1. PURPOSE AND SCOPE

Northview Apartment REIT and its subsidiaries (collectively, “Northview”) respect the privacy of individuals and are committed to protecting the Personal Information (as defined below) under its custody or control.

The purpose of this Privacy Policy (the Policy”) is to provide guidance on the appropriate handling, collection, use and disclosure of Personal Information by Northview. This Policy also intends to ensure compliance with all privacy legislation.


2. DEFINITIONS

For the purposes of this Policy, the following definitions apply:

Business Contact Information” means any information that is used for the purposes of communicating or facilitating communication with an individual in relation to their employment, business, or profession, such as the individual’s name, position name or title, work address, work telephone number, work fax number, or work electronic address.

Customer” means any residential or commercial tenant or guest of Northview.

Employee” means an individual who is potentially, currently, or formerly, an employee, partner, trustee, director, officer, office-holder, apprentice, volunteer, participant, or student performing a service for, or in relation to, Northview, including individuals under a contract or agency relationship.

Collectively, Employees and Customers are referred to as “Individuals”.

“Personal Information” is any information about an identifiable individual.


3. POLICY GUIDELINES

Northview will limit the collection of Personal Information to what is reasonably required for the purposes identified by Northview at the time of collection.

Northview primarily collects Personal Information directly from the affected Individual; however, Northview may also collect Personal Information from other sources, such as references, with the consent of the affected Individual, or if required or permitted by law.

Northview will only use or disclose Personal Information for the purposes for which it was collected, unless the Individual has consented to the use or disclosure of their Personal Information for a new purpose, or if required or permitted by law.

To the extent that Northview uses third-party service providers to store, handle or process Personal Information on its behalf (e.g. data processing or office services), Northview will use contractual and other means to provide a comparable level of protection to that Personal Information. Regardless of the steps taken by Northview to protect Personal Information in the custody of third-party service providers, Personal Information that is processed or stored in a foreign country may be accessible to law enforcement, courts, regulatory agencies and national security authorities of that jurisdiction.
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Where an individual has consented to the collection, use or disclosure of their Personal Information, that Individual may withdraw or vary his/her consent on reasonable notice and subject to legal or contractual restrictions.


Northview welcomes questions and feedback on this Policy and its management of Personal Information. Access and rectification requests, withdrawals or variations of consent, complaints, questions or concerns about our privacy policies and practices, including questions about the collection, use, disclosure or storage of Personal Information by our service providers outside of Canada, may be directed to our Privacy Officer at:

Attention: Northview Privacy Officer


Northview Apartment REIT, 200, 6131 – 6 Street SE, Calgary, AB, T2H 1L9. Telephone: 1 (888) 231-0725


Email: [email protected]

Copies of this Policy and related policies are available on request.

Privacy laws are rapidly evolving and, as a result, this policy may be changed by Northview from time to time, in Northview’s full discretion, without any prior notice or liability to any individual or other person. The collection, use, and disclosure of Personal Information by Northview will be governed by the version of this Policy in effect at that time.


A. PERSONAL INFORMATION OF EMPLOYEES

Northview collects Personal Information in respect of Employees, including, but not limited to:

a) personal contact information, including home address, home or cellular telephone numbers, and personal email;

b) resumes and/or applications with work history, educational history, and skills;

c) references and interview notes;

d) photographs and video;

e) letters of offer and acceptance of employment, as well as other terms and conditions of employment as may be applicable;

f) Business Contact Information;

g) payroll information, including Social Insurance Number, paycheque deposit information, and other related information;

h) wage and benefit information;

i) taxation details;

j) hours worked, absences, and vacation dates;

k) performance reviews;

l) disciplinary matters;

m) forms relating to the application for, or in respect of changes to, employee health and welfare benefits, including disability, medical and dental care; and

n) beneficiary and emergency contact information.

 

After obtaining consent from Employees, the Personal Information of Employees is collected, used and disclosed for Northview’s business or legal purposes, including:

a) establishing, managing or terminating an employment relationship which includes;

i. determining eligibility for initial employment, including the verification of references and qualifications;
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ii. administering payroll and benefits;

iii. processing Employee work-related claims (e.g. worker compensation, insurance claims, disability claims, etc.);

iv. establishing training and/or development requirements;

v. conducting performance reviews and determining performance requirements;

vi. assessing qualifications for a particular job or task;

vii. gathering evidence for disciplinary action or termination;

viii. maintaining health and safety records;

b) identifying and communicating with Employees;

c) managing and servicing our relationships with Customers and suppliers;

d) planning and managing our workload;

e) establishing a contact point in the event of an emergency (such as next of kin);

f) complying with applicable labour or employment statutes;

g) compiling staff telephone lists and directories;

h) ensuring the security of Northview-held information;

i) to protect the rights and property of Northview;

j) during emergency situations or where necessary to protect the safety of a person or group of persons;

k) prospective or completed business transactions including, but not limited to, a sale of Northview property; and

l)those purposes required or permitted by law.

 

The work product of Employees belongs to Northview regardless of the format it is in. The work product and the tools and/or equipment, including computers and cellular telephones, used to generate that work product, are always subject to review and monitoring by Northview.

