Elections Policy

Policy Sponsor: Director, Engagement, Partnerships, and Communications
Approver: Board of Directors
Initial Approval Date: May 18, 2022
Date of Last Revision, if applicable: N/A
Effective Date: June 1, 2022

Policy Statement

Toronto Seniors Housing Corporation (TSHC) is committed to working with tenants, candidates, political parties, and public officials at all three levels of government to facilitate elections and election activities on TSHC-managed property, in accordance with applicable legislation, by-laws, and TSHC policies.

During municipal, provincial, and federal election campaigns, TSHC will:

• ensure tenants’ personal information is kept private and confidential, in accordance with applicable legislation and internal protocols
• ensure that TSHC resources are not used to promote or give advantage to any candidate, political party or registered third party
• ensure that inquiries from candidates, political parties, or their agents are managed by the Communications Team
• support employee participation in political activities by granting unpaid leave to those seeking election

Policy Objectives

The objectives of this policy are to:

• outline TSHC’s responsibilities during elections
• outline how TSHC resources can and cannot be used during election campaigns, and which requests can and cannot be accommodated
• guide the conduct of TSHC’s employees and Board members during election campaigns in compliance with applicable legislation, by-laws and TSHC policies
• guide the conduct of TSHC’s employees and Board members seeking political office

Scope

The Elections Policy (Policy) governs election-related activities on TSHC-managed property and the actions of TSHC’s employees and Board members related to elections.

The Policy applies to:

• municipal (including school board), provincial or federal elections, or by-elections and to questions on the ballot
• all TSHC employees, Board members, and tenants, including those running for political office
• TSHC resources, including, but not limited to, employees, events, facilities, funds, information, and infrastructure

Definitions

Campaign/Campaigning: any activity by or on behalf of a candidate, political party, registered third party or in support or opposition to a question on a ballot, meant to elicit support during the election period. Campaigning does not include the appearance of elected officials, other candidates or registered third parties at an event in their personal capacity without the display of any signage or graphic which identifies the individual as a candidate or registered third party and without the solicitation of votes.

Campaign Materials: Any advertising or promotional materials intended to influence persons to vote for or against a candidate, political party, or a question on a ballot. Materials may include literature, banners, posters, pictures, buttons, clothing, etc. Election materials also include materials in all media, including websites or social media.

Elected Official: An individual elected to the House of Commons, the Legislative Assembly of Ontario, Toronto City Council, or a school board.

Election: An election or by-election at the municipal, provincial, or federal level, or the submission of a question on a ballot to the electors.

Election Officials: Employees of Elections Canada, Elections Ontario, Toronto Elections, or their agents.

Election Period: The official campaign period of an election.

• For municipal elections, the election period commences on May 1 of an election year and ends on election day.
• For provincial and federal elections, the election period commences the day that the election writ is issued and ends on election day.
• For by-elections, the election period commences when the by-election is called and ends on election day.
• For a question on a ballot, the election period commences when the respective level of government passes legislation or a by-law to put a question to the electorate. It ends on election day.

Employee: Includes management and exempt employees, contract-managed employees, and all members of TSHC bargaining units.

Leadership Team (LT): Team of senior leaders responsible for the strategic management of the corporate and operational functions of TSHC.

Official Election Materials: Any materials provided to voters by Elections Canada, Elections Ontario, Toronto Elections, or their agents to facilitate voting.

Personal Information: As defined in the Municipal Freedom of Information and Protection of Privacy Act, includes recorded information about an identifiable individual.

Political Office: The elected offices of municipal, provincial, or federal government.

Question on a Ballot: Any question submitted to electors by the municipal, provincial, or federal government.

Registered Third Party: In relation to a municipal election, an individual, corporation, or trade union that is registered with the City Clerk, in accordance with the Municipal Elections Act, section 88.6, whose purpose is to promote, support, or oppose a candidate for office, or an issue on a question on a ballot, and is not under the direction of a candidate.

