Privacy Guidelines

GWL Realty Advisors Inc. and its affiliates, GWL Realty Advisors Residential Inc. and The Canada Life Assurance Company (“GWLRA”) follow the key privacy principles below when collecting, using, or disclosing your personal information.

Accountability

At GWLRA, we are responsible for all personal information under our control. This includes any personal information that is disclosed to a service provider performing services for, or on behalf of GWLRA.

GWLRA, its directors, officers, employees, licensed representatives, and other persons and organizations who act for, or on behalf of, GWLRA are responsible for the protection of your personal information.

Access to personal information is restricted to directors, officers, employees, licensed representatives, and other persons or organizations acting for, or on behalf of, GWLRA, and employees of the landlords of the properties that GWLRA manages who need the information in order to provide services to the prospective tenants and residents, tenants and residents, or GWLRA.

Business Unit Compliance Contact, GWLRA, monitors compliance with these Privacy Guidelines.

We require our service providers to protect your personal information appropriately in a way that is consistent with our Privacy Guidelines and in accordance with applicable laws.

We require our service providers to only collect, use or disclose your personal information in accordance with the authorized purpose.

Personal information may be subject to disclosure to law enforcement officials and other authorities where required by law, both inside and outside of Canada.

Identifying Purposes

We identify the purposes for collecting personal information before, or at the time the information is collected.

Personal information that we collect may be used to:

  • Provide you with GWLRA services and products
  • Process your application for tenancy, your lease, other tenancy interactions
  • Process your payment, i.e. deposit, rental payment
  • Decide your eligibility for tenancy with GWLRA for which you apply
  • Make reference calls or request verification of your employment, history with prior landlords
  • Respond to your questions, comments, inquiries or request for information regarding GWLRA services
  • Send you communications which you have opted-in to receive
  • Administer your tenancy
  • Accommodate special needs, e.g. during emergency evacuation
  • Enforce rental agreement, parking agreement, lease and any other types of client agreements as applicable
  • Create, maintain or administer Profile log-in account, if applicable
  • Tailor your experience on the Online Services
  • Help diagnose technical problems with the Online Services
  • Administer the Online Services
  • Perform internal data management and analytics by GWLRA
  • Meet legal or regulatory requirements
  • Video surveillance, access cards and other information for general security purposes including prevention of potentially prohibited or illegal activities
  • Emergency or incident reporting including video, other surveillance for investigation, insurance and other risk management
  • Employment purposes, including using resumes, and personal references provided in applications of employment and employment forms
  • Perform statistical analysis
  • Enforce website terms of use
  • Communicate with you and administer your participation in surveys, events, programs, and promotions
  • Protect our interests in a civil proceeding or a proceeding involving criminal activity, fraud, or misrepresentation
  • Provide information related to a purchase, sale, reorganization, or financing of all or part of our business or operations, including for due diligence purposes in connection with any such proposed transactions

We may collect your Social Insurance Number (SIN) where required by law for tax-reporting purposes.

In addition, where you provide consent, we may also use your SIN for identification and record-keeping, such as keeping your information separate from other customers and people with similar names. Where you have consented to use of SIN for identification and record-keeping purposes, you can withdraw this consent at any time.

Consent

We collect, use and disclose your personal information with your consent, or as permitted or required by law.

We may collect your consent in different ways. It may be expressed in writing or be implied, provided to us verbally, electronically, or through an authorized representative.

Subject to legal or contractual restrictions, your consent can be withdrawn at anytime; however, withdrawing your consent may impact our ability to continue to provide you with the services you requested.

Where previously provided, you may withdraw your consent to use your SIN for identification and record keeping purposes.

Limiting Collection

We only collect personal information that is necessary for the purposes identified.

Personal information we collect about you may include:

  • Identification information, such as name, residential address, telephone numbers, e-mail address, date of birth, driver’s license, vehicle information, or other identifying information;
  • Financial information, such as place of employment, annual income, banking information; credit card information, credit history;
  • Emergency contact information, such as name, address, telephone number;
  • Health or lifestyle information, such as job, travel history or plans, driving record, or criminal record;
  • Medical information, such as mobility requirements, medical history; or
  • Information that we collect through security systems such as video surveillance tools and access cards.

