At HighStreet Accommodations, we are committed to providing our clients and residents with exceptional service and accommodations. As providing this service involves the collection, use, and disclosure of certain personal information, protecting the personal information of our clients and residents is one of our highest priorities.
While we have always respected the privacy of our clients and residents, we have strengthened our commitment to protecting personal information as a result of British Columbia’s Personal Information Protection Act (“PIPA”).
We will inform our clients and residents of why and how we collect, use, and disclose their personal information, obtain their consent where required, and only handle their personal information in a manner that a reasonable person would consider appropriate in the circumstances.
This Personal Information Protection Policy, in compliance with PIPA, outlines the principles and practices we will follow in protecting clients’ and residents’ personal information. Our privacy commitment includes ensuring the accuracy, confidentiality, and security of our clients’ and residents’ personal information and allowing our clients, customers, members to request access to, and correction of, their personal information.
Personal Information – means information about an identifiable individual. For example, at a move-in, HighStreet’s Resident Services Representative will use the Resident Registration Card to collect basic personal information including first and last names, home address, and home telephone number or personal mobile number. Under PIPA, Personal Information does not include Contact Information (described below).
Contact Information – means information that would enable an individual to be contacted at a place of business and includes name, position name or title, business telephone number, business address, business email or business fax number. Contact information is not covered by this policy or PIPA.
Privacy Officer – means the individual designated responsibility for ensuring that HighStreet Accommodations complies with this policy and PIPA.
Policy 1 – Collecting Personal Information
1.1 Unless the purposes for collecting personal information are obvious and the client or resident voluntarily provides his or her personal information for those purposes, we will communicate the purposes for which personal information is being collected, either orally or in writing, before or at the time of collection.
1.2 We will only collect client or resident information that is necessary to fulfill the following purposes:
- To verify identity. To verify identity, we may ask to view a resident’s driver’s license, BC ID card, or passport to confirm identity against the information provided with the reservation;
- To identify client or resident preferences;
- To understand the accommodation needs of our clients and residents;
- To deliver requested accommodations and related services;
- To ensure a high standard of service to our clients and residents;
- To verify creditworthiness. To verify creditworthiness, we may ask for a valid credit card number against which we will process a temporary pre-authorization in the amount of $500.
Policy 2 – Consent
2.1 We will obtain client and/or resident consent to collect, use, or disclose personal information (except where, as noted below, we are authorized to do so without consent).
2.2 Clients and/or residents can provide consent orally, in writing, electronically, through an authorized representative, or consent can be implied where the purpose for collecting using or disclosing the personal information would be considered obvious and the client and/or resident voluntarily provides personal information for that purpose.
2.3 Consent may also be implied where a client or resident is given notice and a reasonable opportunity to opt-out of his or her personal information being used for mail-outs, the marketing of new services or products, fundraising and the client or resident does not opt-out.
2.4 Subject to certain exceptions (e.g., the personal information is necessary to provide the accommodations and related services the client or resident has purchased from us, or the withdrawal of consent would frustrate the performance of a legal obligation), clients and residents can withhold or withdraw their consent for HighStreet Accommodations to use their personal information in certain ways. A client’s or resident’s decision to withhold or withdraw their consent to certain uses of personal information may restrict our ability to provide a particular service or product. If so, we will explain the situation to assist the client or resident in making the decision.
2.5 We may collect, use or disclose personal information without the client’s or resident’s knowledge or consent in the following limited circumstances:
- When the collection, use or disclosure of personal information is permitted or required by law;
- In an emergency that threatens an individual’s life, health, or personal security;
- When the personal information is available from a public source (e.g., a telephone directory);
- When we require legal advice from a lawyer;
- For the purposes of collecting a debt;
- To protect ourselves from fraud; and
- To investigate an anticipated breach of an agreement or a contravention of law
Policy 3 – Using and Disclosing Personal Information
3.1 We will only use or disclose client or resident personal information where necessary to fulfill the purposes identified at the time of collection.
3.2 We will not use or disclose client or resident personal information for any additional purpose unless we obtain consent to do so.
3.3 We will not sell client or resident member lists or personal information to other parties.
Policy 4 – Retaining Personal Information
4.1 If we use client or resident personal information to make a decision that directly affects the client or resident, we will retain that personal information for at least one year so that the client or resident has a reasonable opportunity to request access to it.
