Brightside Statement of Values
Brightside promotes an environment that maintains clarity by being fair, open and consistent. To provide the best service possible, Brightside is open to change and eager to constantly improve by being rigorous, diligent and be great problem solvers. In order to continue being recognized as a leader, Brightside must be progressive by being adaptive, flexible and pro-active. Brightside values inclusivity by being respectful, approachable and compassionate.
A. Personal Information
Information concerning an identifiable individual (this does not include contact information).
B. Contact Information
Information that would enable an individual to be contacted at a place of business and includes name, position or title, business telephone number, business address, business email or business fax number. Note: Contact information is not covered by this policy or by PIPA.
C. Privacy Officer
The individual designated responsibility for ensuring that Brightside complies with this policy and PIPA.
II. OPERATIONAL MATTERS
A. Collecting Personal Information
i) Brightside will communicate the purposes for which personal information is being collected, either orally or in writing, before or at the time of collection.
ii) Only tenant or resident information is necessary to fulfill the following will be collected:
- To verify identity
- To communicate with tenants
- To identify tenant communication preferences
- To collect rent and other related payments
- To deliver requested services
- To ensure the orderly management of the building in which the tenant resides
- To allow the use of video surveillance to ensure the safety of tenants and guests
- To respond to emergencies
- To meet regulatory requirements
- To determine if tenants meet designated criteria for tenancy and rent subsidy
iii) Personal information that is collected may include:
- Name, address, email, telephone numbers
- Banking information
- Statements of income from BC Benefits, CPP, OAS, GIS
- Pay stubs
- Statements of assets i.e. Bonds, mutual funds, term deposits, RRSPs and investments
- Completed tax returns sent to Revenue Canada (T1 General)
- Emergency contact information
- Vehicle description and license plates
- Information about pets
- Names of family members residing with tenant
i) Brightside will obtain tenant consent to collect, use or disclose personal information.
ii) Consent can be provided by filling in a form supplied by Brightside or be implied where the purpose for collecting, using or disclosing personal information would be considered obvious and the resident voluntarily provides personal information for that purpose.
iii) Consent may be implied where a tenant is given notice and a reasonable opportunity to opt out of his or her personal information being used for email notices and the tenant does not opt out.
iv) Subject to certain exceptions (i.e. the personal information is necessary to provide the service or product, or the withdrawal of consent would frustrate the performance of a legal obligation) tenants can withhold or withdraw their consent for Brightside to use their personal information in certain ways. A tenant’s decision to withhold or withdraw their consent to certain uses of personal information may restrict Brightside’s ability to provide a particular service or document.
v) Brightside may collect, use or disclose personal information without the tenant’s knowledge or consent 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 personal information is available from a public source (i.e. telephone listing)
- When Brightside requires legal advice
- For the purposes of collecting a debt
- To investigate an anticipated breach of an agreement or a contravention of law
- When requested by law enforcement agencies
C. Using and Disclosing Personal Information
i) Brightside will only use or disclose a tenant’s personal information where necessary to fulfill the purposes identified at the time of collection or for a purpose reasonably related to those purposes, such as:
- To fulfill any rights or obligations as permitted by the Residential Tenancy Act
- To conduct tenant surveys to enhance the provision of Brightside’s services
- To contact tenants directly regarding information, meetings and services that may be of interest
ii) Video camera footage may be provided to law enforcement officials.
iii) Brightside will not use or disclose tenant personal information for any addition purposes unless consent is obtained from the tenant.
iv) Brightside will not sell tenant lists or personal information to other persons or organizations.
D. Retaining Personal Information
i) If Brightside uses tenant personal information to make a decision that directly affects the tenant, that personal information will be retained for at least one year so that the tenant has reasonable opportunity to request access to it.
ii) Subject to D(i) Brightside will retain tenant personal information only as long as is deemed necessary to fulfill the identified purposes or a legal or business purpose.
E. Ensuring Accuracy of Personal Information
i) Brightside will make reasonable effort to ensure that tenant personal information is accurate and complete when it may be used to make a decision about the tenant or be disclosed to another organization.
ii) Tenants may request correction of their personal information to ensure accuracy and completeness. The request must be made in writing and provide sufficient details to identify the personal information and the correction being requested. Any request to correct personal information will be forwarded in writing to Brightside.
iii) If personal information is inaccurate or incomplete, Brightside will correct the information as required and send it to any organization to which Brightside had disclosed said information.
F. Securing Personal Information
i) Brightside is committed to ensuring the security of tenant confidential information and to protect it from unauthorized access, collection, use, disclosure, duplication, modification, disposal or other risks that may arise.
ii) The following security measures will be followed to ensure that tenant personal information is protected:
- Locking filing cabinets
- Physically securing offices where personal information is stored
- Using user ID and passwords for email accounts. Passwords must consist of a minimum of 8 characters, and to include at least one capital letter and number or other character.
- Restricting access to personal information as appropriate i.e. Only those that need to know will be given access
- Contractors must agree, in writing, to secure and not share confidential information belonging to Brightside. (RFPs will include a request for information on what contractors have in place to ensure confidentiality of client information.)
iii) Video camera receiver is located with the service provider or in any other designated area in a locked room with limited and controlled access.
iv) Appropriate security measures will be used when destroying tenants’ personal information i.e. shredding documents and deleting electronically stored information.
v) Brightside will review and update security procedures at a minimum of every 2 years, as technology changes, to ensure ongoing protection of personal information.
vi) The retention and disposition of confidential documents is covered in detail in the Records Retention and Disposition Policy.
G. Providing Tenant Access to Personal Information
i) Tenants have the right to access their personal information subject to the following exceptions:
- Solicitor client privilege
- When disclosure would reveal personal information about another individual
- When there are health and safety concerns
ii) Any request to access personal information must be made in writing and provide sufficient detail to identify the personal information being sought.
iii) Any request to access personal information should be forwarded to the Privacy Officer.
iv) Upon request, Brightside will inform tenants as to how their personal information will be used and to whom it has been disclosed.
v) If a request is denied in full or part, the tenant will be notified in writing, providing the reasons for refusal and any recourse that may be available.
H. Questions and Complaints and the Role of the Privacy Officer
i) The Privacy officer is responsible for ensuring Brightside’s compliance with the Policy and the PIPA.
ii) The CEO shall be the designated Privacy Officer.
iii) Tenants should direct any complaints, concerns or questions regarding Brightside’s compliance in writing to the Privacy Officer. If the Privacy Officer or a designated replacement is for any reason unable to resolve the concern, the tenant may also write to the Information and Privacy Commissioner of BC.
iv) Emails to the Privacy Officer can be sent to PO@brightsidehomes.ca. [Programming note – Link to email: PO@brightsidehomes.ca] Communications can also be mailed to the Privacy Officer c/o the Brightside office at #300 – 905 West Pender, Vancouver, BC V6C 1L6.
v) It is contrary to Brightside’s values for anyone to take action against an employee or Director who in good faith reports an ethics violation, or a suspected violation of law, such as a complaint of discrimination, suspected fraud, or suspected violation of any regulation governing the operations of Brightside.
Document amended November 27, 2018. Page updated October 9, 2019