YOUR PRIVACY IS IMPORTANT TO US. Corporate Privacy Policy
1. POLICY
Boardwalk is committed to maintaining the accuracy, confidentiality, and security of your personally identifiable information. As part of this commitment, this privacy policy (“Privacy Policy”) governs the way in which Boardwalk collects, uses, discloses, and protects Personal Information for Individuals and/or Third Parties. Further, this Privacy Policy addresses an Individual’s or a Third Party’s right to have access to Personal Information and if necessary, correct the information.
Boardwalk has a designated Individual (“Privacy Officer”) who is responsible for compliance with this Privacy Policy. As of the date on which this Privacy Policy was last revised, Helen Mix, VP People, is the designated Privacy Officer. The Privacy Officer can be contacted at privacy@bwalk.com or 403-206-6778.
This Privacy Policy is based upon the principles set by Canada's Personal Information Protection and Electronic Documents Act (“PIPEDA”) and the applicable provincial privacy legislation.
2. PURPOSE
The purpose of this Privacy Policy is to preserve the privacy of Individuals and/or Third Parties by outlining obligations and procedures for dealing with Personal Information. In certain circumstances, Personal Information may be collected, used, or disclosed without the knowledge or Consent of the Individual and/or Third Parties. Exemptions include, but are not limited to, Personal Information gathered for: legal, medical, or security reasons, and prevention of fraud or for Law Enforcement purposes if its use is confined to those purposes.
3. SCOPE
This Privacy Policy describes the minimum requirements for the protection of Personal Information. Any applicable legislation must be considered in implementing these requirements.
4. DEFINITIONS
The following definitions apply to this Privacy Policy:
a. “Personal Information” (PI) means recorded information about an identifiable Individual and/or Third Party which includes, but is not limited to, home addresses and telephone numbers, age, gender, marital or family status, identifying numbers such as social insurance number, driver’s licence and other ID numbers, medical notes, employment history (past and present), financial history, banking information, criminal background checks, anyone else’s opinions about an Individual and/or Third Party, an Individual’s personal views or opinions, and name, address and phone number of parent, guardian or spouse;
b. “Privacy Breach” means the unauthorized or unlawful access, use, disclosure, communication, loss, or other breach of Personal Information, under PIPEDA and substantially similar provincial laws.
c. “Collection” means the act of gathering, acquiring, or obtaining Personal Information from any source, including a Third Party, by any means;
d. “Consent” means a voluntary agreement with what is being done or proposed. Consent can either be express or implied. Express consent is given explicitly, either orally or in writing. Express consent is unequivocal and does not require any inference on the part of the organization seeking consent. Implied consent arises where consent may reasonably be inferred from the action, or inaction, of the Individual and/or Third Party;
e. “Disclosure” means making Personal Information available to others inside and/or outside of Boardwalk;
f. “Individual” and “Individuals” means persons being the subject of records held by Boardwalk;
g. “Law Enforcement” means disciplinary investigations or proceedings that lead or could lead to a penalty or sanction being imposed and policed;
h. “Third Party” and “Third Parties” mean persons or organizations other than the subject of the records or representatives of Boardwalk. Note that in certain circumstances, the company may be entitled to provide Personal Information to an external party acting as an agent of Boardwalk;
i. “Use” means the treatment and handling of Personal Information by, and within Boardwalk; and
j. “Boardwalk” means all entities and subsidiaries included in the Boardwalk Real Estate Investment Trust consolidated structure.
k. “Sensitive Personal Information is information that is medical, biometric or otherwise intimate in nature, or the context of its use or release entails a high level of reasonable expectation of privacy. Examples of Sensitive Personal Information under the General Data Protection Regulation (GDPR) include race or ethnicity, political opinions, religious of philosophical beliefs, trade union membership, sexual orientation or sex life, genetic data, biometric data, and health data.5. RESPONSIBILITY
Boardwalk acknowledges its responsibility for the protection of Personal Information under its control and is committed to complying with Canada's Personal Information Protection and Electronic Documents Act (PIPEDA) and any applicable provincial privacy legislation. Boardwalk has designated a Privacy Officer who is accountable for overseeing compliance with privacy laws and ensuring the implementation of appropriate privacy practices and procedures.
