Privacy Policy — Element Housing Inspections (Element Housing)
Effective date: 2025-09-16
Who we are
[Element Housing Inc.] (“Element”, “we”, “us”, “our”)
App covered: Element Housing Inspections (mobile) and the connected Element Housing web application (together, the “Services”).
Element Housing Inspections is used by Housing Inspectors in First Nation Communities to complete property inspections offline and securely sync data to Element Housing when back online. All data is owned by the Community using the Services. We support and respect the First Nations Principles of OCAP® (Ownership, Control, Access, and Possession). Each Community is the data controller/owner for the information they enter about their properties and occupants; Element acts as a service provider / data processor.
1) Information We Collect & Process
A. Community-Entered Property & Housing Data (examples you control and configure):
2) How We Use Information
We process data only to provide the Services to the Community, including to:
3) Legal Basis / Authority
We process data under the direction and authority of the Community (the data owner/controller), in line with Community policies and applicable privacy laws (e.g., PIPEDA and relevant provincial privacy laws, where applicable), and the OCAP® principles. Element acts as a service provider/data processor.
4) Data Ownership & OCAP®
5) Sharing & Disclosure
We do not sell Community data. We may share data only:
6) Data Storage, Security & Location
7) Your Choices & Controls (Communities)
8) Individual Privacy Rights
Where applicable under privacy laws, individuals (e.g., occupants) may request access, correction, or deletion through their Community’s housing office. Element will support the Community in responding.
9) Children & Vulnerable Persons
The app is for authorized housing staff/inspectors only—not children or the general public. Household records may include minor information entered by the Community for housing administration; Communities are responsible for appropriate notices/consents under OCAP® and law.
10) Data Transfers
If a Community requests services that involve cross-border processing, contractual and technical safeguards (e.g., SCCs) will be applied.
11) Security Incidents
We maintain an incident response program. Communities will be notified without undue delay in the event of a security incident.
12) Cookies (Web App)
13) How We Communicate Changes
We may update this policy as services or laws change. Material changes will be communicated to Community administrators and posted with a new effective date.
14) Contact
Privacy & OCAP inquiries:
Dee Albert, Privacy Officer
[email protected] | 1.306.441.8388
Community-specific requests: Contact your Community Housing Office or administrator.
Who we are
[Element Housing Inc.] (“Element”, “we”, “us”, “our”)
App covered: Element Housing Inspections (mobile) and the connected Element Housing web application (together, the “Services”).
Element Housing Inspections is used by Housing Inspectors in First Nation Communities to complete property inspections offline and securely sync data to Element Housing when back online. All data is owned by the Community using the Services. We support and respect the First Nations Principles of OCAP® (Ownership, Control, Access, and Possession). Each Community is the data controller/owner for the information they enter about their properties and occupants; Element acts as a service provider / data processor.
1) Information We Collect & Process
A. Community-Entered Property & Housing Data (examples you control and configure):
- Property profile: Unit number, address, Community/First Nation, province, postal code, country, building nickname/description, specifications (sq ft, bedrooms/bathrooms, year built/inspected/renovated, category, utilities, water/sewage, heat/power, foundation, siding, electrical, etc.).
- Administrative & utility fields: Meter/account numbers, service providers.
- Land location fields: Quarter/Section/Township/Range/Meridian, Lot/Block/Plan.
- Animals: Pets/livestock info as configured by the Community.
- Value info: Purchase price, current value (used for aggregate reporting).
- Access & system fields: Property access codes that the Community chooses to store.
- Emergency status: Emergency type/priority/details, including GPS if used.
- Property type/stage/status and related classification fields.
- GPS location: Latitude, longitude, plus code (optional). Communities may configure GPS capture; it is never mandatory.
- Media & documents: Photos, inspection documents, PDFs, and other files.
- Structured inspection checklists and findings (e.g., Housing Condition Assessment sections, statuses, priorities, cost estimates).
- Photos taken in-app or uploaded from device gallery.
- Notes, comments, follow-ups, and attachments.
- Occupants (names and contact details), maintenance requests, and follow-up notes.
