This Privacy Policy (the “Policy”) describes the practices of Chartwell Retirement Residences and our subsidiaries and affiliates (collectively, “Chartwell,” “we,” or “us”) in relation to the collection, use, disclosure, retention and protection of Personal Information, as well as the rights you may have with respect to your Personal Information. We strive to be open and transparent regarding how we handle your Personal Information.
This Policy applies to Personal Information Chartwell collects about prospective and current residents, occupants and guarantors under residency agreements, visitors to the Chartwell website at https://chartwell.com (the “Website”) and job applicants (collectively “individual” or “you”).
Personal Information is “any information about an identifiable individual”, which alone or in combination with other information, could be used to identify a person. This may include contact or demographic information, information relating to your communications with us or more technical information (such as users’ IP addresses, usernames), but only when this information can identify you as an individual. Personal Information does not include Personal Information that has been anonymized and/or aggregated such that the data cannot be connected to a particular person, and the professional contact information within an organization.
Chartwell limits the collection of Personal Information to that which is reasonably necessary to fulfill the purposes for which it was collected. Chartwell may collect, use and disclose different kinds of Personal Information, grouped together as follows:
We use different methods to collect Personal Information, including:
Chartwell uses the collected Personal Information in order to provide residential, recreational and health care services, understand, improve, and develop our services and the Website, make hiring decisions, and complying with our legal obligations, including:
The knowledge and consent of the individual are required for the collection, use, or disclosure of personal information, except where inappropriate or otherwise permitted by applicable law. Chartwell will take into account the sensitivity of the Personal Information when determining the appropriate form and method of obtaining consent, including requesting express consent for the collection of sensitive personal information (i.e., information that is sensitive due to its nature or the context of its use or disclosure, requiring high levels of protection under reasonable expectations).
When you provide your Personal Information to Chartwell, you are providing your consent to the collection, use and disclosure of your Personal Information as set out in this Policy and as otherwise permitted or required by law. Consent can be obtained in person, by phone, via email, by signature or by other lawful means.
Consent to the collection, use and disclosure of Personal Information is given for specific purposes or for general purposes consistent with those for which it was collected.
In some circumstances consent is implied through the individual relationship or conduct i.e. your permission is assumed based on your action or inaction at the point of collection, use or sharing of your Personal Information. Your consent can also be provided through an authorized representative such as an attorney, substitute decision maker or another designated individual. In the case of sensitive Personal Information (e.g. health information), consent must be expressly given.
In certain circumstances, your Personal Information may be collected, used or disclosed without consent in case of an emergency, when authorized by law (for example, to detect or prevent fraud or an illegal activity) or when required to comply with a court order or a similar type of requirement.
You are able to withdraw your consent with reasonable notice at any time, subject to legal or contractual restrictions. Upon receipt of a notice of withdrawal of consent, we will inform you of the likely consequences of the withdrawal of consent, which may include our inability to provide services for which that information is necessary.
If you do not consent to the collection, use and disclosure of your Personal Information please do not provide any Personal Information to Chartwell.
Chartwell does not use or disclose Personal Information other than for the purposes for which it was collected in accordance with this Policy. We may share Personal Information as outlined below and in accordance with applicable law:
Chartwell is headquartered in Canada and your Personal Information is stored in secured locations and on servers controlled by Chartwell or our service providers, located either at our facilities in and outside of Quebec, or at the facilities of our service providers in Canada, located in and outside of Quebec.
Notwithstanding the foregoing, Chartwell reserves the right to transfer and process Personal Information on a global and worldwide basis when necessary to operate our business, meet our contractual obligations and comply with our legal and regulatory obligations. In such cases, Chartwell will use reasonable safeguards to ensure the protection of your Personal Information wherever it is used or stored and to ensure that any international transfer of Personal Information is carried out in accordance with applicable privacy laws.
The protection of such Personal Information will be subject to the legal requirements of the jurisdictions where the information is transferred, including lawful requirements to disclose information to government authorities in those countries.
Chartwell retains Personal Information so long as we have an ongoing legitimate business need to do so (for example, to provide you with the services, to comply with applicable legal, tax or accounting requirements, to resolve disputes, or as otherwise permitted or required under applicable law).
When we have no ongoing legitimate need to process your Personal Information or are required under the applicable law, we will delete it or, if this is not possible (for example, because your Personal Information has been stored in backup archives), then we will securely store your Personal Information and isolate it from any further processing until deletion is possible. We may also further retain Personal Information in an anonymous or aggregated form where that information would not identify you personally.
Chartwell uses physical, electronic and procedural safeguards to protect against unauthorized use, access, modification, destruction, disclosure, loss or theft of your Personal Information in our custody or control.
The nature of the security safeguards will vary depending on the amount of information, distribution method, format, and method of information storage employed. Information will be safeguarded using measures appropriate to the Personal Information involved.
Chartwell has agreements and controls in place with third party service providers requiring that any information we provide to them must be safeguarded and used only for the purpose of providing the service we have requested the service provider to perform.
Employees with access to Personal Information are required, as a condition of employment, to safeguard Personal Information viewed or handled by them and to complete a privacy training course.
Chartwell takes all reasonable measures to address any access, collection, use, disclosure, copying, modification, retention or disposal of Personal Information in our systems in accordance with relevant legislation.
In the event of a Privacy Incident, Chartwell will take reasonable measures to contain and mitigate such a breach and ascertain its harm to individuals whose Personal Information has been affected and issue all required notifications through a clear communications and escalation process in accordance with relevant legislation.
In accordance with applicable law, you have the following rights, subject to some conditions and exceptions:
All requests regarding your Personal Information should be sent to Chartwell’s Privacy Office or the General Manager of the Residence in which you live.
Chartwell will respond to such requests within thirty (30) business days of their receipt or within any other delay required or authorized by applicable law. Chartwell will take reasonable steps to functionally correct or delete your Personal Information from Chartwell database(s) upon request, although Chartwell may keep a copy for archival purposes in compliance with applicable laws. Before Chartwell provides you with any Personal Information, corrects any inaccuracies or deletes any Personal Information, Chartwell may request additional information to verify your identity or otherwise help respond to your request.
Chartwell's Privacy Office manages and administer all matters relating to protecting the privacy of individual’s Personal Information and can provide more information about any aspect of this Policy or about the way in which Chartwell operates to protect the privacy of your Personal Information.
Individuals may send a written request to:
Attention: Privacy Officer
Chartwell Retirement Residences
7070 Derrycrest Drive
Mississauga, Ontario L5W 0G5
or
privacyoffice@chartwell.com
If you have any questions regarding the access we have provided or wish to advise us of inaccuracies, you may speak directly to the General Manager at the Chartwell residence you live at or, you may escalate your request with our Privacy Officer at privacyoffice@chartwell.com.
Chartwell may update the Privacy Policy from time to time to reflect developments in its practices, new technology or the law. Any amendment to this Policy will be effective at the date of the amendment. All changes to the Policy will be posted on the Website. If the changes are significant, we will highlight them if required by applicable law.
