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Who We Are?
Our
organization, Perry + Perry Architects Inc., provides architectural
advice and services to both residential and commercial clients. It
includes, at the time of writing, two architects and three support
staff. We use a number of consultants and agencies that may, in the
course of their duties, have limited access to personal information we
hold. These include professional engineers, general contractors,
computer consultants, bookkeepers and accountants, lawyers, contract
staff, co-op students and landlord. We restrict their access to any
personal information we hold as much as is reasonably possible. We also
have their assurance that they follow appropriate privacy principles.
We
Collect Personal Information: Primary Purposes
About Clients
Like
most architects, we collect, use and disclose personal information in
order to serve our clients. For our clients, the primary purpose for
collecting personal information is to provide architectural advice and
services. Where our client is an individual, we collect information
about the client’s building or renovation desires and intended uses,
financial situation and, for residential services, family circumstances
so that we can advise the client as to their options. We then carry out
their instructions.
A
second primary purpose might be to collect personal information from
third parties (e.g., neighbours) about a client’s architectural plans so
that we can ascertain how the third party’s views affect our client’s
architectural situation.
A
third primary purpose is to obtain home contact information so that we
can contact the client in private or in an emergency.
It
would be rare for us to collect any personal information without the
client’s express consent, but this might occur in a case of urgency
(e.g., the client is unavailable) or where we believe the client would
consent if asked and it is impractical to obtain consent (e.g., a family
member who appears to be aware of the project contacts us to provide
additional information).
About Members of the General Public
For
members of the general public, our primary purpose for collecting
personal information is usually to gather and review information that is
relevant to an architectural issue affecting our own clients (e.g., if
they would object to a project). Thus, the personal information is
usually incidental to our providing advice to our client. Normally this
would be done with the consent of the individual.
Another primary purpose for collecting personal information about
members of the general public is to provide notice of special events
(e.g., a seminar or conference) or to make them aware of architectural
services in general or our firm in particular. For example, while we
try to collect work contact information where possible, we might collect
home addresses, fax numbers and email addresses. We try to obtain
consent before collecting any such personal information, but where this
is not, for any reason, possible, we will upon request remove any
personal information from our distribution list.
On
our website, we only collect, with the exception of cookies (electronic
markers identifying computers that have previously visited our website),
the personal information you provide and only use that information for
the purpose you gave it to us (e.g., to respond to your email message,
to register for a course, to subscribe to our newsletters). Cookies are
only used to help you navigate our website and are not used to monitor
you.
Contractors, Suppliers
For
people who are contracted to do work for us (e.g., temporary workers,
students and volunteers), our primary purpose for collecting personal
information is to ensure we can contact them in the future (e.g., for
new assignments) and for necessary work-related communication (e.g.,
sending out paycheques, year-end tax receipts, tax filings). Examples
of the type of personal information we collect for those purposes
include home addresses and telephone numbers and performance information
for a review or a reference letter. It is rare for us to collect such
information without prior consent, but it might happen in the case of a
health emergency (e.g., an outbreak of a contagious disease) or to
investigate a possible breach of law (e.g., if a theft were to occur in
the office).
Contractors, Suppliers and Project Security
We
collect personal information about contractors and other suppliers and
their staff to assist us in assessing their performance, both for the
specific project in issue and in respect of future projects. We may
share this information in a reciprocal way with other architects and
construction contacts. Often this information is collected with consent
as a part of a written or verbal contract with the organizations
involved. Sometimes the exceptions for collecting personal information
without consent relating to publicly available information, breach of
agreement and contravention of the law apply. Sometimes the information
is business, not personal, information.
We
may collect personal information to maintain the security of our
projects through security cameras and security personnel. We try to
make it known, through signs or the public nature of the camera and
personnel that we are doing so.
Third Party Opinions
When
we are retained to provide an opinion about the work of another
architect or a related professional, our primary purpose for collecting
personal information is to gather the necessary information to express a
sound opinion on the issue for our client. In such circumstances, we
often act without the consent of the subject of the third party opinion
because we are inquiring into an apparent breach of law or an agreement
and obtaining consent would compromise the investigation.
We
Collect Personal Information: Related and Secondary Purposes
Like
most organizations, we also collect, use and disclose information for
purposes related to or secondary to our primary purposes. The most
common examples of our related and secondary purposes are as follows: |
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a.) |
To
invoice clients for goods or services that are not paid for at the time,
to process credit card payments or to collect unpaid accounts. |
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b.) |
To
advise clients and others of new developments in architecture (e.g., a
newsletter sent to a home e-mail of a client). |
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c.) |
To
advise clients and others of our newsletters, courses we provide,
special offers and promotions that we have available. |
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d.) |
Our
firm reviews client and other files for the purpose of ensuring that we
provide high quality services, including assessing the performance of
our partners and staff. In addition, external consultants (e.g.,
auditors, lawyers, information technologists) may on our behalf do
audits and continuing quality improvement reviews of our firm, including
reviewing client files and interviewing our staff. |
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e.) |
Architects are regulated by the Ontario Association of Architects who
may inspect our records and interview our staff as a part of its
regulatory activities in the public interest. In addition, as
professionals, we will report serious misconduct, incompetence or
incapacity of other practitioners, whether they belong to other
organizations or our own. Also, our firm believes that it should report
information suggesting serious illegal behaviour to the authorities.
