2304975 Ontario Ltd.
Privacy of personal information is an important principle to Brennan Harbour RV Park. We are committed to collecting, using and disclosing personal information responsibly and only to the extent necessary for the premises and services we provide. We also try 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 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, electronic address, 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.
Who We Are
Our organization, Brennan Harbour RV Park licenses the use of short and long-term camping sites on our property.
To provide this service, we hire employees and use a number of consultants and agencies that may, in the course of their duties, have access to personal information we hold. These include, but are not limited to, property managers, security, cleaning and maintenance organizations, accountants, lawyers, computer consultants, cleaners, and temporary workers.
We restrict their access to any personal information we hold as much as is reasonably possible. We also have their
assurance that they follow appropriate privacy principles.
We Collect Personal Information: Primary Purposes About Occupants
We collect, use and disclose personal information in order to serve the people we license camping sites to and to manage the properties in our portfolio. For the people we license camping sites to, the primary purpose for collecting personal information is to ensure their safety, security and reasonable enjoyment and that of other persons, to ensure they have access to the premises, equipment and services that we have agreed to provide, to preserve property and to collect fee s. We disclose limited personal information to third party suppliers of services so that they may make available their services to new and existing occupants. We may also disclose personal information to insurers, lenders or prospective purchasers of properties we own or manage. A complete list of persons or business entities to whom your personal information may be provided and who may, in turn, send Commercial Electronic Messages (CEMs) to you is
Examples of the type of information we collect for these purposes includes the following:
- Names of all occupants of the camping site
- Business, personal and emergency contact information
- Use and intended uses of the property
- Compliance with the Occupancy agreement and our rules and regulations
- Payment, banking and other financial information
- Any special needs of persons receiving accommodations (e.g., disability or health) and
- Social insurance number, but only for the purpose of issuing a tax receipt
- For obtaining credit reports
- The amount of fees payable with respect to each license to use
It would be rare for us to collect any personal information without a person’s express consent, but this might occur in a case of urgency (e.g., the person is unavailable), where we believe the person would consent if asked and it is impractical to obtain consent (e.g., information provided by a relative about an absent occupant), appropriate public sources (e.g., government, court or tribunal records) or to investigate a breach of the Occupancy agreement or contravention of the law.
We subscribe to a consumer reporting service. This service provides information to us about prospective occupants. In return, we provide information to the service in order for the service to maintain a databank on a person’s credit history. We collect your full legal name and date of birth to ensure the accuracy of those records. We obtain your consent for using the consumer reporting service in the Consent to Disclosure form.
The information described above and the information set out below about prospective occupants can be collected or updated if the occupant is in arrears of fees or wishes to renew their license to use.
About Prospective Occupants
Prospective occupants are requested to complete an application form so that we can assess their suitability as occupants and have necessary basic information should they stay at our properties. This would include, but not be limited to the following types of information:
- Past and current rental history
- Employment history
- Business and personal telephone, email, and other contact information
- 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 occupants. 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). We may also provide the Applicant’s name or other personal information to a third party service provider, if the Applicant is accepted as an occupant, in order to enable that third party to contact the occupant in regard to the provision of services. By completing an application form and the Consent to Disclosure form you agree to us collecting this information about your suitability to be an occupant. Your information is subject to transfer to Third Parties in the same manner as that set out above in relation to Occupants.
About Members of the General Public
For members of the general public, our primary purpose for collecting personal information is to promote the safety of occupants and the security of property. For example we may operate security cameras and monitor the presence, vehicles and the conduct of visitors and non-occupants on our property. We believe that the collection of this information is implied by the private and recreational nature of our property.
Secondly, we might gather personal information in the course of marketing our property to prospective occupants. This information is collected either from appropriate public sources (e.g., telephone directories) or directly from the individuals with their consent.
On our website, we only collect, with the exception of cookies (electronic markers identifying computers that have previously visited our website), the personal information you provide and only use that information for the purpose you gave it to us (e.g., to respond to your email message, to provide information about our services). Cookies are only used to help you navigate our website and are not used to monitor you.
Suppliers and Contractors
We often deal with suppliers and contractors who provide goods and services to the properties we own and operate. 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, in
appropriate behaviour or comments by a particular representative). We reserve the right to collect this information, use it in deciding upon future services and to disclose it to others involved in related or similar operations.
We may also collect home contact information to reach them in case of emergencies.
About Contract Staff
For people who are contracted to do work for us (e.g., temporary workers), our primary purpose for collecting personal information is to ensure we can contact them in the future (e.g., for new assignments) and for necessary work-related communication (e.g., sending out paycheques, year-end tax receipts, tax filings). Examples of the type of personal information we collect for those purposes include home addresses and telephone numbers. It is rare for us to collect such information without prior consent, but it might happen in the case of an emergency (e.g., an outbreak of a contagious disease) or to investigate a possible breach of law (e.g., if a theft were to occur).