The personal information we collect is obtained from applications and other forms collected directly from you or through your authorized representative. We may also collect your personal information from credit agencies, employers or personal references, or other third parties who represent that they have the right to disclose the information. In addition, when you visit our Online Services, we may obtain certain information by automated means. We gather data when you interact with our websites and apps as indicated in our Online Privacy Statement.

Use, Disclosure and Retention

We will keep personal information only as long as necessary to fulfill the identified purpose and in accordance with our policies and applicable laws.

We may share your personal information with other companies or individuals to assess applications and service your tenancy but only for the purposes disclosed at the time of collection or for a use consistent with that purpose. We may share your information, including personal information with:

  • Credit reporting agencies for the purposes of assessing your application for tenancy;
  • Financial institutions for the purposes of processing your deposit or rental payment;
  • Law enforcement agencies or governmental agencies as required or permitted by law;
  • Our subsidiaries and affiliates to fulfill their roles as service providers and/or property owners;
  • Owner of a GWLRA managed property and/or Landlord for the purposes of managing your tenancy, and providing statistical analysis and reporting;
  • Vendors or suppliers of utility, cable, satellite and other services and products to provide their services or sell their products to tenants and residents of our buildings with your consent;
  • Prospective lenders, purchasers and their agents, provided that purchasers have entered into a confidentiality agreement;
  • Other third parties with your consent;
  • Our service providers which may be located outside of Canada. In those cases, your personal information will be subject to the laws that apply in those countries, including public authorities access laws.

We may disclose your personal information in order to protect our interests in a civil proceeding or a proceeding involving criminal activity, fraud, or misrepresentation.

We may also disclose your information, including personal information, in the event we sell or transfer all or a portion of our business or assets (including corporate reorganization, merger or amalgamation with another entity, dissolution or liquidation).

We may also disclose your personal information for additional purposes that may be identified at or before the time that the information is collected or disclosed or for new purposes to which you have consented.

GWLRA uses video surveillance to deter crime and protect the safety and security of our tenants, residents and employees. When a crime has occurred, we use and share the video with police to assist police in the ensuing investigation.

Security cameras are placed exclusively in common areas of the property. The recorded images are stored in a secure location at the property which is only accessed by authorized GWLRA employees. The recorded images are kept for up to 180 days before being destroyed.

Any questions regarding video surveillance should be directed to the Business Unit Compliance Contact, GWLRA whose contact information is listed below:

Business Unit Compliance Contact
GWL Realty Advisors Inc.
33 Yonge Street, Suite 1000,
Toronto, ON, M5E 1G4
GWLRACompliance@gwlra.com

Accuracy

We recognize the importance of ensuring that your personal information is accurate and up to date.

We rely on you to provide us accurate information and to contact us about any changes to your personal information. You have the right to ask us to change or correct information we have collected about you. Where your personal information is inaccurate or incomplete, we will make any necessary changes.

Safeguards

We take the protection of your personal information seriously. We use appropriate physical, technical and organizational safeguards to protect your personal information against loss and unauthorized access, use, or disclosure.

All of our employees receive annual information security, privacy, and Code of Conduct training.

We have security standards to protect our systems against unauthorized access and use. Our service providers are required to protect their systems against unauthorized access and apply security standards that are, at a minimum, equivalent to ours. Our service providers are also contractually required to protect and only use your personal information for the purposes authorized by GWLRA.

Openness

This Privacy Guideline, as well as other policies and procedures, are always available to you. Please contact us if you are unable to access our website or require documents in another format.

Upon written request, we will respond to inquiries about our practices relating to the management of personal information. You can contact Business Unit Compliance Contact, GWLRA with any inquiries or complaints.

Individual Access

Upon written request, we will provide you with details regarding your personal information including what information we have about you, and how it has been used and disclosed, subject to certain exceptions permitted by law. You may also request that we correct your personal information. Where we find that the personal information is indeed incorrect, we will update it.

To protect your personal information, all requests for access must be made to us in writing.

Any concern, inquiry or request related to privacy, should be made in writing to Business Unit Compliance Contact, GWLRA using the below contact information:

Business Unit Compliance Contact

GWL Realty Advisors Inc.
33 Yonge Street, Suite 1000,
Toronto, ON, M5E 1G4
GWLRACompliance@gwlra.com

 

Click here for a downloadable PDF version