Toronto Seniors Housing Corporation (TSHC) Resources: Including, but not limited to, employees, funds, events, facilities, information, and infrastructure, as defined below:

• “Election Day” means the day on which an election is held. This is the day most people go to vote.
• “Events” means events funded or organized by TSHC, including events that may be jointly organized with tenants, community organizations, and/or external sponsors.
• “Facilities” means common areas or grounds of any facility which is managed by TSHC.
• “Information” means any information in the custody and control of TSHC, including databases that may be the repository of names, contact information, business records, financial information, personal information, or other identifiers compiled and used by TSHC employees to carry out TSHC business. This information is considered TSHC property, and in most cases, it is not known to the public and may be confidential. It must not be used or disclosed without proper authorization, and in accordance with the Municipal Freedom of Information and Protection of Privacy Act.
• “Infrastructure” means any physical or technological systems and equipment that support the operation of TSHC, including, but not limited to, fleet vehicles, computer networks, telecommunications systems, wireless equipment, mobile phones, computer hardware, software and peripherals, internet, and intranet.

Roles and Responsibilities

• Communications Team: As policy owner, the Communications Team is responsible for the administration of this policy. All issues with respect to this policy and guidelines should be directed to the Communications Team.
• Department Leads: Department Leads are responsible for the application of this policy and guidelines to TSHC resources, facilities, and employees they manage.
• TSHC Employees: Employees are responsible for understanding and applying the Elections Policy and guidelines and for seeking clarification and advice from Department Leads if required.

Policy Content

The Elections Policy provides detailed information in the following areas:

• election activities on TSHC-managed property
• election signs
• protection of tenant privacy
• election-related inquiries
• use of TSHC resources during an election campaign
• workplace conduct during an election campaign
• employees seeking political office

Election Activities on TSHC-Managed Property

TSHC employees must ensure that:

• election officials, candidates, and their agents provide proper identification and display that identification to gain access to TSHC-managed property for election-related work
• election officials, candidates, and their agents have reasonable access to TSHC-managed property to perform their duties in accordance with the Residential Tenancies Act

TSHC employees will not:

• discard or tamper with official election materials (e.g., voter registration, voter identification cards, polling location information, etc.) delivered to tenants by election officials or their agents
• discard or tamper with campaign materials (e.g., pamphlets, flyers, letters, etc.) delivered to tenants by candidates, political parties, registered third parties or their agents

Election Signs

The City of Toronto’s Municipal Code provides rules and regulations regarding election signage that candidates must observe for any election in the City of Toronto.

• Signs cannot be illuminated or attached to trees.
• Signs cannot be placed between the curb and the sidewalk.
• Signs cannot interfere with the safe operation of vehicular traffic or with the safety of pedestrians.
• Signs cannot be located adjacent to a voting place.
• Signs may only be erected with the consent of the tenant.
• Signs may be higher than two meters above ground level provided they are displayed indoors. They cannot be attached to the outside of a balcony or terrace.
• No person is allowed to deface or willfully cause damage to a lawfully erected election sign.

Election signs may be erected on TSHC-managed property subject to compliance with the City’s rules and the following conditions:

• Tenants are permitted to post election signs anywhere considered to be within their personal unit. This includes fenced-off yards and ground-level fences attached to their unit.
• Tenants are not permitted to post election signs on their balconies.
• Election signs cannot be posted in common areas.

TSHC employees are required to remove election signs from common or prohibited areas, or signs that do not comply with City rules.

Protection of Tenant Privacy

TSHC is committed to protecting personal information consistent with the principles outlined in the Municipal Freedom of Information and Protection of Privacy Act and the Housing Services Act. TSHC employees must not provide tenant lists or other personal information about tenants to election officials, candidates, political parties, registered third parties, or their agents.

Election-Related Inquiries

• All election-related inquiries to employees or Board members from political parties, candidates, registered third parties, and/or their agents must immediately be directed to the Communications Team. Employees should also inform their managers of the inquiry.
• TSHC will share information with candidates, political parties, and/or their agents provided it contains no confidential information or personal information about tenants.
• Information that is provided by TSHC to one candidate or political party during an election period will be provided to all others, either by posting the information online or through other means.
• Requests made by a candidate, political party, or registered third party for a personal meeting or tour with an Officer, Board member, Leadership Team member or other TSHC employee during an official election period will not be accommodated.

