WHO WE ARE
Universal Realty Group is involved in the development and management of commercial and residential real estate with a reputation for building excellence in Halifax, Nova Scotia. Our portfolio consists of over 2,300 apartments, 1.5 million square feet of commercial space and Halifax's beloved landmark hotel, Lord Nelson Hotel & Suites. We use a number of consultants, agencies, and staff that may, in the course of their duties, have limited access to the personal information we hold. These include building superintendents, security, concierge, cleaning and maintenance companies, bookkeepers and accountants, computer consultants, and lawyers. We restrict their access to any personal information we hold as much as is reasonably possible. We in turn have their assurance that they follow appropriate privacy principles.
WHAT IS PERSONAL INFORMATION?
Personal information is information about an identifiable individual. Personal information includes information that relates to their personal characteristics (e.g., gender, age, income, home address or phone number, family status), their health (e.g., disabilities) or their activities and views (e.g., religion, politics, opinions expressed by an individual, opinions about an individual). Personal information is to be contrasted with business information (e.g., an individual’s business address and telephone number), which is not protected by privacy legislation.
COLLECTING PERSONAL INFORMATION: PRIMARY PURPOSES
We collect, use and disclose personal information solely in order to serve our tenants. The primary purpose for collecting personal information is to ensure their safety, security and reasonable enjoyment and that of the other residents. As well, to ensure they have access to the premises, equipment and services, to preserve our property and to collect rents and other fees. Examples of the type of information we collect for these purposes include the following:
- Names of all occupants of units, parking spaces, lockers, etc.
- Business and emergency contact information
- Vehicle information
- Use and intended uses of the property
- Compliance with tenancy agreements and rules and regulations
- Payment, banking and other financial information
- Any special needs of tenants (e.g., disability or health)
It would be rare for us to collect any personal information without the resident’s express consent, but this might occur in a case of urgency to investigate a breach of the tenancy agreement or contravention of the law.
RESIDENTIAL / COMMERCIAL RENTAL PROPERTIES
We subscribe to a consumer reporting (credit check) service. This service provides information to landlords about prospective tenants. In return, we provide information to the service in order for the service to maintain a databank on a tenant’s history. We collect full legal name and date of birth to ensure the accuracy of those records. Having a good tenant history filed with the service will make it easier for you to be accepted as a tenant at other properties in the future.
The information described above and the information set out below about prospective tenants can be collected or updated if the tenant is in arrears of rent or fees or wishes to renew a tenancy agreement.
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 the following types of information:
- Past tenancy history
- Employment history
- References and conduct history
- Financial means and credit history
- Automobile information and
- Intended use of the premises
We will then confirm this information and check references and the conduct history of the prospective tenants. This might include following up with other individuals identified during the course of these inquiries as having relevant information (e.g., 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 might also check appropriate public sources (e.g., government, court or tribunal records). By completing a rental application form you agree to us collecting this information about your suitability to be a tenant.
SUPPLIERS AND CONTRACTORS
We often deal with suppliers and contractors who provide goods and services to the Universal properties. We monitor their performance, including their promptness, reliability, quality and value of services. Most of this information is business information and would not be covered by privacy legislation. However, occasionally, this information relates to the conduct of an individual (e.g., skill of a particular employee of a supplier or contractor, inappropriate behaviour or comments by a particular representative). We reserve the right to collect this information, use it in deciding upon future services. We may also collect home contact information to reach them in case of emergencies.
COLLECTING PERSONAL INFORMATION: RELATED AND SECONDARY PURPOSES
We collect, use and disclose information for purposes related to or secondary to our primary purposes. The most common examples of our related and secondary purposes are as follows:
- To collect fees or rents.
- To collect fees and accounts.
We review resident and other files for the purpose of ensuring that we provide high quality services, including assessing the performance of our contractors, suppliers and staff. In addition, external consultants (e.g., auditors, lawyers, business consultants) may on our behalf do audits and continuing quality improvement reviews of our operations, including reviewing tenant files and interviewing our staff.
Various government agencies (e.g., Canada Customs and Revenue Agency, Information and Privacy Commissioner, Human Rights Commission, etc.) have the authority to review our files and interview our staff as a part of their mandates. Also, we believe that we should report information suggesting serious illegal behaviour to the authorities. These reports could include personal information about a tenant or other individual to support the concern (e.g., illegal drug activity), although we try to keep this disclosure to a minimum. In these circumstances, we may consult with professionals (e.g., lawyers, a private security service) who will investigate the matter and report back to us.
If a resident’s rent or fees are paid for by a third party (e.g., employer, your trustee, the government) we may be asked to provide them with certain information. These third party payers often have tenant consent or legislative authority to direct us to collect and disclose to them certain information in order to demonstrate tenant entitlement to and responsible use of this funding.
We retain tenant information for a minimum of five years after the last contact to enable us to respond to questions and provide services.
You can choose not to be part of some of these related or secondary purposes (e.g., declining to receive our newsletter). We do not, however, have much choice about some of these related or secondary purposes (e.g., external regulation).
PROTECTING PERSONAL INFORMATION
We understand the importance of protecting personal information. For that reason, Universal Realty Group has taken measures to protect the security and confidentiality of personal information as are appropriate in the circumstances. However, any information transmitted via the Internet may be intercepted by third parties. Universal Realty Group does not assume any liability for interception, alteration or misuse of information transmitted over the Internet.
RETENTION AND DESTRUCTION OF PERSONAL INFORMATION
We need to retain personal information for some time to ensure that we can answer any questions you might have about the services provided and for our own accountability to external regulatory bodies. However, we do not want to keep personal information too long in order to protect your privacy.
At such time as personal information is no longer required for the purposes stated herein or other statutory requirements, such personal information will be made anonymous or destroyed.
Upon request, you have the right to see what personal information we hold about you. Tenants may verify the accuracy and completeness of their information, and may request that it be amended, if appropriate.
Should you wish access to your personal information, we would ask that you make your request in writing to Universal Realty Group Property Manager, stating specifically which information you are requesting. We will try to respond to your request as soon as possible. We may charge you a reasonable fee for administering your request, but only after first advising you of the approximate cost.
Universal Realty Group reserves the right to confirm the identity of the persons seeking access to personal information before complying with any requests.
COMMENTS AND QUESTIONS
Any comments or questions about this Statement, should be addressed to Universal Realty Group as follows:
4th Floor 1190 Barrington Street
Halifax, Nova Scotia, Canada, B3H 2R4
Phone: 902.425.8877, Fax: 902.429.9952