The Privacy Officer is responsible for:
a. Developing and maintaining privacy policies and procedures in accordance with applicable privacy laws and regulations;
b. Educating employees and contractors about their privacy obligations and providing necessary training and guidance;
c. Responding to inquiries, complaints, and requests related to privacy matters;
d. Conducting privacy assessments and audits to identify risks and ensure compliance;
e. Monitoring changes in privacy laws and regulations and updating privacy practices accordingly;
f. Collaborating with relevant departments and stakeholders to implement privacy best practices;
g. Acting as a point of contact for individuals seeking information or exercising their privacy rights;
h. Ensuring the security and protection of Personal Information through appropriate technical and organizational measures;
i. Coordinating and cooperating with regulatory authorities and supervisory bodies on privacy-related matters;
j. Overseeing the handling of privacy breaches, including notification and mitigation procedures;
k. Regularly reviewing and updating the privacy policy and related documentation to reflect changes in the organization's practices or legal requirements.
Boardwalk recognizes that safeguarding Personal Information is a shared responsibility, and all employees and contractors are expected to comply with this privacy policy and related procedures.
Individuals and/or Third Parties are responsible for:
a. Being familiar with and following this Privacy Policy;
b. Providing the proper consents and authorizations;
c. Immediately reporting any privacy breaches to the Privacy Officer; and
d. Updating Personal Information with Boardwalk.6. LEGAL REQUIREMENTS
a. Accountability
Boardwalk is responsible for Personal Information under its control and has a designated Privacy Officer who is accountable for Boardwalk’s compliance with PIPEDA, applicable provincial privacy legislation, and all privacy requirements.
b. Identifying Purposes
Boardwalk specifies the purposes of Collection and Use of Personal Information prior to receiving consent from the Individual and/or Third Party and proceeding with the Collection and/or Use of such Personal Information.
Personal Information is collected and/or used for the following purposes:
i. Verifying an Individual or a Third Party’s identity;
ii. Processing rental applications.
iii. Performing background and credit checks in:
1. Processing rental applications; and
2. Processing employment applications
iv. Contacting Individuals and/or Third Parties for the purpose of Boardwalk-related business, such as arranging an apartment viewing, and following up with an individual on a guest card or waitlist;
v. Disclosing Personal Information to utility or service providers to provision services such as Internet, electricity, natural gas, telephone and security alarm systems;
v1. Exercising legal recourses during or after a business relationship between Boardwalk and an Individual or a Third Party is over (for example, recovering rents due and/or damages);
vii. Managing and operating properties, including lease agreements and Resident Member relations (for example, ensuring that a parking space is used by an authorized Resident Member);
viii. Conducting due diligence on properties and related transactions;
ix. Complying with legal and regulatory obligations related to real estate investments;
x. Ensuring successful completion of financial transactions, including property acquisitions, dispositions, and financing arrangements;
xi. Facilitating internal record-keeping, accounting, and financial reporting processes;
xii. Ensuring compliance with applicable tax laws and regulations; and
xiii. Conducting internal audits, risk assessments, and investigations.
Please note that this list of purposes may be updated or amended from time to time to reflect the evolving nature of Boardwalk's activities and legal obligations.
c. Consent
The knowledge and Consent of the Individual and/or Third Party is required for the Collection, Use, or Disclosure of Personal Information. In certain circumstances, Personal Information may be collected, used, or disclosed without the knowledge or Consent of the Individual. Exemptions include, but are not limited to, Personal Information gathered for: legal, medical, or security reasons, and prevention of fraud or for Law Enforcement purposes if its use is confined to those purposes.
d. Limiting Collection
With the Individual’s and/or Third Party’s Consent and in compliance with this Policy, PIPEDA and substantially similar provincial laws, Boardwalk may collect Personal Information from the Individual or from any other Third Party.