Use of Toronto Seniors Housing Corporation (TSHC) Resources

• Elected officials may attend TSHC events and/or events held at TSHC facilities in their capacity as elected officials; however, they may not solicit votes, display election signs, or distribute campaign material.
• Candidates, representatives of political parties, and registered third parties may attend TSHC events and/or events held at TSHC-managed facilities as private citizens but may not campaign while in attendance. They may not solicit votes, display election signs, or distribute campaign material.
• Once the writ is issued for Provincial or Federal elections, Members of Parliament (MPs) and Members of Provincial Parliament (MPPs) are no longer elected officials and should not be invited to attend TSHC events in their capacity as elected officials.
• TSHC cannot make a contribution including money, goods, and services to any candidate, political party, or registered third party.
• TSHC resources cannot be used to promote one candidate, political party, or registered third party over another during an election period.
• TSHC supports tenant engagement in elections. To facilitate this engagement, all-candidates meetings may be held at TSHC-managed facilities, where practicable, provided that all registered candidates are invited to attend.
• After August 1 in a municipal election year, TSHC will not reference the name of members of City Council in:
  • advertising and other communications materials paid for or distributed by TSHC
  • event signage, including banners and posters
  • media releases issued by the Communications Team
• If it is necessary to reference a specific member of City Council or the Mayor in TSHC communications or media materials after August 1 in a municipal election year, the generic term “Councillor Ward XX” or “Mayor of Toronto” must be used.
• TSHC communications materials, including websites or domain names funded or administered by TSHC, and social media, blogs, or other new media created and managed by TSHC employees, whether for internal or public distribution, must not:
  • profile (name or photograph), refer to, and/or identify any individual as a candidate, or any individual or entity as registered third party, in any election
  • profile any slogan or symbol associated with a candidate, political party, or registered third party during the election period
  • advocate for or against a particular candidate, political party, or ballot question position during an election period
• Photographic or video materials created by TSHC employees or with TSHC resources cannot be used in any campaign materials.
• TSHC’s logo cannot be used in any campaign material.

Workplace Conduct During an Election Campaign

TSHC recognizes the right of employees to participate in political and election activities balanced against the corporation’s legitimate interest in both being and appearing to be non-partisan.

TSHC employees are not permitted to:

• use or allow the use of TSHC resources for campaign activities. TSHC resources include, but are not limited to, employee time, as well as events, facilities, funds, information, and infrastructure.
• engage in campaign activities during working hours. Working hours do not include vacation time or time on leaves of absence.
• display election campaign items at work.
• attend campaign events or undertake campaign activities while in TSHC clothing.
• solicit funds for a candidate from co-workers, either at work or outside of work.

The Chief Executive Officer of TSHC and members of the Leadership Team are not permitted to campaign for a candidate or political party before or during municipal, provincial, and federal elections.

Employees Seeking Political Office

TSHC employees seeking to run for political office must first declare a potential conflict in writing to their Department Lead and receive authorization prior to filing their candidacy. The employee must provide written notice to their manager at least two weeks in advance of their intention to take unpaid leave.

• For municipal elections, the leave must start the next working day after the employee files their candidacy.
• For provincial and federal elections, the leave must start the next working day after the employee receives the nomination.

Conflict of Interest

• Employees on an approved leave of absence from TSHC remain employees of the organization and are bound by all TSHC policies.
• While campaigning, employees on political leave must clearly state at all times that the views they express are personal views, and not those of TSHC.

Salary and Benefits

• Political leave is unpaid, and benefits can be continued at the employee’s expense.
• For management and exempt employees, continuous service and vacation entitlement are not affected by a leave without pay, where the leave is for twenty (20) business days or less.
• Bargaining unit employees are subject to the provisions in their existing collective agreement.

Election to Political Office

• An employee who is elected to political office within the geographical boundaries of the City of Toronto must resign from TSHC.
• An employee who is elected to political office outside of the geographical boundaries of the City of Toronto must resign from TSHC if the political office will interfere with their ability to perform their regular duties, as determined by their Department Lead.
• The resignation must take effect no more than two weeks after the election and prior to the commencement of the term of office.

Rehiring

• TSHC has no obligation to rehire employees who have resigned their position to take political office. Rehiring would be subject to TSHC’s hiring policies.

Board Members Seeking Political Office

TSHC Tenant Directors (Board members) seeking political office should refer to the rules set out in the Board of Directors Conflict of Interest Policy.

