Privacy Policy

Northwest Healthcare Properties

1. Introduction

This privacy policy explains the privacy practices of Northwest Healthcare Properties (referred to as "Northwest", "us", "we" or "our"). This Privacy Code is based on the Personal Information Protection and Electronic Documents Act (PIPEDA). In order to ensure that this Privacy Code is kept up to date, we reserve the right to change this Privacy Code from time to time. Any changes will be effective 30 days following Northwest providing you with notice. Notice of changes to the Privacy Code may be distributed through Northwest statements, and/or posted on the Northwest web site at http://www.nwhreit.com

2. Our Commitment to Your Privacy

We value the trust you have placed in us and are taking all appropriate measures to safeguard your personal information and maintain your confidence. Northwest has established this privacy policy to ensure that your personal information is protected and that all our practices and procedures comply with relevant personal information protection and privacy legislation.

3. Accountability

Senior management of Northwest will have ultimate accountability for protecting personal information. Senior management has delegated the day-to-day management of procedures involving personal information protection to one or more persons.

Northwest's Privacy Office is responsible for overall personal information protection and Northwest's compliance with this Privacy Code.

Human Resources Personnel will have access to information about Northwest's employees.

Northwest is also accountable for personal information that has been transferred to a third party for processing.

Contact information for our Privacy Office is set out below:

Privacy Officer
c/o General Counsel
Northwest Healthcare Properties
180 Dundas Street West Suite 1100
Toronto, ON M5G 1Z8
Tel:  (416) 366-2000
Fax: (416) 366-8331
E-mail: privacyofficer@nwhreit.com

4. Identifying Purposes

We will clearly identify and document the purposes for which we may collect, use or disclose personal information at or before the time of collection. As part of our business operations, we may collect and use certain personal information strictly for the following purposes:

The specific uses of personal information in connection with the foregoing purposes will be limited to what a reasonable person would consider appropriate in the circumstances.

If Northwest identifies other purposes for which the personal information may be used, Northwest will seek the individual's consent prior to starting these uses. Northwest will advise that it is the individual's right to refuse permission for Northwest to use personal information for any new purposes.

Northwest will obtain consent before or when it collects, uses or discloses personal information. Generally, Northwest will seek consent to use and disclose personal information at the same time it collects the information. In some circumstances, Northwest may identify a new purpose and seek consent to use and disclose personal information after it has been collected.

Northwest will explain to individuals in plain language how personal information will be used or disclosed before they give their consent.

5. Obtaining Consent and Opting Out/Withdrawing Consent

Consent to the collection, use and disclosure of personal information can be expressed, implied, or given through an authorized representative of the individual. Individuals can express consent verbally, such as when information is collected over the telephone, in writing, such as when completing and signing an application, or electronically, such as when applying on a computer.

Individuals can imply their consent, for example, by using a Northwest product or service. In such a case, Northwest may assume that the individual consents to the use of the personal information for the purpose of using a Northwest product or service.

In certain limited circumstances, as permitted or required by law, we may collect, use or disclose personal information without the knowledge or consent of the individual. Although the following list is not exhaustive, these circumstance include: (i) personal information which is publicly available as defined by regulation; (ii) circumstances where collection or use is clearly in the interests of the individual and consent cannot be obtained in a timely fashion; (iii) to investigate a breach of an agreement or a contravention of a law; (iv) to act in respect of an emergency that threatens the life, health or security of an individual; (v) for debt collection; or (vi) to comply with a subpoena, warrant or court order.

Northwest will inform individuals of the consequences of refusing or withdrawing consent when individuals seek to do so. Refusing or withdrawing consent for Northwest to collect, use or disclose personal information could mean that Northwest cannot provide the individual with a product, service or information of value to the individual. For example, if an individual does not allow Northwest to obtain a credit history report, Northwest may not be able to lease space to the individual. Northwest, however, will not unreasonably withhold products, services or information from individuals who refuse to give consent or who withdraw consent.

We will use reasonable efforts to seek your express consent for the collection, use or disclosure of your personal information at the time of collection. In some circumstances, such as where we want to use personal information for a purpose that was not previously identified, we may have to seek your consent after your personal information has been collected but before our use for that purpose.

We will not, as a condition of leasing a premises to you, require you to consent to the collection, use or disclosure of personal information beyond that which is absolutely necessary.

6. Limiting Use, Disclosure and Retention

Northwest will collect only the amount and type of information needed for the purposes documented by Northwest and identified to the individual.

Northwest will collect personal information about an individual primarily from that individual. Except as permitted by law, Northwest will only collect personal information from external sources if individuals have consented to such collection.

Northwest does not use or disclose personal information for purposes other than those for which it is collected, except with the express consent of the individual or as required by law.

Northwest will retain personal information only for as long as is necessary for the fulfillment of those purposes, subject to legal requirements.

7. Accuracy

We will use our best efforts to ensure that personal information under our control that is used on an ongoing basis, including information that we disclose to third parties in accordance with this privacy policy, is as accurate, complete, and up-to-date as is necessary for the purposes for which it is to be used. In order to assist us in that regard, we urge you to provide us with updates regarding such information and to inform us of any errors affecting your personal information that we hold.

8. Safeguards

We will protect personal information with safeguards appropriate to the sensitivity of the information. We employ appropriate safeguards to protect personal information against loss or theft, as well as unauthorized access, disclosure, copying, use or modification, regardless of the format in which the information is held. We make our employees and business partners aware of the importance of maintaining the confidentiality of personal information, and we will exercise appropriate care in the disposal or destruction of personal information to prevent unauthorized parties from gaining access to the information.

Northwest may disclose personal information to businesses such as credit bureaus, credit insurers and lenders with the individual's consent. Northwest relies on the added protection of credit reporting legislation to ensure that credit bureaus protect personal information which is disclosed to them.

