Purpose of the Policy:
The CRA takes its obligations under PIPEDA seriously and would like to take all reasonable steps in order to comply with the Act and protect the privacy of the personal information that we hold. This policy sets out how we intend to do so.
The personal information that the Association collects:
The CRA collects and holds the following personal information:
- Your name and business name
- Current address, email, telephone numbers and related contact details
- Other – Industry details
The CRA takes all reasonable steps to ensure that the personal information that we hold is accurate and up-to-date. If you feel that information about you is not accurate or your details have or are about to change, please inform us and we will update your personal information.
Why we collect it:
The CRA collects, uses and discloses the information in accordance with the Collection Statement.
Access to your personal information:
The CRA provides access to the personal information that we hold about you. Access will be provided in accordance with our Access Policy. If you require access to your personal information please contact our Executive Director at 1.800.486.9899.
If you have any complaints about our privacy practices or wish to make a complaint about how your personal information is managed please contact our Executive Director. Complaints will be handled under the CRA’s Privacy Complaints Policy.
We will take all reasonable steps to protect the security of the personal information that we hold. This includes appropriate measures to protect electronic materials and materials stored and generated in hard copy.
The CRA endorses fair information handling practices. Any information provided, including identification of individuals, will be used only for the purpose intended and where the intention includes confidentiality, information will be retained as such unless otherwise required by law.
We do not contract out data storage or processing functions. On occasion we may employ other companies to perform functions on our behalf, such as mailing distributions. In these instances we ensure appropriate confidentiality procedures are in place to protect your privacy and provide them only with the information required to perform their function.
The personal information collected is collected by the Canadian Rental Association and the American Rental Association. (CRA)
The information is collected for the purpose of:
- Providing you with our membership services,
- Administration purposes including processing payments and collecting debts,
- We may also collect information from time to time to assist with providing members with services and additional benefits e.g. Conventions, training courses, financial and insurance services etc.
The CRA will usually disclose this information to:
- Our insurer’s
- Related Associations
Any information provided to CRA is used only for the provision of services to its members. It is not provided to any other third party except where necessary to provide our primary services, where required to do so by law or where your consent has been provided. In order to provide some services, products are offered in conjunction with third party partners. When you specifically request information or purchase such products, some personal information is shared with them so that they can provide the stated service.
We collect the information in order to comply with our legal obligations.
What happens if you choose not to provide information:
You are not obliged to give us your personal information. However, if you choose not to provide the CRA with certain personal details such as name address and contact details we may not be able to provide you with the full range of our services.
You can gain access to the personal information that the CRA holds about you. If you wish to do so please refer to our Access Policy or contact Executive Director at 1.800.486.9899.
Sources of information:
Where possible the CRA will collect information directly from the member.
If the personal information was collected not from the member but from another party, such as the ARA, the CRA will take reasonable steps to inform that individual of the Collection and provide the above Collection Statement.
Visitor logs are used on the CRA Website for statistical purposes only. No attempt will be made to identify specific users or their browsing activity. De-identification data from these logs may be used to update and improve the CRA site.
Email addresses provided via this site will only be used to respond to specific user queries and will not be added to any mailing lists, nor disclosed to any other party without users’ knowledge and consent and as intended, unless required by law.
This policy is directed to those individuals whose personal information is held by the Canadian Rental Association (CRA).
At all times the conduct under this Policy will be governed by the following principles:
- All requests for access will be treated seriously
- All requests will be dealt with promptly
- All requests will be dealt with in a confidential manner
- Your request to access your personal information will not effect your existing obligations or effect the commercial arrangements between you and the CRA.
Form of Access:
The CRA will provide access by allowing you to inspect, take notes of or receive copies or print outs of the personal information that the CRA holds about you.
You can request access to your personal information by contacting: The Executive Director, The Canadian Rental Association, 848 Jubilee Avenue, Winnipeg, MB – R3L 1P9 1.800.486.9899
To obtain access you will have to provide proof of your identity. This is necessary to ensure that personal information is provided only to the correct individuals and that the privacy of others is not undermined.
