BC Rent Bank Privacy Statement
Last updated January 17, 2021
- What is BC Rent Bank?
- Refusing Consent
- When your consent is not required
- What personal information do we collect, use, and disclose?
- Why we need your personal information
- Reasons for use of anonymized information by BC Rent Bank
- How do we collect and share your information among the rent banks?
- Using and disclosing your personal information
- Use and disclosure by BC Rent Bank
- Use and disclosure by the local rent bank
- Retaining your personal information
- When you connect with us online
- Accessing your information
- About this privacy statement
What is BC Rent Bank?
BC Rent Bank is a project of Vancity Community Foundation, and funded by the Province of BC. The mandate of BC Rent Bank is:
- To support the funding of existing rent banks across BC;
- To provide support and seed funding for the establishment of new rent banks in BC; and,
- To create the infrastructure necessary to support a potential future province-wide rent bank system or service.
BC Rent Bank does not provide loans or services to individuals – that is the job of the local rent banks in communities around the province. BC Rent Bank’s goal is that regardless of where you live in the province, you can be supported to help maintain your housing. This goal has not yet been achieved, and establishing a province-wide infrastructure is our strategic focus over the next two years of the project. (may not be needed)
To enable us to meet the mandate of the BC Rent Bank project, we have built a shared tool - the BC Rent Bank Client Management System (the “BC Rent Bank System”) - which supports client intake, pre-assessment of client eligibility, and improving rent bank services in BC.
This BC Rent Bank Privacy Statement (“Privacy Statement”) describes the privacy practices of BC Rent Bank and what we do to protect your personal information in the BC Rent Bank System. This Privacy Statement also explains how the information in the BC Rent Bank System may be used by your local rent bank to provide you services.
To contact the BC Rent Bank Privacy Office, click here.
For more information about what rent banks in BC do, click here.
When you submit your application for rent bank services using the form on this website, we ask for your express consent to collect, use and disclose your personal information for the purposes of the BC Rent Bank project, to provide you with rent bank services and to operate the BC Rent Bank System. These purposes are described in more detail in this Privacy Statement under “Why We Need Your Personal Information,” below.
As a general rule, consent can be express, implied, or given through an authorized representative such as a lawyer, agent, or broker. Express consent may be given orally, in writing, or electronically. We generally rely on your express consent, except in limited circumstances when it is appropriate to rely on implied consent. In limited circumstances, and only if necessary, we don’t rely on consent, as described below under “When Your Consent is Not Required”.
You may withdraw or refuse consent to collect, use, disclose, or retain certain personal information. However, your withdrawal or refusal may prevent us or a local rent bank from providing services to you if the information is needed to provide the services. If the information is required by law or necessary to provide you rent bank services, the rent bank will not be able to proceed with your application.
When your consent is not required
There are a few limited circumstances when BC Rent Bank is permitted by law to collect, use, disclose, or retain personal information without your knowledge or consent. For instance:
- In an emergency that threatens an individual’s life, health, or personal security.
- When a rent bank needs to collect a debt from you.
- When a rent bank needs to carry out an investigation involving its own operations.
- When it is required by law.
What personal information do we collect, use and disclose?
The BC Rent Bank and the local rent bank collect the information on your application form, including your name, address and contact information, your age, birthdate, and information about your family status, housing situation, financial situation, citizenship status, household income, debts, expenses, banking information, other sources of financial assistance you have sought, current situation including the reasons for your application to the rent bank and other information you may provide that may be relevant to your application.
After your application is accepted, the local rent bank may require more information from you to provide you with services, and they may need to speak with others as part of the services they provide. Before they do that, they will tell you and get your consent directly.
Why we need your personal information
Your personal information will be collected, used, disclosed, and retained for the purposes of providing you with the rent bank services and for the purposes of the BC Rent Bank project, which are:
- To verify your identity. For example: in the BC Rent Bank system, over the telephone, or in person;
- To determine your eligibility for rent bank services, including reviewing and assessing your application and redirecting your application to a different rent bank where appropriate;
- To provide you with the rent bank services and any supplementary services such as referrals to counselling or other support agencies;
- To keep a record of your application including to manage the file and administer any loan provided, throughout the period of the loan or any supplementary services;
- To keep a history of your application(s) including your repayment history, and any supplementary services offered or provided;
- To comply with regulatory requirements, obtain legal advice, or bring or defend against legal proceedings;
- To help protect the lenders and you against fraud and error; and
- as authorized or required by law.
