Policies

PHIPA Policy

The facility supports and reflects Sifton Properties Limited (SPL) privacy initiatives and policy development under the direction of Senior Management, the Privacy Officers and the Steering Committee formed for this purpose.

Definitions

Attorney for Personal Care: means an attorney under a power of attorney for personal care made in accordance with the Substitute Decisions Act, 1992, pursuant to the Personal Health Information Protection Act, 2004, S.O. 2004, c. 3 (hereinafter referred to as “PHIPA”)

Attorney for Property: means an attorney under a continuing power of attorney for property made in accordance with the Substitute Decisions Act, 1992; pursuant to PHIPA.

Circle of Care: means a person or organization, whether a health information custodian or non-health information custodian within the meaning of PHIPA, that is directly or indirectly involved in the provision of care of the resident and the resident has provided express or implied consent to such provision of care by the person or organization.

Confidential Information: means all information, other than personal and personal health information, regarding a client, staff person, volunteer or the organization, that is seen, heard, obtained or observed.

Health Information Agent: in relation to a health information custodian, means a person that, with the authorization of the custodian, acts for or on behalf of the custodian in respect of personal health information for the purposes of the custodian, and not the agent’s own purposes, whether or not the agent has the authority to bind the custodian, whether or not the agent is employed by the custodian and whether or not the agent is being remunerated; pursuant to PHIPA.

Health Information Custodian: (hereinafter referred to as “HIC”) a person or organization described in one of the following paragraphs who has custody or control of personal health information as a result of or in connection with performing the person’s or organization’s powers or duties or the work described in the paragraph, if any:

  • A health care practitioner or a person who operates a group practice of health care practitioners.
  • A service provider within the meaning of the Long-Term Care Act, 1994 who provides a community service to which that Act applies.
  • A community care access corporation within the meaning of the Community Care Access Corporations Act, 2001.
  • A person who operates one of the following facilities, programs or services:
    • A hospital within the meaning of the Public Hospitals Act, a private hospital within the meaning of the Private Hospitals Act, a psychiatric facility within the meaning of the Mental Health Act, an institution within the meaning of the Mental Hospitals Act or an independent health facility within the meaning of the Independent Health Facilities Act.
    • An approved charitable home for the aged within the meaning of the Charitable Institutions Act, a placement co-ordinator described in subsection 9.6 (2) of that Act, a home or joint home within the meaning of the Homes for the Aged and Rest Homes Act, a placement co-ordinator described in subsection 18 (2) of that Act, a nursing home within the meaning of the Nursing Homes Act, a placement co-ordinator described in subsection 20.1 (2) of that Act or a care home within the meaning of the Residential Tenancies Act, 2006.
    • A pharmacy within the meaning of Part VI of the Drug and Pharmacies Regulation Act.
    • A laboratory or a specimen collection centre as defined in section 5 of the Laboratory and Specimen Collection Centre Licensing Act.
    • An ambulance service within the meaning of the Ambulance Act.
    • A home for special care within the meaning of the Homes for Special Care Act.
    • A centre, program or service for community health or mental health whose primary purpose is the provision of health care.
  • An evaluator within the meaning of the Health Care Consent Act, 1996 or an assessor within the meaning of the Substitute Decisions Act, 1992.
  • A medical officer of health or a board of health within the meaning of the Health Protection and Promotion Act.
  • The Minister, together with the Ministry of the Minister if the context so requires. Any other person prescribed as a health information custodian if the person has custody or control of personal health information as a result of or in connection with performing prescribed powers, duties or work or any prescribed class of such persons, pursuant to PHIPA.

