PRIVACY POLICY
VOTER PRIVACY POLICY
LAST UPDATED: December 22, 2021
CondoVoter is dedicated to the protection of the personal information of voters, be they owners or proxy holders, and any other individuals who provide us with their personal information.
Policy Contents:
- Accountability for Your Privacy
- Personal Information and How We Collect It
- Obtaining Your Consent
- Purposes for Collecting and Using Your Information
- Sharing Your Information
- Keeping Your Information Safe
- Accessing Your Personal Information
- How Long We Keep Your Information
- Our Privacy Complaint and Breach Management Process
- Changes to this Policy and Getting in Touch
1. Accountability for Your Privacy
CondoVoter takes full responsibility for the management and confidentiality of personal information provided to us by our clients, being condominium corporations. Personal information is collected, used, shared and stored in accordance with all applicable privacy and condominium laws that apply to CondoVoter, as well as the best practice principles contained in the Canadian Standards Association Model Code for the Protection of Personal Information, CAN/CSA-Q830-96.
CondoVoter has appointed a Privacy Officer who oversees compliance with privacy laws and best practice. The Privacy Officer’s duties include:
- Developing and, on a regular basis, reviewing CondoVoter policies and practices to ensure consistent implementation and compliance;
- Ensuring all staff are trained on privacy best practices and are aware of the importance of safeguarding any personal information that they are privy to;
- Ensuring that all inquiries and complaints relating to privacy are appropriately handled; and
- Ensuring all third parties to whom CondoVoter provides access to personal information adhere to appropriate standards of care in managing that
2. Personal Information and How We Collect It
‘Personal information’ is any information about an identifiable individual, including a voter’s name, e-mail address, unit number, as well as whether a unit is owner-occupied or in arrears. An IP address from which voting takes place, the date/time stamp of a vote, a phone number (for telephone voters) and whether an e-mail sent from our system such as a ballot, meeting invitation or reminder has been opened, is also personal information collected by CondoVoter. We collect limited personal information to service condominium corporations.
Aggregate or de-identified information that cannot be associated with a specific individual, such as statistics on voter participation or meeting attendance, is not personal information.
Personal information can be collected in several ways, including when a property manager uploads a voter list, when a proxy form is completed, or in the context of a support call or e-mail. We identify when information may be provided optionally and when it is necessary in order to service you.
Although much of the voter information collected by CondoVoter is done so indirectly (i.e. your information is provided by your property manager), your personal information will be respected in exactly the same way as if we collected it from you personally and directly.
3. Obtaining your Consent
CondoVoter acts as a third party service provider to condominium corporations who have obtained express or implied consent to collect, use and disclose your personal information, except as otherwise required or permitted by law. CondoVoter relies on this consent being lawfully obtained by our clients, and has no legal obligation to obtain further consent to the collection or use of your personal information. Should you have any concerns about consent or wish to withdraw consent, such a request must be directed to your condominium corporation, and may be subject to legal or contractual restrictions.
Note that there may be instances where the law permits the collection, use or disclosure of your personal information without your consent, for example in the context of fraud investigations or to protect the legal interests of our clients. For example, we may be required to disclose or retain a voter’s personal information without consent to comply with a court order.
4. Purposes for Collecting and Using Your Information
Personal information is collected and used by CondoVoter for one or more of the following specific purposes:
- Administer and facilitate electronic voting and virtual meetings for condominium corporations;
- Provide support, such as assisting individuals with process related questions or technical difficulties;
- Improve our services and programs;
- Promote our services and tailor our offerings with the objective of meeting our clients’ needs;
- Confirm unique votes or investigate complaints;
- Assess and manage risk, including detecting and preventing fraud or error;
- Internal and external audits;
- meet legal and regulatory processes and requirements, or bring or defend against legal actions;
- such other purposes permitted or required by law.
5. Sharing Your Information
Your personal information is shared only to the extent required to provide you with our services; to support professional excellence and transparency; and to comply with legal requirements. For example, we may disclose your personal information to a court, administrative tribunal, governmental authority or other investigative body who is authorized to compel the disclosure of your personal information and has identified their lawful authority.