Related Legislation, Regulations, and TSHC Policies:

Legislation and Regulations

• Federal Elections Act
• Election Act
• Municipal Elections Act
• City of Toronto Municipal Code
• Residential Tenancies Act
• Housing Services Act
• Municipal Freedom of Information and Protection of Privacy Act
• Personal Information Protection and Electronic Documents Act

TSHC Policies and Procedures:

• Board of Directors Conflict of Interest Policy
• Board of Directors Code of Ethics and Conduct Policy
• Employee Code of Conduct Policy
• Employee Conflict of Interest Policy
• Guidelines for Elections Policy
• Media and Issues Protocol
• Voluntary Leave without Pay Policy

Amendments (Revision History):

N/A

Next Scheduled Review Date: 2027

This policy will be reviewed once every 5 years.

Policy Contact

Manager, Communications and External Affairs

Appendices

Guidelines for Elections Policy

Social Media Policy

Policy Owner: Engagement & Communications Team
Approval: Board of Directors
First Approved: May 18, 2022
Effective Date:

Policy Statement

The Social Media Policy guides the approval and use of social media for official Toronto Seniors Housing Corporation purposes to ensure such use is consistent with the corporation’s mission, vision and values while upholding all relevant policies, legislation and the protection of privacy.

Scope

This policy applies to all employees, and all consultants or independent contractors acting on behalf of Toronto Seniors Housing Corporation who are posting content to or sharing information on social media channels, including but not limited to social networks (including Twitter, Facebook, YouTube, LinkedIn, SnapChat, TikTok, Reddit, Instagram, Tumblr, etc.), blogs, and online communities.

This policy is not intended to limit the ability of Toronto Seniors Housing Corporation employees who, in their private capacity, use social media. However, as social media is a public activity, this policy also outlines considerations for employees using social media for personal purposes.

Values

Toronto Seniors Housing Corporation recognizes that social media are important channels for serving our tenants, engaging partners in building vibrant communities, and for telling the story of how our work benefits tenants and the city as a whole.

All corporate Toronto Seniors Housing Corporation social media use must adhere to practices consistent with the corporation’s mission, vision, and values.

Standards

Toronto Seniors Housing Corporation considers online and social media channels to be comparable to other communications and service delivery channels.

Definitions

Content owner: The employee assigned the responsibility of maintaining, monitoring, and moderating an official social media channel.

Official purposes: Sanctioned social media communications hosted in Toronto Seniors Housing Corporation’s name, including on behalf of any Toronto Seniors Housing Corporation program, in support of a business objective or strategic priority of the corporation, where the communication is part of an approved communications plan.

Private Information: Any information regarding an identifiable individual, which may include, but not be limited to, the individual’s background, race, ethnicity, nationality, age, religion, political views, home address, tenant file, criminal record, social status, education or medical history.

Social Media: Online technologies and practices that people use to share opinions, insights, experiences, and perspectives. Social media can take many different forms, including social networking sites (e.g., Facebook, LinkedIn), microblogging (e.g., Twitter), user- generated content (e.g., TikTok, Snapchat, YouTube, Flickr, Instagram), blogging (e.g., WordPress, Tumblr, Reddit), and online forums including comment sections on websites.

Policy Details

Approval Process

Employees must obtain written approval to use social media for all Toronto Seniors Housing Corporation business purposes. This includes using social media to engage in online interactions and manage a channel to support a Toronto Seniors Housing Corporation program or initiative.

Responsible Use of Social Media for Business Purposes

When using social media for business purposes, employees should conduct themselves in a professional manner and uphold Toronto Seniors Housing Corporation’s mission, vision, and values. In addition to the guidelines outlined in the Social Media Procedure, content owners must adhere to the following:

