Brampton Real Estate Board

Privacy Compliance Review Policy

 

1.  Objectives and Scope of policy

 

The Brampton Real Estate Board ("BREB" or "the Board") is aware that its operations will evolve in the event of changes to (1) the mandate of the organization, (2) the technology it employs or (3) the business processes it uses. BREB has adopted this policy to ensure that the Board remains compliant with federal and/or provincial legislation as well as any requirements of the Canadian Real Estate Association, the Ontario Real Estate Association or the Real Estate Council of Ontario concerning personal information as it may or may not come to apply to BREB.

 

This Policy applies to all BREB employees as a condition of their employment as well as to Members of BREB's Board of Directors as a requirement for continued Board membership. Using contractual or other arrangements, the Board shall ensure that agents, contractors or third party service providers, who may receive Personal Information in the course of providing services to BREB, act in a manner consistent with this Policy.

 

The Executive Director is responsible for ensuring compliance with this Policy.

 

A "privacy compliance review" means that the Board will examine a proposed change by reviewing and applying the questions found in the BREB Privacy Impact Assessment Report to determine if a risk of non-compliance with privacy obligations may result from that proposed change.

 

Generally, minor changes to the scope of a service, business process or information handling practice will not trigger a privacy compliance review. What constitutes a major or minor change is a decision of the Board of Directors or the Executive Director. BREB will examine the privacy implications of any major change of its operations when the Board:

 

Administration Changes

Changes any BREB policy that applies to the collection, use and/or disclosure of personal information.

Changes how it provides notice to individuals about their privacy rights under applicable legislation.

Changes the means by which an individual may validate the accuracy of personal information held by, or challenge BREB's handling of, their personal information.

 

 

 


Service Changes

Proposes to create a new service offered to Members and/or the public.

Makes significant changes to an existing service or business process.

Moves an existing service or business process from a paper to an electronic

       format.

Modifies computer systems in a way that affects the security policies and

       procedures used to manage and control access to personal information.

 

Information Collection Changes

Changes the way it collects personal information within an existing service or

       business process, including making changes to any of its standard forms.

Proposes to collect personal information that it did not previously collect,

       whether directly or through third parties.

Makes a change in the way BREB obtains the consent to collect, use and/or disclose personal information. An example would be where the BREB used to collect such consent directly but proposes to now do so indirectly (through a third party).

 

Information Use/Disclosure Changes

Adds to or varies the purposes for which personal information was originally

       collected.

Proposes to share personal information with an organization, other than

       those with which it shares information now.

Changes the way it shares personal information.

 

2.  Change Management Outcomes

 

BREB will make no change in its policies, business processes or information handling practices that will adversely affect the privacy rights of individuals with respect to such personal information it may hold. In addition, any major changes in BREB's policies business processes or information handling practices will be examined by the Board's Chief Privacy Officer to determine whether it requires an amendment to the Board's Privacy Policy.

 

3.  Notice

 

If it is determined that a change in BREB’s policies, business processes or information handling practices requires an amendment to BREB’s Privacy Policy, such amendment will be made; notice of such will be communicated as provided for in the Board’s Privacy Policy; and the effect of the amendment will be as set out in the Board’s Privacy Policy.  In the case of BREB employees, notice of any change shall be directly and promptly communicated to them in a manner deemed most appropriate by the Executive Director.