- Financials/rates fields configured by the Community (for reporting/administration).
- Device/OS, app version, limited diagnostics, timestamps, and offline sync events (success/failure), used to secure and operate the Services.
- Session & authentication data: standard PHPSESSID cookies (web) and API tokens (mobile).
2) How We Use Information
We process data only to provide the Services to the Community, including to:
- Enable inspectors to work offline and securely sync when back online.
- Let authorized users access all properties in their Community and update information.
- Create inspection reports, store photos/documents, and support follow-ups.
- Auto-capture GPS (if enabled) to pinpoint property/inspection locations.
- Provide aggregate and administrative reporting as configured by the Community.
- Maintain security, availability, backup, and audit trails.
- Provide support, troubleshooting, and improvements to the Services.
3) Legal Basis / Authority
We process data under the direction and authority of the Community (the data owner/controller), in line with Community policies and applicable privacy laws (e.g., PIPEDA and relevant provincial privacy laws, where applicable), and the OCAP® principles. Element acts as a service provider/data processor.
4) Data Ownership & OCAP®
- Ownership & Control: The Community owns and controls its data.
- Access & Possession: The Community determines who can access records in Element Housing and holds ultimate possession over its data.
- Requests: Element fulfills access/export/deletion requests under the Community’s instructions.
5) Sharing & Disclosure
We do not sell Community data. We may share data only:
- At the Community’s direction, including with Community staff, inspectors, leadership, and designated third parties (e.g., authorities for Active Emergency workflows) as configured.
- With vetted service providers under contract, bound to use data only to provide services to the Community and Element.
Our current sub-processors are:- DigitalOcean LLC (Toronto, Canada): hosting & database storage
- Twilio (U.S.): SMS messaging
- Google Maps (Global): displaying maps/location services
- SMTP2Go (Global): transactional email
- Resend (Global): transactional email
- To comply with lawful requests or protect rights, safety, and security.
6) Data Storage, Security & Location
- Encryption in transit: HTTPS/TLS
- Encryption at rest: Planned for future upgrades.
- Passwords: Securely hashed with BCRYPT.
- Sessions & authentication: PHPSESSID cookies and API tokens.
- Access controls: Role-based access, least-privilege, strong authentication, audit logging.
- Offline mode: Data stored locally in secure OS storage until synced.
- Data residency: All data is stored in Toronto, Ontario, Canada (DigitalOcean). Communities may negotiate alternate residency.
- Retention: Our default policy is indefinite archiving, unless the Community requests deletion. Three deletion levels are available: Archive, Processor-only viewable, or Absolute Deletion.
- Backups & resilience: Regular backups and disaster recovery are planned for medium term.
7) Your Choices & Controls (Communities)
- Permissions: Communities control who can view/edit properties, inspections, photos, and documents.
- GPS & Photos: Communities configure whether GPS/photos are required or optional. Device-level permissions may override.
- Exports & Deletion: Communities can request export or permanent deletion of data; Element will act on instructions.
8) Individual Privacy Rights
Where applicable under privacy laws, individuals (e.g., occupants) may request access, correction, or deletion through their Community’s housing office. Element will support the Community in responding.
9) Children & Vulnerable Persons
The app is for authorized housing staff/inspectors only—not children or the general public. Household records may include minor information entered by the Community for housing administration; Communities are responsible for appropriate notices/consents under OCAP® and law.
10) Data Transfers
If a Community requests services that involve cross-border processing, contractual and technical safeguards (e.g., SCCs) will be applied.
11) Security Incidents
We maintain an incident response program. Communities will be notified without undue delay in the event of a security incident.
12) Cookies (Web App)
- PHPSESSID: Essential session cookie to keep users logged in.
- Expires when the browser closes.
- No analytics or advertising cookies are used.
13) How We Communicate Changes
We may update this policy as services or laws change. Material changes will be communicated to Community administrators and posted with a new effective date.
14) Contact
Privacy & OCAP inquiries:
Dee Albert, Privacy Officer
[email protected] | 1.306.441.8388
Community-specific requests: Contact your Community Housing Office or administrator.