Personal Health Information: means identifying information about a resident in oral or recorded form, if the information:

  • relates to the physical or mental health of the individual, including information that consists of the health history of the individual’s family,
  • relates to the providing of health care to the individual, including the identification of a person as a provider of health care to the individual,
  • is a plan of service within the meaning of the Long-Term Care Act, 1994 for the individual,
  • relates to payments or eligibility for health care in respect of the individual,
  • relates to the donation by the individual of any body part or bodily substance of the individual or is derived from the testing or examination of any such body part or bodily substance,
  • is the individual’s health number, or
  • identifies a resident’s substitute decision-maker, as defined by the Personal Health Information Protection Act (“PHIPA”).

Personal Information: means information about an identifiable individual, but does not include the name, title or business address or telephone number of an employee of an organization, as defined by the Personal Information Protection and Electronic Documents Act , 2000, c. 5 (hereinafter referred to as “PIPEDA”).

Privacy: means the safeguarding of personal, personal health, and confidential information from access or disclosure of such information without authorization as such authorization is set out in this Privacy Policy and in accordance with applicable federal and provincial legislation.

Retirement Living Division

Each site is considered a health information custodian and the staff are considered health information agents under PHIPA.

Collection and Use of Personal Information

The purposes for collection of confidential, personal and personal health information include, but may not be limited to:

  • Making decisions about the types of services required by residents;
  • Providing appropriate direct resident care;
  • Communicating with other service providers and agents
  • Monitoring the provision of services and evaluating the resident’s response to services provided;
  • Administering quality control and risk management programs;
  • Providing payment for health care, services or products;
  • Providing employee payroll, benefit and pension administration programs and other services; and
  • Meeting legal, and regulatory requirements

Persons collecting confidential, personal or personal health information will explain to the resident who is the subject of the information the purpose(s) for which the information is being collected, subject to applicable federal and provincial laws.

The confidential, personal or personal health information collected shall be limited to that which is necessary for the purposes identified by the facility, or as otherwise permitted by law.

Consent

Both PHIPA and PIPEDA require a resident’s knowledgeable consent as defined in this Policy to collect, use or disclose the information.

Consent with respect to the collection, use or disclosure of confidential, personal or personal health information about an individual or the facility may be express or implied, except in the following circumstances:

Consent to the disclosure of personal health information about a resident must be express, and not implied, if,

  • the facility makes the disclosure to a person that is not a health information custodian; or
  • the facility makes the disclosure to another health information custodian and the disclosure is not for the purposes of providing health care or assisting in providing health care.

Who may consent:

  • If the individual is capable of consenting to the collection, use or disclosure of the information,
    • the individual, or
    • any person who is capable of consenting, whom the individual has authorized in writing to act on his or her behalf and who, if a natural person, is at least 16 years of age.
  • If the individual is incapable of consenting to the collection, use or disclosure of the information, a person who is authorized under this policy.
  • If the individual is deceased, the deceased’s estate trustee or the person who has assumed responsibility for the administration of the deceased’s estate, if the estate does not have an estate trustee.
  • A person whom an Act of Ontario or Canada authorizes or requires to act on behalf of the individual.

Elements of consent: if this policy or applicable legislation requires the consent of a resident for the collection, use or disclosure of personal or personal health information by the facility, or on behalf of another HIC, the consent,

  • must be a consent of the resident;
  • must be knowledgeable;
  • must relate to the information; and
  • must not be obtained through deception or coercion.

Knowledgeable consent: consent to the collection, use or disclosure of personal health information about a resident is knowledgeable if it is reasonable in the circumstances to believe that the individual knows:

  • the purposes of the collection, use or disclosure, as the case may be; and
  • that the individual may give or withhold consent.

Implied consent:  The facility or its Agent that receives personal or personal health information about a resident from the resident, the resident’s substitute decision-maker or another HIC for the purpose of providing health care or assisting in the provision of health care to the resident, is entitled to assume that it has the resident’s implied consent to collect, use or disclose the information for the purposes of providing health care or assisting in providing health care to the resident, unless the facility is aware that the resident has expressly withheld or withdrawn the consent.