Boardwalk collects Personal Information on Individuals through the following means:
i. Directly from Individuals, for example:
1. Inquiries with customer care or a leasing office via phone, email, chat, SMS or Internet Listing Sites;
2. Employment applications;
3. Rental applications (“offer to lease”, or “OTL”);
4. Website (creating accounts, contact forms, Resident Member portal).
ii. Cookies and similar technology (Please refer to Section 10. “Use of Cookies” for more details);
iii. Other sources or third parties:
1. Credit or collection agencies;
2. Past or current landlords and employers;
3. Government agencies and public records;
4. Advertising partners;
5. Utility or service providers; and
6. Social media platforms.
e. Limiting Use, Disclosure and Retention
Personal Information shall not be used or disclosed for purposes other than those for which it was collected, except with the Consent of such Individual and/or Third Party or as permitted by law. Personal Information will be retained only as long as necessary for the fulfillment of those purposes.
f. Accuracy
Personal Information shall be as accurate, complete, and up to date as is necessary for the purposes for which it is to be used.
g. Safeguards
Personal Information shall be protected by security safeguards appropriate to the sensitivity of the information.
h. Openness
At the time of Collection, and at any time upon request afterwards, Boardwalk shall advise Individuals and/or Third Parties of the following:
I. The source of Personal Information collected, unless Law Enforcement motives are involved;
II. The means by which Personal Information is collected;
III. The Individual’s right to request access and make corrections to their file and Personal Information, their right to withdraw consent to Collection and Use thereof, and the existence of the procedures set out herein with regards to these rights;
IV. Where an agent for Boardwalk is involved in the Collection of Personal Information, that the Collection is being performed on its behalf;
V. The name of any Third Party to which Personal Information must be disclosed for identified purposes;
VI. In the province of Québec, the possibility that Personal Information may be disclosed outside of Québec.
Upon request, Boardwalk shall also inform an Individual of the Privacy Officer’s contact information.
i. Individual Access
Upon request, an Individual shall be informed of the existence, nature, use, and disclosure of their Personal Information and shall be given access to that information. Likewise, an Individual shall be informed of the categories of Boardwalk representatives and Associates that have had access to their Personal Information and the applicable retention period. An Individual shall be able to challenge the accuracy and completeness of Personal Information and have it amended as appropriate.
j. Challenging Compliance
An Individual shall be able to address a challenge concerning compliance with the principles of this Privacy Policy to the Privacy Officer. The Privacy Officer can be contacted at privacy@bwalk.com or 403-206-6778.
7. PROCEDURES
a. Information Collected
Boardwalk’s collection, use, disclosure, and retention of Personal Information is done in order to establish, manage, or terminate a relationship with an Individual and/or Third Party.
b. Providing Consent
The collection, use, or disclosure of your personal information by Boardwalk requires your knowledge and consent. At times, consent to the collection, use, and disclosure of Personal Information may be implied from the manner in which it is collected, unless that Personal Information is deemed Sensitive Personal Information.
If Boardwalk collects, uses or discloses personal information for the purposes other than those described above, prior to the collection, use and/or disclosure of such personal information, unless required to be disclosed by law, you will be notified of and your consent will be obtained prior to, Boardwalk’s collection, use and/or disclosure of that personal information. If we intend to use and/or disclose Personal Information that we previously collected for a new purpose which is not authorized under applicable laws, your consent will always be obtained before we use and/or disclose it for that new purpose.
Exceptions to the requirement of obtaining new or updated consent for the use of existing Personal Information include using the Personal Information:
I. For purposes consistent with the purposes for which it was collected;
II. In a manner that is clearly for the benefit of the Individual;
III. For the purposes of preventing and detecting fraud or of assessing and improving protection and security measures;
IV. For the purpose of providing or delivering a product or providing a service requested by the Individual; or
V. For study or research purposes or for the production of statistics and if the information is de-identified. Personal Information is de-identified when it may no longer allow the PI holder to identify the individual directly.
c. Withdrawal of Consent
An Individual and/or Third Party may withdraw Consent subject to legal or contractual obligations and on reasonable notice. If an Individual wants to withdraw Consent, the Individual should first contact the Privacy Officer to understand the implications of such withdrawal, and then if the Individual and/or Third Party chooses to proceed, to give the requisite notice.