Employees should have no expectation of privacy in any work product, or personal content exchanged, communicated, stored or processed using tools or equipment belonging to Northview.


B. PERSONAL INFORMATION OF CUSTOMERS

Northview collects Personal Information of its Customers, including, but not limited to:

a) personal contact information including home address, home telephone number, and personal email address;

b) name of additional tenants;

c)Business Contact Information;

d)banking information, which may include credit card details;

e) credit scores and other information obtained through a credit check;

f) past addresses;

g) reference information, including employment and former landlord information; and

h) emergency contact information.

 

Northview collects, uses and discloses Personal Information of Customers for business or legal purposes, including:

a) determining eligibility for a tenancy agreement, including creditworthiness;

b) checking references prior to approving a tenancy agreement;

c) collecting rent and security deposits through banking information;

d) administering payments through credit card;

e) establishing a contact point in the event of an emergency (such as next of kin);

f) complying with applicable tenant legislation;

g) to protect the rights and property of Northview;

h) during emergency situations or where necessary to protect the safety of a person or groupof persons;

i) prospective or completed business transactions including, but not limited to, a mortgage

financing or sale of Northview property; and

j) those purposes required or permitted by law.

 

C. SURVEILLANCE

In the course of managing Northview’s properties, Northview may monitor activities on its properties through security cameras. These cameras are generally in high risk areas such as

entrances/exits, parking lots, or work sites. Security cameras are not located in apartments, but may be located in the hallways, elevators, and other common areas. Where in use, security

cameras are there for the protection of Individuals and third parties, and to protect against theft, vandalism and damage to Northview’s property. Footage from these cameras is routinely

destroyed unless there is suspicion of a crime, or a health or safety incident, in which case it may be reviewed by Northview, given to the police or given to other appropriate third parties.

This section is not meant to suggest that all Individuals will in fact be monitored or their actions subject to constant surveillance. It is meant to bring Individuals’ attention to the fact that such monitoring may occur and may result in the collection of Personal Information from Individuals when on, or in the vicinity of, Northview properties.


D. PROTECTION OF PERSONAL INFORMATION

Northview has made reasonable security arrangements to protect Personal Information against risks such as unauthorized access, collection, use, disclosure, copying, modification, disposal or destruction.
 

Northview restricts access to Personal Information to those employees or service providers that need such access in order to perform their tasks, contracts and/or functions. Northview employs firewalls, access control procedures, and cryptography, and other physical, administrative and technological measures to protect Personal Information, regardless of the format in which it is held and in accordance with the sensitivity of the Personal Information.


E. RETENTION AND STORAGE OF PERSONAL INFORMATION

Northview retains Personal Information for as long as necessary to fulfill the purpose(s) for which it was collected and to comply with applicable laws. Personal Information that has been used to make a decision that directly affects an Individual will be retained for at least one year. Personal Information that is no longer required is securely destroyed or rendered anonymous.

Northview stores Personal Information at its offices in Canada, as listed at www.northviewreit.com/contact.

 

F. ACCURACY OF PERSONAL INFORMATION

It is important that the Personal Information contained in Northview’s records is both accurate and current.
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Northview relies on Individuals to provide accurate and current Personal Information. It is the responsibility of the Individual to inform Northview of changes to their Personal Information.

Where appropriate and on written request, Northview will revise Personal Information if it is inaccurate, incomplete or irrelevant. Northview will disclose the revised Personal Information to third parties to permit the revision of their records, where appropriate. Where Personal Information is not revised as requested, the Personal Information will be annotated with the request that was made.


G. ACCESS TO AND RECTIFICATION OF PERSONAL INFORMATION

At any time, with sufficient information, an Individual may seek access to their Personal

Information that is in the custody or control of Northview, and request that such information be updated and/or corrected. Northview will assist any Individual who requires assistance in preparing an access or rectification request.
 

Northview will respond to written access and rectification requests within 30 days. In some cases, Northview may respond to a request with an estimate of the fee required for the transcription, reproduction or transmission of information. Northview may ask for the fee, or part of the fee, to be paid before the request can be processed.
 

Except where otherwise permitted or required by law to deny access, Northview will provide Individuals with (a) access to their Personal Information including, as accurately as possible, an account of the third parties to whom Northview has transferred or disclosed the Individual’s Personal Information; and (b) the right to challenge the accuracy and completeness of their Personal Information and to have it corrected and updated, as appropriate. Where Personal Information that Northview is entitled or required to withhold is severable, Northview will edit the Personal Information to allow access to the remaining information.


H. COMPLAINTS

Complaints regarding Northview’s management of Personal Information should be promptly reported to the Privacy Officer at 1 (888) 231-0725 or [email protected].
 

The Privacy Officer will verify and document the content of the complaint for the purposes of their investigation. The results of that investigation will be shared with the Individual making the complaint.


4. MORE INFORMATION

For further resources or information on privacy in Canada, please visit https://www.priv.gc.ca/en.

To contact the Office of the Privacy Commissioner of Canada, please call toll free: 1 (800) 282- 1376.