Brookfield Residential Property Services ("Brookfield RPS"), a division of Brookfield Asset Management Inc. ("BAM"), is a leading global provider of residential real estate and relocation services, technology and knowledge. Brookfield RPS respects the privacy of its clients, prospective clients and others and is committed to keeping your personal information accurate, confidential, secure and private. We have adopted the following Privacy Policy to ensure that Brookfield RPS continues to meet its commitment to your privacy.
Brookfield RPS’s operating portfolio consists of operating lines in the residential real estate, global relocation services, home valuations, move programs and related services. All Brookfield RPS operating lines are governed by their individual privacy policies.
Brookfield RPS’s clients include governments, institutions, corporations and individuals. At Brookfield RPS we respect the privacy of our clients and we are committed to keeping your personal information accurate, confidential, secure and private. We have adopted the following privacy policy to ensure that Brookfield RPS continues to meet its commitment to privacy.
In the course of providing these services, Brookfield RPS may consensually collect certain personal information about our clients.
"Personal Information" means information about an identifiable individual client. This may include without limitation, the individual's name, address, age, gender, income, employment status, credit history, debts and liabilities, income, personal preferences and other information about his or her family. Personal information does not include the name, title or business address or telephone number of an employee of an organization.
The Brookfield RPS Privacy Policy is based on, and complies with, Canada's Personal Information Protection and Electronic Documents Act ("PIPEDA"), which includes the Ten Privacy Principles outlined in the Canadian Standards Association Model Code for the Protection of Personal Privacy. For more information about this legislation, please visit the official web site of the Privacy Commission of Canada at http://www.privcom.gc.ca.
This privacy policy describes the ten principles that Brookfield RPS follows to ensure that we protect our clients' and employees personal information when we collect, use or disclose it in the course of carrying on commercial activities in Canada or the United States. All of our employees who have access to personal information must adhere to the Brookfield RPS Privacy Policy and related procedures. To this end, Brookfield RPS has appointed a Privacy Officer who has the ultimate responsibility for ensuring compliance within Brookfield RPS and by all Brookfield RPS’s employees.
This introduction and the following sections, read as a whole, comprise the Brookfield RPS Privacy Policy:
- The Ten Principles of Privacy
- Application of the Ten Privacy Principles
- Questions, Concerns and Complaints
1. THE TEN PRINCIPLES OF PRIVACY
The following ten principles govern our actions as they relate to the use of the personal information of our clients, prospective clients and others:
- Principle 1 – Accountability
- Principle 2 – Identifying Purposes
- Principle 3 – Consent
- Principle 4 – Limiting Collection
- Principle 5 – Limiting Use, Disclosure and Retention
- Principle 6 – Accuracy
- Principle 7 – Safeguarding Personal Information
- Principle 8 – Openness
- Principle 9 – Individual Access
- Principle 10 – Questions and Concerns
Principle 1 – Accountability
Brookfield RPS is accountable for all personal information in our possession or custody, including personal information disclosed to third parties for purposes of providing services requested by our clients or employees. Through its policies and procedures, Brookfield RPS will strive to implement this Privacy Policy throughout all of its operations.
Brookfield RPS will seek to include in contractual arrangements with suppliers provisions requiring them to provide an appropriate level of protection for information transferred to them by Brookfield RPS.
Principle 2 – Identifying Purposes
Brookfield RPS will inform you of the purposes for which it is collecting any personal information, unless otherwise apparent, before or at the time the information is collected.
Principle 3 – Consent
Brookfield RPS will seek to obtain consent from our clients before or when we collect, use or disclose their personal information. Brookfield RPS will strive to ensure that individuals understand how their personal information will be used or disclosed.
A client's consent can be express, implied, or given through an authorized representative. Consent may be implicitly when the purposes are not stated expressly but are implied by the circumstances of the transaction or follow logically from other expressly stated purposes. A client can withdraw consent at any time, with certain exceptions. Individuals may contact Brookfield RPS’s Privacy Officer respecting the withdrawal of any previously given consent or any change in the purposes for which information held by Brookfield RPS may be used, disclosed or retained. Additionally, information may be retained by Brookfield RPS for audit or archival purposes notwithstanding any withdrawal of consent otherwise applicable but the fact that consent has been withdrawn will be noted so as to prevent an unauthorized use.
