individual.
If the individual is dissatisfied with the finding and corresponding action taken by Odyssey Homes the individual may file a complaint with the Office of the Privacy Commissioner. More information about the process for filing a complaint with the Office of the Privacy Commissioner can be found here.