When will Access be denied:
Access will be denied if:
- The request does not relate to the personal information of the person making the request;
- Providing access would pose a serious and imminent threat to life or health of a person;
- Providing access would create an unreasonable impact on the privacy of others;
- The request is frivolous and vexatious;
- The request relates to existing or anticipated legal proceedings;
- Providing access would prejudice negotiations with the individual making the request;
- Access would be unlawful;
- Denial of access is authorized or required by law;
- Access would prejudice law enforcement activities;
- Access discloses a ‘commercially sensitive’ decision making process or information; or
- any other reason that is provided for in the Personal Information Protection and Electronic Documents Act or set-out in the Privacy Act.
Where possible, the CRA will favour providing access. It may do so by providing access to the appropriate parts of the record or by using an appropriate ‘intermediary’.
Where there is a dispute about the right or forms of access these will be dealt with in accordance with the CRA’s Complaints Policy, grievance procedure.
We will take all reasonable steps to provide access within 30 days of your request. In cases where the request is not complicated or does not require access to a large volume of information, we will provide information within 14 days.
Costs and charges:
The CRA may impose the following charges:
- Photocopying – [$1 per sheet]
- Delivery cost of information stored off-site – where information is stored off-site, the cost of obtaining access to the information [TBD]
- Access to electronic databases – [TBD]
Privacy Complaints: How we handle privacy complaints
The Canadian Rental Association (CRA) sees the importance of privacy to the Association, its members and other stakeholders. As such the CRA is committed to protecting the privacy of the personal information that we hold. This is part of our Associations:
- Legal obligations under the Privacy Act 1985 and the Personal Information Protection and Electronic Documents Act 2004 – and as subsequently amended
- Ethical and business obligations
- Service to you
The CRA places high priority on effectively dealing with any complaints regarding privacy that you may have.
At all times the conduct under this policy will be governed by the following principles:
- All complaints will be treated seriously,
- All complaints will be dealt with promptly,
- All complaints will be dealt with in a confidential manner,
- The privacy complaint will not effect your existing obligations or the commercial arrangements that exist between this Association and you.,
Who may complain under this policy:
If you have provided us with personal information you have a right to make a complaint, have it investigated and dealt with under this policy.
What is a privacy complaint:
A privacy complaint relates to any concern or dispute that you have with our privacy practices as it relates to your personal information. This could include matters such as:
- (a) How personal information is collected,
(b) How personal information is stored,
(c) How this information is used or disclosed,
(d) How access is provided.
What do I do if I have a complaint about privacy practices:
The CRA resolves grievances at the local level if possible. If you have a complaint about privacy please contact: The Executive Director, The Canadian Rental Association, 848 Jubilee Avenue, Winnipeg, MB – R3L 1P9 1.800.486.9899
All complaints will be logged on a database/complaints register.
You may complain orally or in writing. Usually your contact with the Association will be with the Executive Director who is the proper person to discuss or resolve your complaint, however, if your privacy complaint is still not resolved the matter will then be referred to the National Board of Directors.
The goal of this policy is to achieve an effective resolution of your complaint within a reasonable timeframe.
Once the complaint has been made, the point of contact can then resolve the matter in a number of ways:
- 1. Request further information and investigation: Your initial contact may request further information from you. You should be prepared to give as many details as possible including details of any relevant dates and documentation. This will enable the contact to investigate the complaint and determine an appropriate and useful solution. All details provided will be kept confidential. The complaint may be investigated. It may be necessary to contact others in order to proceed with the investigation. This may be necessary in order to process your complaint.
2. Discuss options: We will discuss options for resolution and if you have suggestions about how the matter might be resolved you should discuss these with your contact. The contact could also suggest other solutions or give examples of how the personal information can be revised or stored in a different way.
3. Resolution: You will be informed of the outcome and the reasons for the decision. If this does not resolve the complaint, the matter will be referred to a mutually agreed intermediary.
4. If after the above steps have been followed you are still dissatisfied with the outcome you may refer the complaint to the federal Office of the Privacy Commissioner.
The Association will keep a record of your complaint and the outcome.
The CRA is unable to deal with anonymous complaints as we are unable to investigate properly and follow-up such complaints.
However, in the event that an anonymous complaint is received the CRA we will note the issues raised and try and resolve them appropriately.
For any further information about this policy please contact:
The Executive Director, The Canadian Rental Association,
848 Jubilee Avenue, Winnipeg, MB R3L 1P9 1.800.486.9899