Brookfield RPS, however, may collect, use or disclose personal information without the client's knowledge or consent in exceptional circumstances where such collection, use or disclosure is permitted or required by law.
Principle 4 – Limiting Collection
Brookfield RPS will only collect information that is reasonably necessary for the purposes identified. Information will be collected by fair and lawful means.
Principle 5 – Limiting Use, Disclosure and Retention
Personal information will only be used or disclosed for the purpose for which it was collected unless the client has otherwise consented, or when it is required or permitted by law. Personal information may only be retained for the amount of time needed to fulfill the purpose for which it was collected.
In certain exceptional circumstances, Brookfield RPS may have a legal duty or right to disclose personal information without our clients' knowledge or consent with respect to matters that concern the company's or the public's interest.
Principle 6 – Accuracy
Brookfield RPS will keep personal information as accurate, complete and current as necessary to fulfill the identified purposes for which it was collected. Brookfield RPS will update and correct any personal information held by it if the individual concerned provides Brookfield RPS, with particulars, satisfactory to it, of any required updating or correction.
Principle 7 – Safeguarding Personal Information
Personal information is safeguarded to protect against loss, theft or unauthorized access, disclosure, use or modification of information using measures appropriate to the sensitivity, amount, format, nature and storage of the information and will involve, as applicable, physical organizational and electronic security measures.
Principle 8 – Openness
Brookfield RPS will make information available to its clients about the policies and procedures Brookfield RPS uses to manage personal information. Clients have access to this information through our web sites, or through written correspondence with Brookfield RPS’s Privacy Officer.
Principle 9 – Access
If your would like to view the personal information held in your file, please make a written request to Brookfield RPS Privacy Officer. Brookfield RPS will respond to your request as efficiently as possible and will advise of the individual cost, if any, prior to the retrieval of such records. Brookfield RPS will not respond to frivolous or vexatious requests for access to information. If Brookfield RPS is prohibited from providing such access, the Brookfield RPS Privacy Officer will explain the reasons, except where prohibited by law.
Principle 10 – Questions or Concerns
Brookfield RPS has policies and procedures to receive, investigate and respond to individuals' complaints and questions. Individuals may contact the Brookfield RPS’s Privacy Officer to express any concerns or to request access to their personal information. The contact information for this individual is provided below.
2. APPLICATION OF THE TEN PRIVACY PRINCIPLES
2.1 The Kind Of Information We Collect
Through links to its operational websites, Brookfield RPS gathers and uses personal information in order to provide you with the services you have requested or to offer additional services in which you may be interested. Providing us with your personal information is your choice, however, we may not be able to provide you with certain services if you do not provide us with certain information.
The nature of our relationship with you will determine the kind of personal information we might ask for.
Information that is typically required to provide you with our services may include:
- Name,
- Residential and e-mail address,
- Phone number(s),
- Relevant financial information, and
- Social Insurance Number
Brookfield RPS may keep a file with your contact history to be used for inquiry purposes so that we may ensure that you are satisfied with the services which we have provided to you.
If you visit Brookfield RPS’s operational web sites, we do not collect personally identifiable information about you unless you provide it. All information that you do provide us with is securely maintained and kept strictly confidential.
2.2 How We Use Your Information
Generally speaking, Brookfield RPS’s operational divisions use personal information for three general purposes:
- To communicate with you in order to provide you with our services or information,
- Transactional information to monitor our level of service and report back to you to ensure your satisfaction with the provision of services, and
Each of Brookfield RPS’s operational businesses will only use personal information for the purpose that it has disclosed to you.
If such operational division wants to use your information for a different purpose, it will notify you and ask for your consent first.