• Social media activities and interactions must uphold the mission, vision, and values of the corporation.
• While conducting Toronto Seniors Housing Corporation business, employees should only use approved social media accounts set up specifically for official purposes or approved for business
• Content owners must make every reasonable effort to respond to concerns or questions directed to social media account(s) for which they are responsible.
• Because records on external social media platforms are not within the control of Toronto Seniors Housing Corporation, content owners must refrain from any posts that disclose Toronto Seniors Housing Corporation tenant, employee or other stakeholder personal information, including but not limited to address, phone number, account number, and reference numbers for work orders or other database reports.
• Exchanges must be redirected to Toronto Seniors Housing Corporation phone and/or email support channels whenever personal information is involved or discussions involve more details than the channel can accommodate.
• Personal information, including photographs or videos of identifiable individuals, must not be shared without express consent of Toronto Seniors Housing Corporation and the individual in the photograph or video.
• Posts that provide information that is already public or that seek public input are not considered business records and are permissible uses of social media.
• As many social media channels present accessibility barriers, whenever possible content owners should refrain from using social media channels as the sole avenue for sharing information. Whenever possible, content owners should make their best efforts to use social media channels that comply with Accessibility
• Any and all media requests or issues of concern must be directed to the Communications and Engagement Team immediately, as per the Media and Issues Protocol.
• Employees must comply with the terms and conditions of use that have been established by the social media service Provider.

Personal Use of Social Media

Toronto Seniors Housing Corporation acknowledges that its employees, in their private capacity, may use social media to share information and communicate with friends, family, co-workers, and members of the public.

Employees of Toronto Seniors Housing Corporation are encouraged to engage through social media in a way that supports the mission, vision, and values of the corporation.

Employees should be aware that, due to their role with Toronto Seniors Housing Corporation, any personal activities on social media could impact the reputation of the organization and/or the interests of our tenants.

Employees are reminded that even though they are using social media for personal purposes, policies and protocols such as the Code of Conduct Policy, the Computer, Internet and Email Use Policy, the Media and Issues Protocol and related policies apply to activities on social media.

Considerations for employees who use social media for personal purposes are included in the Social Media Procedures.

Terms of Use

All Toronto Seniors Housing Corporation social media channels must post and abide by the Terms of Use, which are contained in the Social Media Procedure and posted on the corporation’s external website.

Compliance and Monitoring

Toronto Seniors Housing Corporation reserves the right to monitor content posted on social media channels and to modify or remove any content that it deems, in its sole discretion, to be in contravention of Toronto Seniors Housing Corporation’s policies or guidelines or relevant provincial and federal legislation, or that could be detrimental to the corporation’s mission, vision, and values.

Toronto Seniors Housing Corporation reserves the right to take appropriate action to any incident on social media or non-adherence to this policy, which could include:

• Issuing a correction, apology, or other response;
• Deleting a comment or post;
• Decommissioning a social media account;
• Disciplinary action up to and including dismissal, in accordance with the collective agreement where relevant;
• Pursuing legal action where appropriate;
• Revoking social media access rights for an employee or employee(s);
• Alerting senior management and/or the Board of Directors;
• Developing recommendations to prevent similar incidents from re-occuring.

Governing and Applicable Legislation

• Municipal Freedom of Information and Protection of Privacy Act
• Ontario Human Rights Code
• Canada Copyright Act

Related Policies and Procedures

• Employee Code of Conduct Policy
• Media and Issues Protocol
• Computer, Internet and Email Policy
• Workplace Violence and Workplace Harassment Policy
• Records Management Policy
• Social Media Procedure

Commencement and Review

Revision	Date	Description of changes	Approval
First approval:	May 18, 2022	New	Board of Directors
[Revision #]		n/a
Last review:		n/a

Next Scheduled Review Date:

The proposed review period for this policy is every two years.

Translation and Interpretation Policy

Summary of Policy

This policy sets out Toronto Seniors Housing Corporation (TSHC)’s commitments to communicate to tenants in multiple languages to enable tenant participation and promote tenant communication.

Introduction

TSHC recognizes that the City of Toronto is made up of many peoples and cultures. TSHC is committed to providing an inclusive housing environment in which all individuals are equally valued and fairly treated.

TSHC recognizes that many tenants communicate in a language other than English. In addition to English, there are at least 13 commonly used languages to communicate in our communities. The Housing Services Act requires TSHC to provide translation and interpretation services for the French language where requested. TSHC provides translation/interpretation at the building, community and cross organizational level for at least 12 languages in addition to English and French.

This policy has been adapted from TCHC Translation and Interpretation Policy.

Purpose

The purpose of this policy is to enable tenant participation; maximize tenant understanding of matters affecting tenancy and their daily lives as tenants; provide clear direction to Toronto Seniors Housing Corporation staff regarding translation and interpretation; provide direction to other tenant facing translation and interpretation needs.

