Privacy Policy
HARBOUR & HOME PROPERTY MANAGEMENT
Effective September 22, 2026
Harbour & Home Property Management is a property management business operating in Newfoundland and Labrador, carried on by Deanna McCutcheon as a sole proprietor.
Managing a rental property means handling personal information — sometimes quite sensitive information, particularly when someone applies to rent a home. This policy explains what we collect, why, who we share it with, how long we keep it, and what you can ask us to do about it. It applies to visitors to our website, to property owners who engage us, and to rental applicants and tenants of the properties we manage.
We follow the Personal Information Protection and Electronic Documents Act (PIPEDA), the federal privacy law that governs how Canadian businesses handle personal information. Newfoundland and Labrador has no separate private-sector privacy law, so PIPEDA applies to everything we do.
1. Who is responsible
Deanna McCutcheon is our Privacy Officer and is accountable for the personal information in our care. Any question, request or complaint about privacy comes to her directly:
Deanna@harbourhomepropertymanagement.com
Phone
709-749-0792
Website
harbourhomepropertymanagement.com
2. What we collect, and why
If you visit our website
Our contact form collects your name, email address, phone number and whatever you write in your message. We use it to answer you. That's all.
We use Google Analytics to understand how people find and move through the site. It collects your IP address, device and browser type, the pages you view, how long you stay, and an approximate location based on your IP address. It uses cookies to do this. We see this information as aggregated statistics — we do not use it to identify you, and we do not combine it with anything else we hold.
If you are a property owner
We collect your name, contact details and mailing address; details of your property, tenancy and rent; your insurance particulars; and records of our correspondence and the work we carry out for you. We use it to provide the services in your management agreement, to invoice you, and to keep the records that agreement requires.
If you apply to rent a property we manage
This is the most sensitive information we handle, and we treat it that way. Depending on the application we may collect your name and contact details; your date of birth, where a credit check requires it; your employment and income information; references from previous landlords; identification; and a credit report obtained from a consumer reporting agency.
We collect this for one purpose: to assess your application and give the property owner a recommendation. We do not use it for marketing, we do not build a profile from it, and we do not share it with anyone beyond what section 4 describes.
We will not run a credit check without your express written consent. You are free to refuse. If you do, we will tell you honestly what that means for your application — in most cases the owner will not be able to assess it, but the choice is yours to make.
We assess every applicant in accordance with the Human Rights Act, 2010 (Newfoundland and Labrador). We do not collect, ask about, or take into account any protected characteristic, and we do not act on an owner's instruction to do so.
If you are a tenant of a property we manage
We hold your contact details, your tenancy agreement, records of rent and any arrears reported to us, maintenance requests, inspection reports and photographs, notices served, and our correspondence with you. We use it to administer the tenancy on the owner's behalf and to meet the requirements of the Residential Tenancies Act, 2018.
Inspection photographs record the condition of the property. We do not photograph your personal belongings where that can reasonably be avoided, and we do not use inspection photographs for marketing.
3. Consent
We collect personal information with your knowledge and consent. What that looks like depends on the situation: submitting our contact form is your consent to us replying; signing a management agreement or tenancy agreement is your consent to us handling the information that agreement requires; and a credit check needs your separate, express, written consent every time.
You can withdraw consent at any time, subject to legal and contractual limits — we cannot, for example, delete a tenancy record we are required to keep, or unwind a credit check already performed. Tell us and we will explain precisely what we can and cannot do, and what the consequences would be.
4. Who we share it with
We do not sell personal information. We do not rent, trade or otherwise disclose it for anyone else's marketing purposes. We never have and we will not.
We share personal information only where it is necessary:
With the property owner — an applicant's information relevant to the selection decision, and a tenant's information necessary to administer the tenancy. The owner is contractually required to keep it secure and to use it only for the tenancy.
With consumer reporting agencies — to obtain a credit report, with your express written consent.
With contractors and trades — a tenant's name, phone number and address, so access can be arranged. Nothing more.
With the Residential Tenancies Section — where an application or hearing requires it.
With professional advisors and insurers — a lawyer, accountant or insurer, where needed for advice or a claim.