Capacity to consent

A resident is capable of consenting to the collection, use or disclosure of personal health information if the individual is able,

  • to understand the information that is relevant to deciding whether to consent to the collection, use or disclosure, as the case may be; and
  • to appreciate the reasonably foreseeable consequences of giving, not giving, withholding or withdrawing the consent.

Different information

A resident may be capable of consenting to the collection, use or disclosure of some parts of personal health information, but incapable of consenting with respect to other parts, pursuant to PHIPA, s. 21 (2).

Different times

A resident may be capable of consenting to the collection, use or disclosure of personal health information at one time, but incapable of consenting at another time, pursuant to PHIPA, s. 21 (3).

Presumption of capacity

A resident is presumed to be capable of consenting to the collection, use or disclosure of personal and personal health information, and as a HIC, the facility staff or agents may presume a resident has such unless the staff person or agent responsible for such collection, use or disclosure on behalf of the facility has reasonable grounds to believe that the individual is incapable of granting such consent, pursuant to this policy and PHIPA, s. 21 (4) and (5).

Determination of incapacity

 A health information custodian that determines the incapacity of a resident to consent to the collection, use or disclosure of personal health information under this Act shall do so in accordance with the requirements and restrictions, if any, that are prescribed in PHIPA.

Factors to consider for consent

A person who consents under this policy and applicable legislation on behalf of or in the place of a resident to a collection, use or disclosure of personal health information by the facility, who withholds or withdraws such a consent or who provides an express instruction shall take into consideration

the wishes, values and beliefs that,

  1. if the individual is capable, the person knows the individual holds and believes the individual would want reflected in decisions made concerning the individual’s personal health information, or
  2. if the individual is incapable or deceased, the person knows the individual held when capable or alive and believes the individual would have wanted reflected in decisions made concerning the individual’s personal health information;

whether the benefits that the person expects from the collection, use or disclosure of the information outweigh the risk of negative consequences occurring as a result of the collection, use or disclosure;

  1. whether the purpose for which the collection, use or disclosure is sought can be accomplished without the collection, use or disclosure; and
  2. whether the collection, use or disclosure is necessary to satisfy any legal obligation.

Information about determination

If it is reasonable in the circumstances, the facility shall provide, to the resident determined incapable of consenting to the collection, use or disclosure of his or her personal health information, information about the consequences of the determination of incapacity, including the information, if any, that is prescribed pursuant to PHIPA, s. 22 (2).

Review of determination

A resident whom the facility determines is incapable of consenting to the collection, use or disclosure of his or her personal health information may apply to the Organization Chief Privacy Officer for a review of the determination unless there is a person who is entitled to act as the substitute decision-maker of the individual.

Incapable individual: persons who may consent

If a resident is determined to be incapable of consenting to the collection, use or disclosure of personal health information by the facility, a person described in one of the following paragraphs may, on the resident’s behalf and in the place of the individual, give, withhold or withdraw the consent:

  • The individual’s guardian of the person or guardian of property, if the consent relates to the guardian’s authority to make a decision on behalf of the individual.
  • The individual’s attorney for personal care or attorney for property, if the consent relates to the attorney’s authority to make a decision on behalf of the individual.
  • The individual’s representative appointed by the Board under section 27, if the representative has authority to give the consent.
  • The individual’s spouse or partner.
  • A child of the resident, or other person who is lawfully entitled to give or refuse consent in the place of the resident.
  • A brother or sister of the resident.
  • Any other relative of the resident.

Requirements

A person may consent on behalf of the resident determined to be incapable of granting consent to the collection, use or disclosure of personal and personal health information only if the person,

  • is capable of consenting to the collection, use or disclosure of personal or personal health information by the facility;
  • in the case of an individual, is at least 16 years old or is the parent of the resident to whom the personal or personal health information relates;
  • is not prohibited by court order or separation agreement from having access to the resident to whom the personal or personal health information relates or from giving or refusing consent on the resident’s behalf;
  • is available; and
  • is willing to assume the responsibility of making a decision on whether or not to consent.