The policy helps to meet the goal of providing an inclusive housing and working environment, which is a commitment made in Toronto Seniors Housing Corporation’s policy on Human Rights, Harassment and Fair Access.

This policy focuses on both translation of materials and interpretation services to tenants.

Application of Policy

This policy applies to:

• Rent Geared to Income and Market Rent Tenants;
• Direct and Contract Managed Communities;
• TSHC Contracts for service in which tenant engagement is required.

Definition

For the purposes of this policy, the following definitions have been taken from applicable legislation:

• Translation is changing one written language into another written language.
• Interpretation is changing the spoken word into another spoken language and is an interactive

Principles

Tenants require access to information that affects: 

• the status of their tenancy in Toronto Seniors Housing Corporation,
• their daily lives as tenants,
• their ability to participate in decision-making processes that ultimately can affect their

Policy statement

TSHC will use translation and interpretation services to promote tenant understanding and engagement to enable full participation for tenants in TSHC issues and activities.

Language Preference

TSHC will develop a methodology to collect and analyze the language of preference for TSHC tenants; Translation will be provided based on the identified needs of the target audience of the communication, which may include:

• The top languages of a building;
• Identified languages of a specific group, e.g. tenant representatives;
• Regional Managers will review the language preferences in the communities on a regular basis, at a minimum during the annual business planning process and share information with Communications team;
• When TSHC receives written communication in a language other than English, TSHC will have this communication translated and reply in the language of the tenant’s choice;
• TSHC will ensure that a translation and/or interpretation strategy is incorporated into each communication plan and community engagement activity undertaken;
• TSHC will provide advance notice of meetings to ensure tenants requiring or requesting translation and/or interpretation services are able to do so in advance;
• Regional Managers will ensure that strategies for translation and interpretation are developed to meet the identified language preferences of tenant representatives;
• TSHC will provide interpreters at tenant meetings and other events where tenants and/or staff have identified the need for interpreters;
• Toronto Seniors Housing Corporation recognizes its obligation to provide communications regarding housing services in the French language as requested.

Translation of written communication

TSHC will normally translate the following types of written communication:

• Invitations to participate in consultation sessions, tenant election activities, and building meetings;
• Newsletters, information notices and other communication where the primary audience is tenants;
• Tenant Policies and Procedures;
• Tenant handbooks or similar information materials;
• Building signage in each building’s top languages (e.g., laundry room instructions, fire exit procedures).

Toronto Seniors Housing Corporation will translate materials that affect tenants as described above. This includes, but is not limited to, materials such as:

• Contracts, Leases, Legal Notices,
• Strategic plans

TSHC and Tenant Responsibilities

• Tenants will provide as much notice as possible, in advance of a meeting, to advise TSHC that they are requesting translation and/or interpretation services OR that they no longer require the requested translation and/or interpretation
• TSHC will make use of international symbols and drawings to improve the communication with all language
• Documents on corporation-wide issues will be translated into the languages that are needed.
• Toronto Seniors Housing Corporation staff will provide interpreter services for meetings or telephone conversations with individual tenants where tenancy issues are being discussed. Staff will also arrange for interpreter services where tenants are using the corporation’s complaints procedure.

Standards

• TSHC will develop and communicate to stakeholders a set of standards to be applied to translation and interpretation services;
• TSHC will develop a pool of approved translators and interpreters and make it available to all

Policy Review

This policy, and the costs associated with its usage, will be reviewed as part of the annual planning process.

Applicable Legislation and Reference Documents

The following legislation and reference documents apply:

• Tenant Protection Act, 1997;
• Housing Services Act, 2011;
• TSHC Community Management Plan (CMP);
• TSHC Human Rights, Harassment and Fair Access

Approvals

Approved by the TSHC Board of Directors, May 18, 2022.

Policy Contact

Strategic Communications & Engagement

Enterprise Risk Management

Policy Sponsor: Director, Strategy and Business Management
Approver: Board of Directors
Initial Approval Date: October 24, 2024
Effective Date: November 1, 2024

Policy Statement

The mandate of Enterprise Risk Management (ERM) is to promote risk-informed decision making and support the effective execution of TSHC’s strategic directions and business plans by implementing an enterprise-wide risk management framework.