We may transfer your personal information to third parties and servers located within and outside of Canada for the purposes of storage and use with respect to their accounting and maintenance systems, and for the processing of payroll and on-line applications. While this information is outside of the country, it is subject to the laws of the country in which it is held. As such, it may be accessible to law enforcement and national security authorities of that jurisdiction.
We Collect Personal Information: Related and Secondary Purposes
Like most property owners, we also 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.
- To collect fees and accounts from our clients.
- We review occupant, client and other files for the purpose of ensuring that we provide high quality services, including assessing the performance of our consultants, suppliers and staff. In addition, external consultants (e.g., auditors, lawyers, and business consultants) may on our behalf do audits and continuing quality improvement reviews of our operations, including reviewing occupant or client 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 an occupant 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 an occupant’s 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 occupant consent or legislative authority to direct us to collect and disclose to them certain information in order to demonstrate occupant entitlement to and responsible use of this funding.
- Occupants, clients or other individuals we deal with may have questions about the services they received. We also provide ongoing services for many occupants and clients over a period of months or years for which previous records are helpful. We retain occupant and client information for a minimum of two years after the last contact to enable us to respond to those questions and provide these services. You can choose not to be part of some of these related or secondary purposes (e.g., by not having a third party pay your fees). 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, we have taken the following steps:
Paper information is either under supervision or secured in a locked or restricted area.
Electronic hardware is either under supervision or secured in a locked or restricted area at all times. In addition, passwords are used on computers. All of our cell phones are digital, which signals are more
difficult to intercept (however, we still are careful on cell phones because sometimes they switch over to an analog service).
Paper information is transmitted through sealed, addressed envelopes or boxes by our employees or reputable companies.
Electronic information is transmitted either through a direct line or is anonymized or encrypted.
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 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.
We destroy paper files containing personal information by shredding. We remove electronic information when we can if it does not appear that we will be contacting you again. When the hardware is discarded, we ensure that the hard drive is physically destroyed or completely reformatted.
You Can Look at Your Information
With some exceptions, you have the right to see what personal information we hold about you. We ask that, if you choose to exercise this right, you put your request in writing. We reserve the right to charge a nominal fee for such requests. 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 (e.g., short forms, technical language, etc.). We will need to confirm your identity, if we do not know you, before providing you with this access.
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 we collected personal information on behalf of a client we may have conveyed that information directly to the client. If so, we may not have it as a part of our own files and you will have to go to the client to look at the information.
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 that we made a mistake, we will make the correction and notify anyone to whom we sent this information. If we do not agree that we have made a mistake, we will still agree to include in our file a brief statement from you on the point and we will forward that statement to anyone else who received the earlier information.
Use of Video Surveillance and Recordings
Video equipment may be installed and operating in public areas of the property on which your camping site is located. The video equipment may have special capabilities that will allow it to capture sound recordings along with images. Other special capabilities that the video equipment may possess includes, but is not limited to, zoom, facial recognition, or night-vision features. The video equipment may be operating at all times. Surveillance of the video recordings may occur at any time.
The purpose of the use of such equipment is for your safety, security and reasonable enjoyment and that of the other occupants, to ensure you have access to the premises, equipment and services that we or our clients have agreed to provide, to preserve our property, and to deter crime.
Where required by law, signs will be posted informing you that video equipment is operating and recording personal information about you. Also posted on those signs will be the contact information for our Information Officer whom you can contact if you have questions regarding the video recordings or if you wish to have access to recorded images of you.
What is Captured by the Video Recordings
Your image, movements, actions, or other identifiable information about you, may be captured by the video equipment. Where video equipment captures audio recordings, any sounds or communications you make may be recorded.
Retention and Destruction of Personal Information Recorded by Video Equipment
The recordings captured by the video equipment along with the video equipment will be stored in a secured location. Access to the location and recordings is limited. Hardware is either under supervision or secured in a locked or restricted area. Recordings will be kept for a minimum of 5 days before being destroyed.
Use of Audio Equipment and Recordings
There are circumstances under which the Owner/employer may make audio recordings of its employees, contractors, or occupants. There are several purposes for making the recordings; they include: situations where there are work-related performance issues, to ensure the safety of the workplace, to ensure productivity, and to prevent harassment.
Recordings may be made during meetings, interviews, or telephone calls between the employer and an employee. Audio equipment may be operating at other times. Information recorded by the audio equipment may capture communications of any of the following persons:
- the employer, employee, occupants, contractors, and the general public.