A local rent bank can sometimes advocate for you and represent you in dealings with financial institutions, employers, landlords, utility companies and any other third parties that they deem necessary for the purposes of their program. The local rent bank will tell you about their services when they talk with you, and will get your consent before they represent you in dealings with others.
As part of BC Rent Bank’s work to better understand the need in BC for rent bank services, BC Rent Bank may contact you, either by phone or email, to participate in a survey about housing stability. We anticipate that these surveys will be done three times each year. Participating in these surveys is up to you. We do not tell the local rent bank who participates. Choosing not to participate will not affect any decisions of the local rent bank. We hope you’ll agree to participate because understanding how the rent bank system is (or isn’t) meeting needs in BC is very important for us to be able to improve services. You may opt-out of this contact by emailing email@example.com.
Reasons for use of anonymized information by BC Rent Bank:
BC Rent Bank will use information that does not identify an individual to understand the needs of rent bank users, and to generate analyses and reports about the current economic situation of users, the types of services they use and other important statistical information. This aggregated, anonymized statistical information is used by BC Rent Bank to continue to advance the goals of the BC Rent Bank project to build infrastructure in BC to support a rent bank system, to advocate with government for changes to government policies or laws, and to assist local rent banks to refine their services.
For example, the BC Rent Bank needs to understand the number of people seeking help from rent banks across the province, the number of people approved, the number of supplemental services provided, the number of returning clients, the number of active files, the speed of repayment and so on. This helps us understand how to meet the needs of people in BC and how to improve rent bank program and services.
How do we collect and share your personal information among the rent banks?
BC Rent Bank collects personal information about you through the form you submit, and from your local rent bank when it uses the BC Rent Bank Client Management System.
BC Rent Bank and the local rent bank that provides you services keep your personal information in the BC Rent Bank Client Management System. The local rent bank you select in your application will pre-assess your file in the BC Rent Bank Client Management System to determine whether your case meets the basic criteria for eligibility. This involves reviewing the information in your application, and may involve checking your first and last name, your city and date of birth in the system to see if there is already an open application (if there is an open application, it is not accessible during this process).
If you have a previous file with another rent bank, the local rent bank you selected may contact the other rent bank as part of the pre-assessment determination.
If the rent bank believes you may have selected the wrong rent bank, they may re-direct your application to a more appropriate location. For example, if you chose the Burnaby rent bank in your application form, it will review your application. After reviewing your application and checking to see if you’ve previously applied to another rent bank in BC, if the Burnaby rent bank determines that the New Westminster rent bank is more appropriate, it will simply re-direct your application to that rent bank. This avoids you having to fill out a new form for the New Westminster rent bank.
If the rent bank accepts your pre-assessment, they will contact you directly to get more information to decide whether you are eligible for a loan, and to talk about other supplementary services that could help you with housing stability. That rent bank may keep records of their contact with you and other important information about your services in your secure file in the BC Rent Bank System.
BC Rent Bank does not collect information directly from you except in your pre-assessment form on our website, or through a follow-up survey about housing stability, as described above. BC Rent Bank will never contact you directly, by phone or email to collect information used to provide you services.
Using and Disclosing Information
We recognize that the information you provide to us is very sensitive and we do not disclose any more of your personal information than is necessary.
Use and Disclosure by BC Rent Bank
BC Rent Bank does not use your personal information to provide rent bank services and only discloses your personal information to the local rents banks, as described above. BC Rent Bank may share your name, date of birth, and city with any rent bank if the rent bank is assessing your application for services. Only the rent bank that actually assesses you for services or provides you with services has access to the contents of your file.
BC Rent Bank contracts with a local provider of hosting services to host this website and the contract requires that provider to protect personal information consistent with our privacy policies and security practices. We store your information in Canada.
Use and Disclosure by the Local Rent Bank
The local rent bank that you choose will use the personal information in your pre-assessment form to assess your eligibility and if approved, to administer the loan or other services. It may use the BC Rent Bank System as described above, to keep a record of the services you received, and for this purpose may disclose information about you into the BC Rent Bank System.
If your application is approved, the local rent bank will call you and will get consent from you to use and disclose your personal information for the specific services that they will provide to you. In general, these services might include arranging for a loan, referring to you other service providers, and advocating for you with employers, landlords, utility companies, and other third parties.
If you own assets with another person, or if your liability on a debt is shared with others, the rent bank may ask for your consent to share your information with such other persons in connection with providing the rent bank services to you.