Authority of substitute decision-maker

Where this policy and applicable legislation permits or requires a resident to make a request, give an instruction or take a step and a substitute decision-maker is authorized to consent on behalf of the resident to the collection, use or disclosure of personal or personal health information about the resident, the substitute decision-maker may make the request, give the instruction or take the step on behalf of the individual.  And such request made, instruction given or step taken by the substitute decision-maker shall be read as references to the substitute decision-maker, and not to the individual.

Potential residents of the facility authorize the collection and sharing of personal health information upon admission process in writing.

Residents authorize in writing the sharing of contact information by expressed consent in the admission process.

Residents authorize the use of personal banking information in the admission process by implying consent when completing the automatic bank payment option on admission.

Withdrawal of consent:

If a resident consents to the facility collecting, using or disclosing personal or personal health information about the resident, the resident, or the resident’s substitute decision maker if the resident is determined to be incapable, may withdraw the consent, whether the consent is express or implied, by providing notice to the facility.

The withdrawal of the consent shall not have retroactive effect, and withdrawal of such consent will only be permitted where the withdrawal will not compromise the provision of care to the resident by the facility or other HIC, or such information is required by the facility to comply with applicable legislation.

Openness and Accuracy

The facility endeavours to ensure that any personal and personal health information provided by its residents and in its possession is as accurate, current and complete as necessary for the purposes for which the data is collected and used.

A resident or a resident’s substitute decision maker may, upon written request of the facility Privacy Officer, see that file or files containing the resident’s personal information, subject to applicable law. If personal or personal health information is found contained in the file or files, the facility Privacy Officer will ensure the residents record is amended accordingly upon receipt of documentary proof that the subject information is incorrect or missing, and similar documentation demonstrating the correct or missing information.

Disclosure

Under PHIPA, health care facilities that provide health care may provide the following information to friends or family that make inquires:

  • confirmation that an individual is a resident
  • the individual’s general health status; and
  • the location of the individual in the residence.

Personal and health information will be used and disclosed for the purposes identified. The facility may disclose personal and personal health information to another HIC if the disclosure is reasonably necessary for the provision of health care and it is not reasonably possible to obtain consent in a timely manner, or where the disclosure is necessary for eliminating or reducing a significant risk of serious harm.

Record Retention and Security Safeguards

Record Retention:

Resident Records are retained for the duration of their stay at the facility. Upon transfer and relocation to another HIC, the resident’s record will be transferred to the HIC by courier so as to safeguard the confidentiality of the resident’s personal and personal health information.

If a resident dies, the facility will retain the file for two (2) years after the date of the resident’s death, or for the period required to comply with applicable legislation.

Organizational Security Safeguards:

In accordance with this policy and the Seniors’ Living Code of Conduct, all staff and volunteers are required to comply with this policy and are notified of their duties and obligations with respect to compliance with this policy by being provided with and signing their agreement to so comply in the Staff Handbook.

Staff and volunteer compliance with this policy and the Seniors’ Living Code of Conduct extends to facility Confidential Information as defined in this policy.

Contractors or third party service providers who may receive personal or personal health information in the course of providing services to the facility will protect that information in a manner consistent with the principles outlined in this policy statement, and will execute third party confidentiality agreements as provided by the Corporate Privacy Officer prior to providing services to the facility.

Physical Security Safeguards

Resident records in paper format are stored in the Wellness Centre and in the Business Office in locked cabinets, access to which records are restricted only to those staff with authorization to access such records.

Records of personal and personal health information are retained, transferred and disposed of in a secure manner.

Technological Security Safeguards

Electronic information is secured by personal password protection on the computer network system, firewalled by the latest technology, and limited in access based on a need to know basis.

Questions or Complaints

A resident or a resident’s family, spouse, or substitute decision maker where the resident consents to the complaint being made on his or her behalf, or is determined to be incapable, may direct questions, concerns or complaints respecting the handling of their personal or personal health information to the facility Privacy Officer. All questions and complaints will be investigated promptly and a written report provided to the resident or resident’s representative.