Where the law requires it — in response to a court order, subpoena, or a lawful demand from an authority with the power to make it. We satisfy ourselves that the demand is valid before we respond.
5. Information that leaves Canada
Two of the services we use store information outside Canada, principally in the United States.
Our website is built on a hosted website platform, and messages submitted through the contact form are stored on that platform's servers. Google Analytics processes website usage data on servers outside Canada.
While information is in another country, it is subject to that country's laws, and may be accessible to that country's courts, law enforcement and national security authorities. We have no control over that, and neither does any Canadian business using an international service provider. We tell you because PIPEDA requires that you know, and because you should.
The information we hold about property owners, applicants and tenants is held by us in Canada.
6. How long we keep it
Website contact form messages
Up to 2 years, then deleted
Google Analytics data
Retained per Google's standard retention period; we hold no identifiable copy
Unsuccessful rental applications
12 months, then securely destroyed. We keep them this long so we can properly answer any question about how an application was assessed
Owner, tenancy and property records
Not less than 7 years after the end of the engagement or tenancy, as our management agreements require
Records of any privacy breach
24 months, as PIPEDA requires
When information is no longer needed, we destroy it — paper is shredded, and electronic files are deleted.
7. How we protect it
We keep safeguards appropriate to how sensitive the information is. Credit reports and identification documents get the most protection, because they would do the most harm in the wrong hands.
Access is limited to Deanna McCutcheon. We have no employees who access client or tenant files.
Devices holding personal information are password-protected and encrypted.
Paper documents are stored securely and are not left where others can read them.
We choose service providers with regard to their security practices, and give them only the information they need.
We do not send credit reports, identification or banking details by ordinary email or text message.
No safeguard is perfect, and we will not pretend otherwise. What we can tell you is that we take this seriously and that section 9 explains exactly what we will do if something goes wrong.
8. Cookies and how to opt out
Our website uses cookies for Google Analytics, as described in section 2. You can block or delete cookies in your browser settings, or install Google's opt-out browser add-on, which stops Google Analytics collecting data about you on any site. Blocking cookies will not stop you using our site or contacting us.
9. If there is a privacy breach
If personal information in our care is lost, accessed by someone who should not have it, or disclosed without authority, we will assess whether the breach creates a real risk of significant harm — which includes identity theft, financial loss, damage to your credit record, damage to your reputation or relationships, humiliation, or loss of employment or business opportunity.
Where that risk exists, PIPEDA requires us to report the breach to the Privacy Commissioner of Canada and to notify you directly, as soon as feasible. We will tell you what happened, what information was involved, what we are doing about it, and what you can do to protect yourself.
We keep a record of every breach for 24 months, whether or not it was reportable.
10. Your rights
You can ask us:
What we hold about you, how we have used it, and who we have disclosed it to.
To correct it, if it is wrong or incomplete.
To delete it, subject to the legal and contractual limits in section 3.
To withdraw your consent to a particular use.
Email or phone us using the details in section 1. We will respond within 30 days, as PIPEDA requires. There is no charge for a reasonable request. If a request would take substantial work, we will tell you the cost before we do anything, and you can withdraw the request.
We may need to verify your identity before releasing information — that protects you, not us. In a few cases the law prevents us from disclosing something, such as where it would reveal personal information about another person. If we refuse a request, we will tell you why in writing and explain how to challenge it.
11. Complaints
If you are unhappy with how we have handled your personal information, tell us first — email or phone Deanna using the details in section 1. We will investigate, respond in writing, and where we have got something wrong we will say so and fix it.
If you are not satisfied with our response, you can complain to the Office of the Privacy Commissioner of Canada:
Phone
1-800-282-1376
Website
Office of the Privacy Commissioner of Canada
30 Victoria Street
Gatineau, Quebec K1A 1H3
12. Changes to this policy
We will update this policy if our practices change. The effective date at the top tells you which version you are reading. Where a change is significant, we will say so on the website rather than quietly amend the page.
13. Contact us
Deanna McCutcheon, Privacy Officer
Harbour & Home Property Management
Deanna@harbourhomepropertymanagement.com · 709-749-0792
Harbour & Home Property Management · harbourhomepropertymanagement.com