2.3 When We May Disclose Your Personal Information
Brookfield RPS is obliged to keep your personal information confidential except under the following circumstances:
- When Authorized by You,
- When Required by Law, and
- When Permitted by Law.
- When Authorized by You
Many of the services offered by Brookfield RPS’s operational businesses need to obtain personal information about you in order to perform the services we have been engaged to provide. Each operational division will use this information to tailor products to meet your needs and objectives. We will always obtain consent from you first, and we will never use the information for purposes other than those we have told you about
- When Required by Law
The type of information we are legally required to disclose usually relates to government tax reporting requirements. However, in some cases, such as under a court order, we may be required to disclose certain information to persons specified in the court order. We will only provide the specific information requested and only upon being satisfied that the authorities have legitimate grounds to request the information.
- When Permitted by Law
The legislation has provided certain situations where Brookfield RPS is legally permitted to disclose personal information without your consent. Examples include situations involving the collection of debt in arrears, or suspicion of illegal activities.
2.4 Who We May Share Your Information With
- Brookfield RPS Employees
In the course of daily operations, access to sensitive personal information is limited to those employees with a legitimate reason for accessing it. As a condition of their employment, Brookfield RPS employees are required to follow all applicable laws and regulations, including this privacy policy.
Unauthorized use or disclosure of confidential client information by a Brookfield RPS employee is prohibited and may result in disciplinary measures.
- Brookfield RPS Affiliates.
In order to meet your needs we may share your personal information with our Brookfield RPS Affiliates and suppliers. We will only do this with our consent and you may withdraw this consent at any time. Such suppliers are only given the information that is needed to provide the specific service for which they are necessary to provide the service. We insist that our suppliers are contractually bound to protect the confidentiality of your personal information and that they are prohibited from doing anything with this information that we have not authorize them to do. They are required to treat your personal information in a manner consistent with the Brookfield RPS Privacy Policy.
Brookfield RPS Affiliates are companies that: i) are owned 50% or more by BAM; or ii) those companies that BAM owns less than 50% and that BAM maintains significant influence over the management and operation of the company.
2.5 How We Safeguard Your Information
Brookfield RPS has extensive controls in place to maintain the security of our information and information systems. Client files are stored according to the sensitivity of the information contained therein. Appropriate controls (such as restricted access) are placed on our computer systems. Physical access to areas where personal information is gathered, processed or stored is limited to authorized employees.
When you telephone a Brookfield RPS employee to speak about your file, you may be asked for some personally identifying information. This type of safeguard is designed to ensure that only you, or someone authorized by you, has access to your file.
2.6 Web Site Security
In order to serve you better, Brookfield RPS offers clients access to certain information through our web sites. For instance, www.brookfieldrps.com provides general information about Brookfield RPS and the services we offer.
If you visit Brookfield RPS operational web sites, we do not collect personally identifiable information about you unless you provide it. All information that you do provide us with is securely maintained and kept strictly confidential.
2.7 Accessing and Amending Your Personal Information
You have the right to access the personal information we keep in your file and you have the right to verify or amend the information if it is shown to be inaccurate. If you would like to view the personal information held in your file, please make a written request to the Privacy Officer at the address listed below, under "3. Questions, Concerns and Complaints". We will respond to your request as efficiently as possible.
To make a change, please make a similar request in writing to the Privacy Officer.
2.8 Opting Out
In order to provide you with our services, Brookfield will, with your consent, share your personal information with other Brookfield affiliates. Should you not want to receive promotional materials from or have your personal information shared with these companies please contact Brookfield's Privacy Officer at the address, phone number or email address provided in Section 3 below.
3. QUESTIONS, CONCERNS AND COMPLAINTS
If you have any questions, concerns or complaints about your personal information, or about the Brookfield RPS Privacy Policy, please contact our Privacy Officer using the following contact information:
Brookfield RPS’s Privacy Officer: Mr. Kevin von Bargen
Brookfield Residential Property Services
39 Wynford Drive
Toronto, Ontario, M3C 3K5
kvonbargen@brookfield.com
T: 416-386-6001
F: 416-446-0050