If the resident or the resident’s representative is not satisfied with the results of the report, he or she may make their concern or complaint known to the Corporate Privacy Officer at: sbrady@sifton.com The Corporate Privacy Officer will investigate the complaint or issue promptly and report in writing to the resident or resident’s representative.

If the resident or the resident’s representative is not satisfied with the results of the report from the Corporate Privacy Officer, a complaint may be directed to the Privacy Commissioner for Ontario, for issues respecting the handling of personal health information, as defined under PHIPA, or the Office of the Privacy Commissioner for issues respecting the handling of personal information as defined under PIPEDA. Contact information for the offices of the provincial and federal privacy commissioners is as follows:

Complaints under PIPEDA,

to be made in writing:

Office of the Privacy Commissioner

112 Kent Street, Place de Ville

Tower B, 3rd Floor

Ottawa, Ontario K1A 1H3

Complaints under PHIPA,

to be made in writing:

Information and Privacy Commissioner/Ontario

2 Bloor Street East, Suite 1400

Toronto, Ontario M4W 1A8

Policy Notice

A summary of this policy, in the form of a Privacy Notice, is to be posted in a general area(s) where it is available to residents and the residents’ families, spouses, substitute decision makers for review at all times and includes who to contact if there is a concern or question relating to the policy or any suspected violation.

The organization reserves the right to amend this policy as required to comply with privacy and other provincial and federal legislation. Any amendments to the said policy will have no retroactive effect, and be in force as of the date that it is posted on the Sifton Group of Companies website.

Corporate PIPEDA Policy

Purpose

Privacy of personal information is an important principle to Sifton Properties Limited.  We are committed to collecting, using and disclosing personal information responsibly and only to the extent necessary for providing the quality goods and services of our business to our customers. We also endeavour to be open and transparent as to how we handle personal information. This document describes our privacy policies.

What is Personal Information?

Personal information is any information that can be used to identify an individual.  This information includes information that relates to an individual’s personal data or characteristics, their health or their activities and views.  In most circumstances, personal information does not include information that might appear on a business card, or information that is available in public records.

Who We Are

Sifton Properties Limited provides a variety of quality goods and services in the following areas:

  • Office, retail, land and industrial leasing, property management services and construction
  • New home construction and sales
  • Development of land for the purposes of building communities, including new homes, recreation, shopping and commercial services
  • Management of gated community and recreational amenities
  • Rentals of apartments and townhomes
  • Accommodation and provision of care in retirement residences
  • To provide these goods and services, we hire employees and use a number of contractors, sub-contractors, consultants and agencies that may, in the course of their duties, have access to personal information we hold.

The Ten Privacy Principles

We follow 10 principles when collecting, using and disclosing your personal information:

  1. We are accountable for personal information under our control.
  2. The purpose for collecting personal information is identified at or before the time it is collected.
  3. We obtain your consent before, collecting, using or disclosing your personal information, except where otherwise permitted or required by law.
  4. We limit the personal information we collect to that which is necessary for us to conduct business.
  5. The personal information we collect is only used, disclosed or retained for its original intended purpose (unless you provide your consent to a different use or disclosure) and we retain it only as long as necessary for those purposes.
  6. We take care to ensure that the information we have is accurate.
  7. We safeguard the privacy of your personal information through security measures.
  8. We are open with you about our policies and practices related to managing your personal information.
  9. Upon request, we provide you with access to your personal information, subject to any limitations imposed by law.
  10. We address your concerns.  If you have questions or concerns regarding your privacy or this policy please contact us.

Your Consent

By providing us with your personal information, you consent to the collection, use and disclosure of that information.  We will not, as a condition of supplying a product or service, require you to consent to the collection, use or disclosure of your personal information beyond that required to enable us to provide the products or services requested.  The form of the consent that we will seek before collecting, using or disclosing personal information will vary depending upon the circumstances and the type of information, and includes express oral or written consent, implied consent or opt-out consent.  We will consider the sensitivity of the information and the individual’s reasonable expectations in determining how consent must be given.