External regulators have their own strict privacy obligations. These
reports could include personal information about our clients, or other
individuals, to support the concern (e.g., improper services), although
we try to keep this disclosure to a minimum. Also, like all
organizations, various government agencies (e.g., Canada Customs and
Revenue Agency, Information and Privacy Commissioner, Human Rights
Commission, etc.( have the authority to review our files and interview
our staff as a part of their mandates. In these circumstances, we may
consult with professionals (e.g., lawyers, accountants) who will
investigate the matter and report back to us. |
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f.) |
Clients or other individuals we deal with may have questions about the
services they received. We also provide ongoing services for many of
our clients over a period of months or years for which previous records
are helpful. We retain our client information for a minimum of fifteen
years after the last contact to enable us to respond to questions and
provide these services (the Ontario Association of Architects also
requires us to retain our client records). |
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g.) |
If
Perry + Perry Architects Inc. or its assets were to be sold, the
purchaser would want to conduct a “due diligence” review of the firm’s
records to ensure that it is a viable business that has been honestly
portrayed to the purchaser. This due diligence may involve some review
of our accounting and service files. The purchaser would not be able to
remove or record personal information. Before being provided access to
the files, the purchaser must provide a written promise to keep all
personal information confidential. Only reputable purchasers who have
already agreed to buy the organization’s business or its assets would be
provided access to personal information, and only for the purpose of
completing their due diligence search prior to closing the purchase. |
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You
can choose not to be part of some of these related or secondary purposes
(e.g., by declining special offers or promotions, by paying for your
services in advance). We do not, however, have much choice about some of
these related or secondary purposes (e.g., external regulation).
Protecting Personal Information
We
understand the importance of protecting personal information. For that
reason, we have taken the following steps: |
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a.) |
Paper
information is either under supervision or secured in a locked or
restricted area. |
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b.) |
Electronic hardware is either under supervision or secured in a locked
or restricted area at all times. In addition, passwords are used on
computers. All of our cell phones are digital, which signals are more
difficult to intercept (however, we still are careful on cell phones
because sometimes they switch over to an analog service). |
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c.) |
Paper
information is transmitted through sealed, addressed envelopes or boxes
by reputable companies. |
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d.) |
Electronic information is transmitted either through a direct line or is
anonymized or encrypted. |
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e.) |
Staff
are trained to collect, use and disclose personal information only as
necessary to fulfill their duties and in accordance with our privacy
policy. |
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Retention and Destruction of Personal Information
We
need to retain personal information for some time to ensure that we can
answer any questions you might have about the services provided and for
our own accountability to external regulatory bodies. However, we do
not want to keep personal information too long in order to protect your
privacy.
We
keep our client files for about fifteen years. Out client and contact
directories are much more difficult to systematically destroy, so we
remove such information when we can if it does not appear that we will
be contacting you again. However, if you ask, we will remove such
contact information right away. We keep any personal information
relating to our general correspondence with people who are not our
clients, newsletters, seminars and marketing activities for about two
years after the newsletter ceases publication or a seminar or marketing
activity is over.
We
destroy paper files containing personal information by shredding. We
destroy electronic information by deleting it and, when the hardware is
discarded, we ensure that the hard drive is physically destroyed.
Alternatively, we may send some or all of the client file to our client.
You can Look at Your Information
With
some exceptions, you have the right to see what personal information we
hold about you. Often all you have to do is ask. We can help you
identify what records we might have about you. We will also try to help
you understand any information you do not understand (e.g., short forms,
technical language, etc.). We will need to confirm your identity, if we
do not know you, before providing you with this access. We reserve the
right to charge a nominal fee for such requests.
If
there is a problem, we may ask you to put your request in writing. If
we cannot give you access, we will tell you within 30 days if at all
possible and tell you the reason, as best we can, as to why we cannot
give you access.
If
you believe there is a mistake in the information, you have the right to
ask for it to be corrected. This applies to factual information and not
to any professional opinions we may have formed. We may ask you to
provide documentation that our files are wrong. Where we agree that we
made a mistake, we will make the correction and notify anyone to whom we
sent this information. If we do not agree that we have made a mistake,
we will still agree to include in our file a brief statement from you on
the point and we will forward that statement to anyone else who received
the earlier information.
Do You
Have a Question?
Any
questions concerning the above can be addressed to either Jeff Perry or
Chris Perry and they can be reached at:
174
Larch Street, Sudbury, Ontario P3E 1C5
Phone: (705) 688-0440
Fax:
(705) 688-0439
If
you wish to make a formal complaint about our privacy practices, you may
make it in writing to either Jeff or Chris Perry. They will acknowledge
receipt of your complaint, ensure that it is investigated promptly and
that you are provided with a formal decision and reasons in writing.
This
policy is made under the Personal Information Protection and Electronic
Documents Act. It is a complex Act and provides some additional
exceptions to the privacy principles that are too detailed to set our
here. There are some rare exceptions to the commitments set out above.
For
more general inquiries the Information and Privacy Commissioner of
Canada oversees the administration of the privacy legislation in the
private sector. The Commissioner also acts as a kind of ombudsman for a
privacy disputes. The Information and Privacy Commissioner can be
reached at:
112
Kent Street
Ottawa, Ontario K1A 1H3
Phone: (613) 995-8210
Toll-free: 1-800-282-1376
Fax:
(613) 947-6850
TTY:
(613) 992-9190 |
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174
Larch St. Suite 201 