d. Access to Personal Information
I. Individuals and/or Third Parties may request access to review their own file by making arrangements with the Privacy Officer. Individuals and/or Third Parties shall provide written notice to the Privacy Officer. The Privacy Officer will respond to the request within thirty (30) days or advise the Individual and/or Third Party when/if additional time is required to respond to the request, insofar as law permits in the circumstances;
II. There may be situations in which Boardwalk is legally prohibited from allowing an Individual and/or Third Party to access to their Personal Information. For example, Boardwalk would be so prohibited if allowing an Individual and/or Third Party to access to their Personal Information would likely reveal Personal Information about another person or other confidential information. If this is the case, Boardwalk will advise the Individual and/or Third Party, why, subject to any legal restrictions.
Other exceptions include but are not limited to the following:
1. The right of access does not extend to information exempted from Disclosure under PIPEDA or the applicable provincial privacy legislation, however, if that information can reasonably be severed from a record an applicant has the right of access to the remainder of the record.
e. Correcting Personal Information
As stated above in subsection 7 (d)(i), an Individual and/or Third Party has the right to submit a written request to access their Personal Information that is in Boardwalk’s possession and make corrections to it. The Individual and/or Third Party can request a correction to their Personal Information if there is an error omission or, alternatively, the Individual and/or Third Party may require that a statement of disagreement is attached. Boardwalk will amend Personal Information that is demonstrated to be inaccurate or incomplete.
Requests to update or correct Personal Information can be submitted by contacting the Privacy Officer via email or phone.
f. Disclosure
Disclosure will be governed according to this Privacy Policy or other specific policies and procedures, which may be established or amended from time to time by Boardwalk to apply to the Personal Information of Individuals and/or Third Parties.
Boardwalk will not disclose Personal Information about Individuals and/or Third Parties to any Third Party, except under the following circumstances:
I. Where the Individual and/or Third Party who is the subject of Disclosure has provided express Consent;
II. If the information is required for the purpose for which it was obtained;
III. Where Boardwalk is permitted or required to do so by application legislation or regulation;
IV. Where the Disclosure is required by authorized government representatives who are acting to enforce any federal or provincial law or carrying out an investigation relating to the enforcement of any federal or provincial law, or for gathering information for the purpose of enforcing any federal or provincial law;
V. Where Boardwalk is required to comply with any valid court orders, warrants, or any other valid legal processes;
VI. In an emergency to protect the physical safety or any person or group of persons; and
VII. In compassionate circumstances in order to facilitate contact with a family member or a friend of an Individual and/or Third Party who is injured, ill or deceased.
Requests regarding Third Party access to Personal Information will be handled by the Privacy Officer of Boardwalk and must be in writing.
g. Retention and Destruction of Personal Information
Personal information that is no longer needed for its stated purpose will be destroyed, erased, or made anonymous.
Boardwalk will maintain Personal Information for as long as it is necessary to fulfill the purpose for which it was collected or to comply with any laws. The period in which Personal Information is retained may extend beyond the relationship between Boardwalk and the Individual and/or Third Party, as defined in Boardwalk’s Data Retention and Disposal Schedule. For example, a tenant’s Personal Information may be retained for years after their tenancy relationship with Boardwalk has ended, for financial and legal auditing purposes.
8. SAFEGUARD, SECURITY AND PROTECTION OF PERSONAL INFORMATION
Boardwalk will take and enforce all reasonable security measures appropriate for the sensitivity of the information to ensure that all Personal Information is protected against any form of unauthorized Use including but not limited to accidental or malicious Disclosure, unauthorized access, unauthorized modification, unauthorized duplication, or theft.
Methods of security will include but not be limited to the following:
a. Physical security including locked filing cabinets and secure access offices;
b. Organizational security including security clearances and limited access; and
c. Technological security including passwords and encryption.9. USE OF VIDEO SURVEILLANCE AND AUDIO RECORDINGS
Video equipment may be installed and operating in common areas of our buildings. The video equipment may have capabilities such as zoom or night-vision features. The video equipment may be operating at all times. Surveillance of the video recordings may occur at any time.