Northwest will use care when disposing of or destroying personal information in order to prevent unauthorized access to the information.

9. Openness

We will make specific information about our policies readily available, except to the extent that it is confidential commercial information.

Information about this Privacy Code will be available in a format that is easy to understand. The contact information of the Privacy Office are provided in this Privacy Code, so individuals know where to address complaints and questions about Northwest's personal information policies and procedures.

The information we will make available will include: (i) how to gain access to your personal information; (ii) the type of personal information held by us, including a general account of its use; (iii) general information concerning our privacy policy; (iv) what personal information is made available to third parties; and (v) how to contact our Privacy Officer.

Copies of the current version of our privacy policy are available by contacting our Privacy Office at:

Privacy Officer
c/o General Counsel
Northwest Healthcare Properties
180 Dundas Street West Suite 1100
Toronto, ON M5G 1Z8
Tel:  (416) 366-2000
Fax: (416) 366-8331
E-mail: privacyofficer@nwhreit.com

Our privacy policy can also be viewed on our website at http://www.nwhreit.com/Privacy-Policy.

10. Access

Upon written request addressed to our Privacy Officer, we will inform an individual of the existence, use and disclosure of his or her personal information and we will give the individual access to that personal information. An individual can challenge the accuracy and completeness of his or her personal information under our control and have it amended as appropriate.

We will respond to an individual's written request within a reasonable time (generally within 30 days) and we will assist any individual who informs us that he or she needs assistance in preparing a request. We may require an individual to provide sufficient information to permit us to provide an account of the existence, use and disclosure of personal information. While our response will typically be provided at no cost to the individual, depending on the nature of the request and the amount of information involved, we reserve the right to impose a reasonable cost. In these circumstances, we will inform the individual of the approximate cost to provide the response and proceed upon payment by the individual of the cost. Requested information will be provided or made available in a form that is understandable. Where possible, we will indicate the source of the information.

If you feel that your personal information we hold is inaccurate or incomplete you are invited to advise our Privacy Officer of such inaccuracies and ask that we amend the personal information. Any such request must be in writing.

In providing an account of third parties to which we may have disclosed personal information about an individual, we will attempt to be as specific as possible. When it is not possible to provide a list of the organizations to which we have actually disclosed personal information, we will provide a list of organizations to which we may have disclosed the personal information.

If an individual successfully demonstrates an inaccuracy or incompleteness of his or her personal information under our control, we will amend the personal information as appropriate. If a challenge is not resolved to the satisfaction of the individual, we will record the substance of the unresolved challenge. Where appropriate, the amended information or the existence of the unresolved challenge, as the case may be, will be transmitted to third parties having access to the information in question.

In certain situations, we may refuse a request or not be able to provide access to all the personal information we hold about an individual. Exceptions to the access requirement will be limited and specific, as permitted or required by law. Where permitted, the reasons for denying access will be provided to the individual upon request. Although the following list is not exhaustive, exceptions may include: (i) information that contains references to other individuals or contains confidential commercial information, where such information cannot be severed from the record; (ii) information collected in the course of investigating a breach of an agreement or in the course of a formal dispute resolution process; and (iii) information that is subject to solicitor-client privilege.

11. Challenging Compliance

If you are not completely satisfied with our privacy policy wish to submit comments or concerns regarding our privacy practices, we invite you to contact our Privacy Officer. We will thoroughly investigate all written complaints addressed to our Privacy Officer. If we find a written complaint to be justified, we will take all appropriate measures, including, if necessary, amending our policies and practices.

If for any reason you are not satisfied with the results of our investigation of and responses to your complaint, you may file a complaint with the Office of the Federal Privacy Commissioner, 112 Kent Street, Ottawa, Ontario, K1A1H3
Telephone:  1-800-282-1376

Provincial Offices:

Ontario:

2 Bloor Street East, Suite 1400, Toronto, Ontario, M4W 1A8
Telephone:  416-326-3333
Toll Free:  1-800-387-0073
Fax: 416-325-9195
E-Mail: info@ipc.on.ca

Quebec:

Office of Information and Privacy Commissioner,
575 St. Amable Street Suite 1.10 Québec, Quebec G1R 2G4
Telephone:  418-528-7741
Toll Free:  1-888-528-7741
Fax: 418-529-3102
E-Mail: Cai.Communications@cai.gouv.qc.ca

Nova Scotia:

Nova Scotia Freedom of Information and Protection of Privacy Review Office,
Box 181, Halifax, NS B3J 2M4
Phone:  (902) 424-4684.
No Charge-Dial:  1-866-243-1564.
Fax: (902) 424-8303

New Brunswick:

Regency Park, 65 Regent Street Suite 230, Fredericton, New Brunswick E3B 7H8
Telephone:  506-453-5965
Toll Free:  1-877-755-2811
Fax: 506- 453-5963
E-Mail: access.info.privacy@gnb.ca

Alberta:

410, 9925 - 109 Street, Edmonton, Alberta, T5K 2J8
Telephone:  780-422-6860
Toll Free:  1-888-878-4044
Fax: 780-422-5682
E-Mail: generalinfo@oipc.ab.ca

British Columbia:

Office of the Information and Privacy Commissioner for British Columbia,
4th Floor, 947 Fort Street, P.O. Box 9038, Station Prov. Govt., Victoria BC V8V 3K3
Phone:  (250) 387-5629
Toll Free:  1-800-663-7867
Fax: (250) 387-1696
E-mail: info@oipc.bc.ca

Manitoba:

750 - 500 Portage Avenue, Winnipeg, Manitoba R3C 3X1
Telephone:  204-982-9130
Toll Free:  1-800-665-0531
Fax: 204-942-7803