Community Housing Partners Corporation (“CHP”) is committed to protecting your privacy. This privacy statement describes why and how we collect, use, and disclose personal information collected from individuals themselves or from other third parties, and provides information about individuals’ rights with respect to their personal information. We may use personal information provided to us for any of the purposes described in this privacy statement or as otherwise stated at the point of collection.

Our goal is to process personal information as necessary for our legitimate business purposes in a transparent manner. If you have any questions regarding our privacy practices, please contact us at legal@chpc2.org.

This Privacy Statement applies to all aspects of CHP’s business practices in all states in which it operates. This includes when CHP (1) is involved in providing you services, products, or housing; (2) sends you communications; or (3) posts a position for which you are applying; and/or (4) you have a role or relationship with, including through the use of and access to, CHP websites and applications.

INDIVIDUAL CLIENTS OF CHP SERVICES

We may provide a separate privacy statement in connection with certain services provided to individuals, and where we do so, such privacy statement will apply to our processing of personal information in the performance of those services.

Generally, our policy is to collect only the personal information necessary for agreed purposes or as required by law, and we ask our clients only to share personal information when it is needed for those purposes. When we need to process personal information relating to individuals other than our clients to provide our services, we ask our clients to provide the necessary information to other data subjects concerned, such as family members, regarding its use, or provide the necessary information directly to the other data subjects as part of our services.

Information collection

Generally, we collect personal information directly from our clients, from a government agency, or from a third party acting on the instructions of the client or as required by law. Given the diversity of the services we provide to individuals, we process many categories of personal information, including, as appropriate for the services we are providing:

  • contact details (e.g., email address, phone number, postal address);
  • business activities (e.g., job details, role, experience);
  • family information (e.g., dependents and other household information);
  • financial details (e.g., salary, payroll details and other financial-related details such as income, investments and other financial interests, benefits, tax status);
  • demographical information; and
  • survey responses.

For certain services, and when permitted by law, we may also collect sensitive or special categories of personal information. Examples of sensitive or special categories include social security, driver’s license, state identification card, or passport numbers; certain financial account details; information revealing racial or ethnic origin, religious or philosophical beliefs, sexual life/orientation, union membership, or political opinions; health information; genetic data; biometric data; precise geolocation data; and criminal records.

Information use

We use personal information for the following business purposes:

  • Providing professional services. We provide a range of professional services, and some of our services require us to process personal information to provide advice and deliverables. For example, we may use personal information to provide individual advice regarding home ownership eligibility or to assess eligibility for programs providing weatherization services or housing.
  • Administering, managing, and developing our businesses and services. We may process personal information to run our business, including:
    • managing our relationship with clients;
    • developing our businesses and services (such as identifying client needs and improvements in service delivery);
    • maintaining and using IT systems;
    • conducting surveys (e.g., benchmarking); and
    • hosting or facilitating the hosting of events.
  • Security, quality and risk management activities. Personal information may be processed as part of the security monitoring that we undertake. For example, automated scans to identify harmful emails (e.g., phishing emails), or to monitor the services provided to clients for quality purposes, which may involve processing personal information stored in the relevant client file. We have policies and procedures in place to monitor the quality of our services. We collect and hold personal information as part of our client engagement and acceptance procedures.
  • Complying with any requirement of law, regulation, or a professional body of which we are a member. As with any provider of services, we are subject to legal, regulatory, and professional obligations. Subject to these obligations, as described in the Information retention section below, we need to keep certain records to demonstrate that our services are provided in compliance with those obligations and those records may contain personal information.

We are continually looking for ways to help our clients and improve our business and services. Where agreed with our clients, we may use the information that we receive in the course of providing professional services for other lawful purposes, including analysis to better understand a particular issue; to provide insights; to improve our business, service delivery and offerings; and to develop new CHP offerings. To the extent that the information that we receive in the course of providing professional services contains personal information, we will often de-identify and/or aggregate the information prior to using it for these purposes.

BUSINESS CONTACTS OF CHP

We collect and use business contact details for individuals associated with existing and potential CHP partners, vendors, and customers, in order to manage and maintain our relationship with those individuals. Like most businesses, we use customer relationship management systems (“CRM”) to store personal information about our business contacts. The collection of personal information about contacts and the addition of that personal information to the CRM is initiated by CHP staff and may include name, employer name, title, phone, email and other business contact details. In addition, the CRM may collect data from CHP email and calendar systems concerning interactions between CHP staff and business contacts.