It would be rare for us to collect any personal information without the customer’s, tenant’s or resident’s express consent, but this might occur in a case of urgency where we believe the individual would consent if asked and it is impractical to obtain consent, appropriate public sources or if it is necessary to investigate a breach of the customer’s agreement or a contravention of the law, or enforce an agreement you have with us.

You may refuse to give personal information and may, subject to legal or contractual restrictions and reasonable notice, withdraw consent at any time to the continued use and disclosure of personal information previously collected.  The period of reasonable notice will vary depending on the nature of the information and its’ purpose to the company.  We will inform you of the implications of refusing or withdrawing consent, which may have legal consequences or preclude us from providing the services or other consideration requested.

Collection of Personal Information

We collect, use and disclose personal information in order to serve our customers, tenants and residents. For most of our customers, the primary purposes for collecting personal information as per PIPEDA are:

  • To ensure our customers have access to the premises, equipment, accommodation, care, goods and services that we have agreed to provide
  • To ensure the safety, security and reasonable enjoyment of our customers and that of others
  • To communicate and promote information regarding our goods and services
  • To determine eligibility for purchase, leasing, or rental of properties
  • To collect payments, rents and other fees for care, products and services
  • To carry out quality assurance activities to help make us better
  • To comply with legal and regulatory requirements

Examples of the type of information we collect may include the following:

  • Names of occupants of the premises
  • Business and emergency contact information
  • Use and intended uses of the property
  • Compliance with the customer or tenancy agreement and/or rules and regulations related to the accommodation, new home financing requirements and construction, and/or other goods and services provided
  • Credit information and history
  • Payment, banking and other financial information
  • Tenant information on behalf of third party commercial property management services
  • Any special needs of tenants or residents, such as disability information or health history
  • Social insurance number

How is your information used?

Residential Rentals

Prospective tenants are requested to complete a rental application form so that we can assess their suitability as tenants and have necessary basic information should they become tenants. This would include, but not be limited to, the following types of information:

  • Past and current tenancy history
  • Employment history
  • Business and personal telephone and contact information
  • References and conduct history
  • Financial means and credit history
  • Automobile information
  • Intended use of the premises

We may then confirm this information and check references and the conduct history of the prospective tenants. This may include following up with other individuals identified during the course of these inquiries as having relevant information, including a person identified by a reference you provided to us. We may also contact a credit agency and/or a consumer reporting service for information about your suitability. We may also check appropriate public sources such as government, court or tribunal records. By completing a rental application form, you agree to our collecting this information about your suitability to be a tenant.

Retirement Living 

We collect, use and disclose and store personal information about residents at our retirement residences, in order to provide residential, recreational and health care services. This would include the following types of personal information:

  • Your name and contact information
  • Payment and financial information
  • Recreational interests
  • Health card number, social insurance number, medical records, and facts about your health

We use this information to:

  • Provide the services you have requested
  • To serve as a means to communicate with other service providers regarding your care.
  • To monitor the provision of services and evaluate your response to services
  • To meet federal, provincial, or municipal legislated and/or regulated compliance requirements
  • To obtain accreditation with the Ontario Retirement Communities Association and/or other governing bodies

Details regarding how residents’ personal health care information is collected, used and disclosed within  Retirement Living is available by accessing Sifton’s Personal Health Information Protection Act (PHIPA) Policy, at www.sifton.com.

New Home Purchasers

Purchasers of new homes complete a written consent which details the collection, use and disclosure of personal information to financial institutions, marketing, insurance, trades/suppliers, solicitors, government agencies and any other third parties involved in Sifton new home sales and construction process.

