Privacy Guidelines

GWL Realty Advisors Inc. (“GWLRA”, “we”, “us” or “our”) follows the key privacy principles below when collecting, using, or disclosing your personal information. For the purposes of these guidelines, “personal information” means information about an identifiable individual.

These privacy guidelines, as well as our other public policies and procedures, are always available to you. These guidelines may be changed or updated from time to time, and those changes will be reflected on our websites and are available for download. Please check back often to stay up to date with any changes we’ve made.  

Accountability

At GWLRA, we are responsible for all personal information under our control. This includes any personal information that is transferred to a service provider performing services for, or on behalf of GWLRA. We have established these Privacy Guidelines to keep your personal information safe.

Who is accountable?

Our 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.

Personal information is maintained on our servers or those of our service providers and is accessible by authorized employees, representatives and agents who require access for the purposes described in this Privacy Statement.

The Privacy Officer, 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.

Service providers may 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 permitted or 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.

Consent

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

We may obtain your consent in different ways. It may be expressed in writing or be implied, provided to us verbally, electronically, or through an authorized representative. In some cases, we may rely on a third party to obtain consent on our behalf (for example, your employer).

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. You may withdraw your consent by emailing or writing the Privacy Officer, GWLRA at the contact information listed below.

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

Personal information we collect about you may include:

  • Identification information, such as name, residential or business address, telephone number and e-mail address, vehicle information, or other identifying information;
  • Workplace information, such as employer name and place of employment;
  • Emergency contact information (for you or a person you name as your emergency contact), such as name, address, telephone number;
  • Information submitted in connection with a job application, including qualifications, career experience and educational background;
  • Medical information, such as mobility or other requirements in the event of an emergency;
  • Information that we collect through security systems or other building systems such as video surveillance cameras, people counting tools, access card systems, amenity, room and elevator booking systems, tenant portals, mobile applications, digital offerings and similar systems and tools;
  • Information we collect at events including photographs and videos.

In addition, we may collect other information as described to you at the time of collection or through a separate privacy notice (for example, our Online Privacy Statement).

How we collect your personal information

The personal information we collect is obtained directly from you or your authorized representative, or indirectly, for example, from your employer or through our systems and tools. 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, apps and other Online Services as indicated in our Online Privacy Statement.

Examples of how we may use your personal information

GWLRA collects personal information to manage properties on behalf of landlords and property owners. In particular, personal information that we collect may be used to:

  • Provide you with GWLRA services and products
  • Conduct “know your client” and related screenings in connection with an application for commercial tenancy
  • Process payments
  • Respond to your questions, comments, inquiries or requests for information
  • Send you communications which you have opted-in to receive
  • Administer and enforce the commercial tenancy agreement and any related agreements
  • Accommodate special needs, e.g. during emergency evacuation
  • Enforce our agreements with you, such as parking agreements or amenity memberships
  • Create, maintain or administer your account for Online Services
  • Tailor your experience on the Online Services
  • Help diagnose technical problems with the Online Services
  • Administer the Online Services
  • Perform data management and analytics
  • 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
  • Statistical analysis
  • Enforce website terms of use
  • Market and promote our buildings, amenities, services and business generally
  • Communicate with you and administer your participation in surveys, sweepstakes, events, programs, and promotions
  • To protect our interests in a civil proceeding or a proceeding involving criminal activity, fraud, or misrepresentation
  • To evaluate, complete or administer a purchase, sale, reorganization or financing of all or a part of our business or assets.

We may use personal information for other purposes identified to you at the time of collection, or in a separate privacy notice (for example, our Online Privacy Statement). 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.

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 for the purposes described below or otherwise at the time of collection.

  • Credit reporting agencies for the purposes of assessing your application for tenancy;
  • Financial institutions and payment processors for the purposes of processing payments;
  • 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 the commercial tenancy, and providing statistical analysis and reporting;
  • Third party operators of amenities or facilities in or otherwise associated with the buildings we manage for purposes relating to the management and operation of such amenities or facilities;
  • Prospective lenders, purchasers and their agents, provided that purchasers have entered into a confidentiality agreement;
  • Other third parties with your consent.

We may work with service providers 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 use or disclose your personal information in connection with an investigation or civil or criminal proceeding, or to detect, prevent or investigate any unlawful or unauthorized activity, including fraud or breach of an agreement.

In addition, we may disclose your information, including personal information, if we sell or transfer all or a portion of our business or assets. For example, in the event of a corporate reorganization, merger or amalgamation with another entity, dissolution or liquidation. Your information may also be transferred to a successor property manager designated by the landlord or owner of your building.

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, in accordance with a specific privacy notice (for example, our Online Privacy Statement) or for new purposes to which you have consented. We may disclose personal information where required by law.

GWLRA uses video surveillance to deter crime and protect the safety and security of our tenants as well as of our and their employees, workers and visitors. Security cameras are placed exclusively in common areas of the property. When a crime occurs, we use and share the video with police to assist them in the ensuing investigation and may also share the video with a commercial tenant. In some buildings, workers may be able to access certain surveillance cameras through mobile applications or other digital tools.

Any questions regarding video surveillance should be directed to the Privacy Officer, GWLRA using the contact information provided at the end of this Statement.

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.

How we protect your personal information

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 the Privacy Officer, GWLRA with any inquiries or complaints.

Individual Access, Correction and Deletion

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. In certain circumstances, you may also have the right to request that your personal information be deleted.

To protect your personal information, all requests for access, correction or deletion must be made to us in writing using the below contact information.

Have any Concerns, Inquiries or Requests?

Email or write to our Privacy Officer, GWLRA, about any privacy concern, inquiry, or request.

Privacy Officer
GWL Realty Advisors Inc.
Suite 1000, 33 Yonge Street | Toronto, Ontario, Canada | M5E 1G4
gwlra_privacy@gwlra.com

 

Click here for a downloadable PDF version

 

Revised September 2022