The purpose of this equipment is to ensure your safety, security, and reasonable enjoyment and that of our Resident Members, to ensure you have access to the premises, equipment and services that Boardwalk has agrees to provide, to preserve Boardwalk’s 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.
Audio recordings may be made during meetings, interviews, or telephone calls.
The purpose of audio recordings may be used for, but not limited to, quality control, training purposes, ensuring safety or conflict resolution. These recordings may be provided to law enforcement as deemed necessary and per the request of the authorities.
You can contact our Privacy Officer if you have questions regarding video or audio recordings.
10. USE OF COOKIES
We and our vendors (which may include third-party advertising networks, social media companies, or other service providers) use cookies on our website to provide necessary website functionality (such as filling out a form), to enhance the user experience or optimize performance, or to display content or advertising tailored to you. Some cookies may store information collected about you over time and across multiple websites.
The information collected does not always directly identify you, but it can help us deliver a more personalized website experience. To respect your privacy and your personal information, you have the option to accept or deny optional cookies. Denying some cookies may affect a web page’s functionality as well as the user experience on the website.
What is a Cookie?
A cookie is a small text file that is placed on your computer or other device via your web browser. Cookies enable the ability to store and remember information about you or your device, such as website preferences, language preferences, the type of device you are using, or how many times you have visited a web page.
What types of Cookies do we use?
Necessary Cookies: These cookies are necessary for the website to function and cannot be turned off in our systems. They normally only respond to actions in which you request a type of service or interaction such as saving your privacy preferences or filling out a form. You can set your browser to block or alert you about these cookies, but some parts of the site will not then work. These types of cookies do not collect personal information.
Functional Cookies: These cookies help to create enhanced functionality and a more personalized user experience. They may be first-party (set by us) or third-party (set by a vendor or other service provider). Disabling or denying these cookies may cause some functions and personalization options to not work properly. These types of cookies do not collect personal information.
Performance Cookies: These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our site. They help us to know which pages are the most and least popular and see how visitors move around the site. All information these cookies collect is aggregated and therefore anonymous. If you do not allow these cookies we will not know when you have visited our site and will not be able to monitor its performance.
Targeting Cookies: These cookies may be set through our site by our partners. They may be used by those companies to build a profile of your interests and show you relevant adverts on other sites. These cookies may use personal information that uniquely identifies you, your browser, and your internet device. If you do not allow these cookies, you will experience less targeted advertising.
When you have access to our website for the first time, a prompt will inform you of the use of cookies and request that you select which types of cookies you wish to turn on (except for necessary cookies).
Your selection will be saved for later visits on the website, and you may change your selection at any time. Please note that by not enabling or disabling future cookies, you may not be able to access certain areas or features of our website.
11. REVISIONS TO THIS PRIVACY POLICY
Boardwalk reserves the right to change this Privacy Policy from time to time. Revisions will be effective when posted on Boardwalk’s websites.
12. FURTHER INFORMATION AND CONTACT
Commercial Electronic Messages (CEM)
If you would like to make an inquiry regarding any CEM that you may have received from Boardwalk REIT, please contact one of the following persons:
Nancy Dietterle – Director, Operations Support Teams
nmdietterle@bwalk.com
Helen Mix – Privacy Officer
privacy@bwalk.com
If an Individual and/or Third Party has a question or complaint regarding Boardwalk’s privacy policies or procedures, they may contact the Privacy Officer, Helen Mix, via email at privacy@bwalk.com or 403-206-6778.
If an Individual’s and/or Third Party’s concern remains unresolved to their satisfaction, the Individual and/or Third Party may address the concerns to the Privacy Commissioner of Canada, 112 Kent Street, Ottawa, Ontario, K1A 1H3 or the Privacy Commissioner of Alberta, Suite 2460, 801 6 Avenue SW, Calgary, Alberta, T2P 3W2.
Last updated December 20, 2023
QUESTIONS?
If you have questions or concerns about our privacy policy or about the security of your personal information, please contact:
BOARDWALK PRIVACY OFFICER
Phone: 403-206-6778
Email: privacy@bwalk.com