Golf Community

Residents of the golf community and club members are advised of the requirements for the collection, use and disclosure of personal information within the gated community as it pertains to security, membership, fitness services, involvement and promotion of committees, special events and other activities, website access and available web services, fee collection, account information review and use of other products and services provided within the community.  We may also require digital photos for identification and security purposes.

Commercial Leasing and Third Party Management

Prospective commercial tenants are required to provide detailed business and/or personal credit information when applying to lease commercial property.  The application will include details of the collection, use and disclosure of the personal information requested that are required by any third parties involved in the property management, financing, amenities, construction and renovations of the leased property.

Express consent may be obtained from individuals in commercial properties to provide a digital photo, for identification and security purposes.  Photos will be accessed exclusively by authorized personnel and will be electronically stored on the password protected security computer equipment.

Public Directories

As a service and convenience for tenants, residents, club members or other customers, we may maintain public directories such as front door directories, phone listings or membership directories. If you do not wish to be listed in any directories or wish to be described in a particular way, please let us know.

General Public Information

For members of the general public, our primary purpose for collecting personal information is to promote the safety of customers, tenants and residents and the enhance the security of the property. For example we, or our clients, may operate security cameras, restrict entry, record license plate numbers, or monitor the presence of vehicles. Security cameras may also monitor the movement and conduct of visitors and others on and about our various properties. We believe that the collection of this information is necessary to support the provision of services and security of the properties and that of our residents, tenants and customers.

Secondly, we may gather personal information in the course of marketing and promoting our property or services to prospective customers, tenants or residents. This information is collected either from appropriate public sources including telephone or service directories, or directly from the individuals, with their consent.  Personal information may also be collected through the operation of video cameras which monitor operations at our properties for marketing purposes.

Government Agencies

Various government agencies have the authority to review our files and interview our staff as a part of their mandates.

If a tenant’s or resident’s rent or fees are paid for by a third party such as an employer, trustee or government agency, we may be asked to provide them with certain information. These third party payers often have consent or legislative authority to direct us to collect and disclose to them certain information in order to demonstrate entitlement to and responsible use of this funding.

Website Information

When you access and use our website we may collect some personal information relative to activities, products and services shown on the website. You may also be providing us with information regarding your financial and employment status to facilitate financing or approval of an application or information about your purchase patterns, personal preferences and demographics. We will use and retain your personal information for the following purposes:

  • To respond to your requests for product information.
  • To complete business transactions with you and to provide appropriate levels of service following the completion of a transaction, such as a suite rental, lease or sale.
  • To share personal information that we collect with other service providers, such as utilities, insurance companies, banking institutions and credit agencies, as well as trades and contractors, etc. who perform various functions to assist in our delivery of service to you.
  • We may also be required to provide personal information to third parties for legal or regulatory purposes or to the owners of properties we are providing management services to.
  • From time to time, we will provide personal information to a third party in order to conduct customer satisfaction surveys.
  • We will use personal information at an aggregate level to improve the quality and efficiency of our products and services and to enhance our marketing efforts.
  • We may share your personal information within Sifton to cross promote products and services which we believe will be of interest to you.

We prohibit the sale, transfer or sharing of personal information with third parties for any other purposes than those identified, without your consent, unless it is required by law.

When we collect personal information from you we will make you aware of the purpose(s) for collecting, using or disclosing the information and obtain your consent in an appropriate fashion consistent with the sensitivity of the information.

Applications for Employment

Personal information collected from resumes and applications for employment received by the Corporation will be used to facilitate the recruiting process.  Candidates who apply electronically through the Corporation’s career site and submit documents must do so in PDF format.  To facilitate this process, the candidate may choose to forward their resume to a third party via the career site, which will transfer the document to PDF format and forward it back to the Corporation for use with the application for employment. 

Although there may or may not be current vacancies, resumes are kept for six months for future consideration. 

Suppliers and Contractors

We often deal with agents, suppliers, contractors and sub-contractors who provide goods, care and services to our customers and assist with maintaining the properties we manage. We monitor their performance, including their promptness, reliability, quality and value of services.