In addition, personal information may be transferred or made accessible to CondoVoter’s agents and third party service providers who assist us in carrying out our business and providing you with our services. These trusted entities have agreed to comply with strict privacy and confidentiality obligations. Such transfers of data for processing may occur in the context of payment processing; IT managed services; software development; or end user support. Please note that in the context of any of these outsourcing arrangements, your personal information may be processed or stored outside of Canada. Such information may be provided to law enforcement or national security authorities of the foreign jurisdiction upon request, in order to comply with foreign laws. We take reasonable steps to ensure that any such third parties who we entrust with your personal information are reputable, and have safeguards in place to protect your information.
Note that in the context of electronic voting, CondoVoter never shares your ballot choices or the IP address from which you have voted with your property manager.
6. Keeping Your Information Safe
CondoVoter acknowledges that a data security breach could result in potential harm to individuals whose personal information is entrusted to CondoVoter. Thus, we have implemented critical physical, organizational and technical measures to guard against unauthorized or unlawful access to the personal information we manage and store. We have also taken steps to avoid accidental loss or destruction of, or damage to, your personal information. While no system is completely secure, the measures implemented by CondoVoter significantly reduce the likelihood of a data security breach.
Here are some examples of the security controls we have in place:
- Voters receive tokenized links for secure and verifiable electronic voting;
- Your property manager can upload voter lists seamlessly using a secure admin portal;
- We use sophisticated cloud providers (Amazon Web Services) with data centres that offer state-of-the-art physical and logical data security controls;
- Data is appropriately encrypted in transit and at rest; firewalls, anti-virus programs and robust authentication processes, including complex passwords, reduce the risk of unauthorized access to electronic records;
- Paper records, such as mailed in paper proxies that are converted to electronic votes, are securely stored under lock-and-key.
- Our limited paper records are securely shredded when being destroyed;
- Access to personal information by CondoVoter employees is limited based on who needs this information to perform their work-related duties; and
- We undertake regular reviews of privacy compliance and data security best practices.
In addition, we recommend that you do your part in protecting yourself from unauthorized access to your personal information. For example, ensure your e-mail cannot be accessed by others without authorization. CondoVoter is not liable for any unauthorized access to your personal information or voting/meeting participation that is beyond our reasonable control.
7. Accessing Your Information
We make every effort to ensure that the personal information contained in records that we control or have custody over is accurate, complete and up-to-date for the purposes for which we collect it. You can make a written request to your property manager for access to your personal information at any time, and they will get in touch with us to assist in a timely manner.
You will need to provide as much information as you can to help us process your request and locate the information you require. As we take your privacy seriously, we will take reasonable steps to verify your identity before granting access or making corrections, updates or deletions to your personal information. Upon written request, CondoVoter will also inform individuals of how their personal information has been or is being used, and who it has been shared with.
8. How Long We Keep Your Information
CondoVoter retains personal information for as long as necessary to fulfill legal or business purposes and in accordance with our record retention schedules. For example, voting results are maintained to ensure votes can be re-tallied if needed, but voter data is purged altogether after our maximum retention timeline of two (2) years. CondoVoter may be subject to specific contractual or legal requirements to maintain personal information as well, in which case necessary exceptions to our retention schedules will be applied.
Once your information is no longer required by CondoVoter to administer our services and meet business, contractual, legal or regulatory requirements, it is securely destroyed, erased or made anonymous. Keep in mind however that residual information may remain in back-ups for a period of time after its destruction date.
9. Our Privacy Complaint and Breach Management Process
CondoVoter takes privacy complaints very seriously and has a procedure in place for escalating and managing any privacy related concerns to ensure that they are responded to in a timely and effective manner. Any suspected privacy breach, whether identified by us or one of our condominium corporation clients, will be escalated internally to CondoVoter’s Privacy Officer who oversees the containment, investigation and corrective actions for a breach situation.
10. Changes to this Policy and Getting in Touch
We may change this Privacy Policy from time to time in order to better reflect our current personal information handling practices. Thus, we encourage you to review this document frequently. The “Last Updated” date at the top of this Privacy Policy indicates when changes to this policy were published and are thus in force.
Any inquires, concerns or complaints regarding privacy should be directed to your property manager or by contacting us directly:
Privacy Officer, CondoVoter
Email: privacy@condovoter.com
Your concerns will receive prompt attention. Our Privacy Officer can also provide you with detailed information about CondoVoter’s policies and practices. Keep in mind however that e-mail is not a secure form of communication, so never send confidential personal information to us this way.
At CondoVoter, your privacy is of great importance to us.