When we send you emails, we may use technologies to determine whether the email has been opened and whether the links contained within the message have been clicked on. We may combine information collected through these means with other information we maintain about you to measure interest in our specific offerings and email campaigns, improve our offerings to specific target audiences, and tailor our interactions with you.

We use this information for the following business purposes: Administering, managing and developing our business and services. We may process personal information to run our business, including: managing our relationships with clients or business partners; providing services and customer support to our clients and residents; developing our business and services, such as identifying client needs and improvements in service delivery and learning more about a client relationship opportunity we have an interest in; analyzing and evaluating the strength of interactions between CHP and a contact; performing analytics, including with regard to trends, relationship maps, and progress against business goals maintaining and using IT systems; hosting or facilitating the hosting of events; conducting surveys (e.g., benchmarking) or quizzes; and administering and managing our websites, systems, and applications.

Please review the Individual rights section below for information about how you may unsubscribe from our mailing lists and exercise other rights.

GENERAL DATA PRIVACY POLICIES

Information retention

We retain the personal information processed by us for as long as is considered necessary for the purpose(s) for which it was collected, including retention of business contact information in our CRMs, as applicable. Personal information may be held for longer periods where extended retention periods are required by law, regulation, or professional standards and to establish, exercise or defend our legal rights.

Security

CHP has implemented generally accepted standards of technology and operational security designed to protect personal information from loss, misuse, alteration or destruction. Only authorized CHP personnel and the third parties described in this privacy statement are provided access to personal information and these employees and third parties have agreed to maintain the confidentiality of this information. Please note that in the unlikely event that we might need to contact you about a matter involving your personal information, we may email you about the matter.

Information disclosure

We will only disclose personal information to others for a business purpose and when we are legally permitted or required to do so. When we disclose information to others, we put contractual arrangements and security mechanisms in place as appropriate to protect the information and to comply with our information protection, confidentiality, and security standards.

Disclosure to Auditors, professional advisors, insurers, and other third-parties

We engage auditors and other professional advisors, e.g., law firms, as necessary to establish, exercise or defend our legal rights and obtain advice in connection with the running of our business. Personal information may be disclosed to these auditors and other advisors as necessary in connection with the products and services they have been engaged to provide. We also have a number of business insurance policies in place and we may need to disclose personal information to the insurer, for example, in the event of a claim. We also disclose information to law enforcement or other government and regulatory agencies or other third parties as required by applicable law or regulation.

Occasionally, we may receive requests from third parties with authority to obtain disclosure of personal information, such as to check that we are complying with applicable law and regulation, to investigate an alleged crime, and/or to establish, exercise or defend legal rights. We will only fulfill requests for personal information where we are permitted to do so in accordance with applicable law or regulation.

We may also disclose personal information to a third party as necessary in connection with a corporate reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or capital.

Applications for Employment & Personnel Data Policies

If you are formally applying for one of CHP’s open positions, you will be presented separate privacy statements at the point of data collection during these processes. Should your formal application result in being extended an opportunity of employment with CHP, and your acceptance thereof, you will also be presented with employee privacy policies during the onboarding process. Please review those privacy statements for information about how CHP processes personal information in connection with recruitment and onboarding.

Others who contact us

We may collect personal information (such as name, contact details and contents of the communication) when an individual gets in touch with us with a question, complaint, comment, survey response or other feedback. In these cases, we will only use the information for the purpose of responding to and keeping a record of the communication. We may disclose personal information as described in the Information disclosure section.

Individual rights

Unsubscribe (where applicable). Should you wish to unsubscribe from our mailing list or any communications, we will provide instructions in the appropriate area of our websites or in our communications to you.

Users of our websites and applications. Information submitted via our websites and applications is subject to the same terms and conditions as Business Contact Information above.

Individual privacy rights. In certain circumstances under applicable law, you may have the right to access your personal information (including in a portable format if so requested), to correct your personal information, to delete your personal information, and/or to opt out of the sale of your personal information. To submit a request relating to any of these rights, please [CONTACT FORM]. We will respond to your request within a reasonable timeframe in accordance with applicable law.

Complaints or concerns. We hope that you won’t ever need to, but if you do want to complain about our use of personal information, please send us a message with the details of your complaint by email to legal@chpc2.org

Changes to this privacy statement. CHP may update this privacy atement at any time by publishing an updated version here. You can access the most current version of this privacy statement at any time on this site.

Contact us. If you have questions about this privacy statement or about our privacy practices, please contact us by email at legal@chpc2.org.

Last Updated May 20, 2024.