If the BC Rent Bank or a local rent bank ever re-organize their corporate structures, it may be necessary to disclose personal information in the course of that reorganization or restructuring, to advisors or to a successor organization. Any such disclosure will be subject to appropriate privacy and security safeguards and compliant with any applicable law.
Retaining your personal information
Your personal information will be retained in the BC Rent Bank System for as long as necessary for the identified purposes and for legal and business purposes, but at least for a minimum one year period after your application is pre-assessed. The local rent bank that provides you with services may maintain a separate file and if they do, they will tell you when they get your consent to use and disclose your personal information for their specific services.
When you connect with us online
The rent banks will communicate with you by phone or by another means (email, text, social media), depending on your instructions. E-mail is not secure or confidential unless properly encrypted. The BCRB discourages the use of e-mail to send personal or financial information to us. Persons that use e-mail for those purposes do so at their own risk, and we will not be responsible or liable to you or any other person for any loss or damage suffered as a result of your use of e-mail to communicate with us, or the use of e-mail by us to communicate with you or other persons at your request.
Your personal information may be updated if it is necessary to fulfill the rent bank services described in this Privacy Statement, or if it is required to maintain a rent bank service.
We rely on you to provide us with accurate information about yourself. Please update the rent bank if your personal information changes to ensure the accuracy of our records and so the rent bank can provide you with the services you need.
In many cases, BC Rent Bank and the local rent bank providing you service relies on you to ensure that certain personal information, such as your address, telephone number, is accurate. Keeping your personal information accurate lowers your risk of fraud and of us losing contact with you, avoids any information that needs to be mailed to you being mailed to an incorrect address, and ensures accurate reporting and follow up.
The BC Rent Bank and the rent banks are committed to keeping your personal information safe. The BC Rent Bank uses technical, administrative and contractual means to keep your personal information secure, to protect the BC Rent Bank System and our technical infrastructure, and to protect your personal information from unauthorized access, use or disclosure. Your information is encrypted when being transmitted to our servers and while held on our servers. All rent bank authorized users who have access to the BC Rent Bank System can see the name of a person who has had a file opened on the system because that is necessary for the purposes of pre-assessment. Only the rent bank assigned to your file has the right see the contents of the file.
All staff are trained to deal with confidentiality requirements around sensitive financial information and to follow appropriate safeguarding procedures. Every rent bank employee and contract is required as a term of their employment or contract to act responsibly in order to protect your privacy and the security of personal information.
You also have a part to play to keep your information secure. If you are using a public computer, make sure to close the browser after you’ve submitted your application. Always log off when you leave a public computer. Try to protect the screen from being viewed by others while you are using it and be sure to take all your paper records with you and keep them secure.
Accessing Your Information
You have a right to access your personal information held by BC Rent Bank. Upon request in writing, BC Rent Bank will tell you within 30 business days what personal information it has, what it has been used for and with whom it has been shared.
If you would like access to your personal information held by BC Rent Bank, please submit a written request to the rent bank that you are dealing with, or directly to the BC Rent Bank Privacy Officer. We have a process in place to protect your information and part of that involves communicating with the rent bank that provides you services and verifying your identity to ensure that the access request is legitimate. We may also request that you specify the type of information you would like to access.
There may be a cost to fulfilling an access request, depending on the type and amount of information requested. When there is a cost, BC Rent Bank will inform you of the estimated cost and ask you whether BC Rent Bank should proceed with the request. If an access request is refused, in whole or in part, BC Rent Bank will provide written notification to you of its refusal, reasons for refusal, and what other options you may have. Any information provided will be made available in a way that is accessible to you. If you believe the information provided is inaccurate or incomplete, you may request BC Rent Bank to amend the information and where appropriate, share the amended information with relevant third parties.
About this Privacy Statement
The BC Rent Bank Privacy Statement is based on British Columbia's Personal Information Protection Act (“PIPA”). BC Rent Bank will notify you on the BC Rent Bank website (www.bcrentbank.ca) of any substantial changes to this Privacy Statement before the changes come into effect.
This Privacy Statement applies to the personal information of individual BC Rent Bank and local rent bank clients. It does not apply to information about businesses or organizations, or to information about individuals acting in their professional capacity in the course of providing rent bank services.
If you have any questions or complaints you may reach us at:
Vancity Community Foundation
312 Main St #409, Vancouver, BC V6A 2T2
Attn: Privacy Office