4.2 Subject to policy 4.1, we will retain client and resident personal information only as long as necessary to fulfill the identified purposes or a legal or business purpose.
Policy 5 – Ensuring Accuracy of Personal Information
5.1 We will make reasonable efforts to ensure that client and resident personal information is accurate and complete where it may be used to make a decision about the client and resident or disclosed to another organization.
5.2 Clients and residents may request correction to their personal information in order to ensure its accuracy and completeness. A request to correct personal information must be made in writing and provide sufficient detail to identify the personal information and the correction being sought. A request to correct personal information should be forwarded to the Privacy Officer.
5.3 If the personal information is demonstrated to be inaccurate or incomplete, we will correct the information as required and send the corrected information to any organization to which we disclosed the personal information in the previous year. If the correction is not made, we will note the clients’ or residents’ correction request in the file.
Policy 6 – Securing Personal Information
6.1 We are committed to ensuring the security of client and resident personal information in order to protect it from unauthorized access, collection, use, disclosure, copying, modification or disposal or similar risks.
6.2 At HighStreet Accommodations, the following security measures are followed to ensure that client and resident personal information is appropriately protected:
- Physically secured office premises where personal information is held, including the use of locked offices and locked filing cabinets;
- The use of user IDs, passwords, encryption, and firewalls;
- The use of a private, local server and network (i.e. no cloud storage or cloud-based services); and
- The restriction of employee access to personal information as appropriate, so that only those that need to know will have access.
6.3 We will use appropriate security measures when destroying clients’ and residents’ personal information such as shredding documents and permanently deleting electronically stored information.
6.4 We will continually review and update our security policies and controls as technology changes to ensure ongoing personal information security.
Policy 7 – Providing Clients and Residents Access to Personal Information
7.1 Clients and residents have a right to access their personal information, subject to limited exceptions.
7.2 A request to access personal information must be made in writing and provide sufficient detail to identify the personal information being sought. A request to access personal information should be forwarded to the Privacy Officer.
7.3 Upon request, we will also tell and residents how we use their personal information and to whom it has been disclosed if applicable.
7.4 We will make the requested information available within 30 business days, or provide written notice of an extension where additional time is required to fulfill the request.
7.5 A minimal fee may be charged for providing access to personal information. Where a fee may apply, we will inform the client or resident of the cost and request further direction from the client or resident on whether or not we should proceed with the request.
7.6 If a request is refused in full or in part, we will notify the client or resident in writing, providing the reasons for refusal and the recourse available to the client or resident.
Policy 8 – Service Providers
8.1 We use certain Google Analytics advertising features, including demographics and audience targeting tools, which are part of Google’s web analytics service that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our website. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.
8.3 For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: http://www.google.com/intl/en/policies/privacy/
8.4 For more information about how Google uses information from other websites or apps that use Google’s services, please see: https://policies.google.com/technologies/partner-sites
Policy 9 – Questions and Complaints: the Role of the Privacy Officer
9.1 The Privacy Officer is responsible for ensuring HighStreet Accommodations’ compliance with this policy and the Personal Information Protection Act.
9.2 Clients and residents should direct any complaints, concerns or questions regarding HighStreet Accommodations’ compliance in writing to the Privacy Officer. If the Privacy Officer is unable to resolve the concern, the client, customer, member may also write to the Information and Privacy Commissioner of British Columbia.
General Data Protection Regulation (GDPR) Compliance Statement
Under the GDPR, HighStreet Accommodations is both a data controller and also a data processor, meaning our clients provide us with the personal data we need to provide our accommodations and related services. We are responsible for the personal data that we collect and we take care that data is accurate, kept up to date, and removed when no longer necessary.
We are committed to:
-Transparency with regard to the use of data;
-Lawful, fair, transparent, and necessary processing of the data provided to us for a specific purpose; and
-Safe, secure storage of data while it is being used.
GDPR compliance and Google Analytics
When we collect personal information through cookies, website forms, and other features on hscr.com, we will not identify users or facilitate the merging of personally identifiable information with non-personally identifiable information collected through any Google Analytics tool unless we have provided robust notice of, and obtained the user’s prior affirmative (i.e., opt-in) consent to, that identification or merger, and are using a Google Analytics feature that expressly supports such identification or merger. Irrespective of users’ consent, we will never attempt to disaggregate data that Google reports in aggregate.