The consultants we use have restricted access to any personal information we hold. We also have their assurance that they follow appropriate privacy principles.

We may disclose limited personal information to suppliers of various services, such as telecommunications service providers, so that they can make available their services to new and existing customers, tenants and residents. 

We may also disclose personal information to insurers, lenders, or prospective purchasers of properties we own or manage.

Protecting Personal Information

We understand the importance of protecting personal information. For that reason, we have taken the following steps:

  • Paper information is either under supervision or secured in a locked or restricted area.
  • Electronic hardware containing personal information is either under supervision or secured in a locked or restricted area at all times. In addition, passwords are used on computers.
  • Paper information is transmitted through sealed, addressed envelopes or boxes by reputable companies.
  • Electronic information is transmitted either through a direct line or is anonymized or encrypted.
  • Staff are trained to collect, use and disclose personal information only as necessary to fulfill their duties and in accordance with our privacy policy.
  • Retirement  Living staff and volunteers are required to sign confidentiality agreements
  • External consultants and agencies with access to personal information must provide us with appropriate privacy assurances.

Retention and Destruction of Personal Information

We need to retain personal information for some time to ensure that we can answer any questions regarding the goods or services provided and for our own accountability to external regulatory bodies.

Tenants, residents, clients or other individuals we deal with may have questions about the goods and services they received. We also provide ongoing services for many tenants, customers and clients over a period of months or years for which the retention of service records is necessary.

We retain information for as long as it is needed for the purposes for which it was collected. We may also be subject to legislative requirements regarding the length of time for retention of certain types of information.

We destroy paper files containing personal information by shredding. We destroy electronic information by deleting it and, when the hardware is discarded, we ensure that the hard drive is physically destroyed or completely reformatted.

Access to Your Personal Information

With some exceptions, you have the right to see what personal information we hold about you. We can help you identify what records we might have about you. We will also try to help you understand any information you do not understand.  We will need to confirm your identity, if we do not know you, before providing you with this access. We reserve the right to charge a nominal fee for such requests.

If there is a problem, we may ask you to put your request in writing. If we cannot give you access, we will tell you within 30 days if at all possible and tell you the reason, as best we can, as to why we cannot give you access.

If you believe there is a mistake in the information, you have the right to ask for it to be corrected. We may ask you to provide documentation that our files are wrong. Where we agree, we will make the correction.

Changes to this Privacy Policy

Sifton Properties Limited reserves the right to change this Privacy Policy from time to time.  We recommend that you periodically review this Privacy Policy, which is posted on our website at www.sifton.com, so that you are aware of any changes.  Any amendments to the Sifton privacy Policy will be effective from the date that it is posted on the Sifton web site. Your continued reading of the policy and use of our site following the posting of any changes to this Privacy Policy shall constitute your acceptance of these changes.

Do You Have a Question?

If you have any questions or concerns about how we collect and share your information, please contact the senior manager at your local Sifton office.

Our Corporate Privacy Information Officer can be reached at:

Sifton Properties Limited
1295 Riverbend Road
London, ON   N6K 0G2
Phone 519-434-1000
Fax 519-434-1009

If you have any questions about this policy and the company’s handling of your personal information, please contact us. We will investigate and respond to your concerns.

This policy is made under the Personal Information Protection and Electronic Documents Act. It is a complex Act and provides some additional exceptions to the privacy principles that are too detailed to set out here. There are some rare exceptions to the commitments set out above.

For more general inquiries, the Information and Privacy Commissioner of Canada oversees the administration of the privacy legislation in the private sector. The Commissioner also acts as a kind of ombudsman for privacy disputes. The Information and Privacy Commissioner can be reached at:

112 Kent Street
Ottawa, ON   K1A 1H3
Phone: (613) 995-8210
Toll-free: 1-800-282-1376
Fax: (613) 947-6850
TTY: (613) 992-9190
www.privcom.gc.ca