Policy Objective(s)

The objective of this Policy is to articulate the Corporation’s approach to ERM and provide an overview of the related roles, responsibilities and accountabilities.

ERM is a common practice utilized by organizations across a variety of sectors which aims to manage the risk necessary in the pursuit of strategic priorities and objectives. ERM forms part of the overall management system, helping to improve decision-making capabilities throughout the Corporation.

Scope

The ERM Policy outlines TSHC’s philosophy and approach to the management of risk exposures across the corporation. The Policy highlights the structure and processes contained within the ERM framework. In addition, this Policy outlines the key roles and responsibilities for ERM with TSHC.

Definitions

Enterprise Risk Management (ERM): the coordinated activities to direct and control risks within an organization. This includes assessing risks, communicating risks, assigning responsibility for risks, identifying mitigating strategies to avoid or lessen risk, planning risk response strategies and reviewing and improving risk management based on lessons learned from risk experience.

ERM Framework: the suite of policies, procedures, tools and training that support Enterprise Risk Management within the Corporation. The ERM Framework includes the ERM Policy, the risk management process and supporting tools and procedures.

Risks: the likelihood that there will be a positive or negative deviation from the expected objective. Risk is inherent in any business venture. Risks can be threats or opportunities and are measured by likelihood or probability of occurrence and the impact or consequences should they occur. Risks will be classified as insignificant, minor, moderate, major, or severe.

Risk Appetite: the general amount of risk the corporation is willing to accept, which has an influence how risks are assessed and treated. Defining risk appetite will help TSHC develop risk mitigation and risk response strategies appropriate to the Corporation’s needs.

Risk Assessment: Overall process of risk identification, risk analysis, and risk evaluation.

Risk Monitoring and Reporting: The process of communicating risk to different stakeholders. Monitoring risk is a continuous activity that results in awareness throughout the Corporation.

Risk Register: A listing of strategic risks (with impact and likelihood assessed) will form the risk register.

Roles and Responsibilities

Board of Directors

The Board of Directors has responsibility for providing effective oversight of the corporation’s risks and risk management processes. This includes:

• approving the Policy, risk register, heat map, and risk appetite on an annual basis
• receiving reasonable assurances on a regular basis from Management, External Auditors and Internal Audit (e.g., attestations, third-party reports, etc.) on the efficacy of the organization’s internal controls
• receiving detailed presentations from Management on individual risks or groups of risks as required or as requested, and
• receiving quarterly briefing from Management on changes to the organization’s risks, emerging risks, and planned responses/mitigation actions

Note: These responsibilities have been delegated to the Audit, Finance and Risk Committee (AFRC) and are included in the Committee’s list of accountabilities as outlined in their Terms of Reference. However, the Board retains the collective, overarching oversight of the risk management program.

Chief Executive Officer

The Chief Executive Officer acts as the ultimate management body responsible for risk, acting as the key conduit between the Board of Directors and Management within the governance structure.

Leadership Team

The Leadership Team acts as the ultimate management body responsible for risk, in conjunction with the processes and efforts to manage performance and the achievement of strategic directions.

Director, Strategy and Business Management

The Director, Strategy and Business Management is responsible for the ownership and management of this Framework and the ERM Program as a whole. This includes ensuring that the right supports and tools are in place to enable staff to identify, assess, manage and monitor risks relevant to the Corporation.

Risk Owner

Each risk identified by TSHC must have a designated Risk Owner (i.e., the Division and/or Department) responsible for the overall management of the risk.

Subject Matter Experts

Subject Matter Experts are comprised of staff members or key partners (e.g. TCHC) who have subject matter knowledge and expertise to inform and guide the management of risks. They ensure that risks relevant to the achievement of business objectives are considered from all relevant perspectives, and that potential impacts of a risk (new or revised) can be assessed well in advance of that risk becoming a reality.

Employees

Employees are responsible for integrating risk management into their day-to-day activities. This includes applying the risk management process in their respective functions, informing management of new risks and significant changes to current risks, and providing requested information required for reporting.

Policy Content

Principles

The following principles will guide risk management at TSHC.

• We recognize that risk – and risk management – is part of our day-to-day work.
• We will balance risk and reward, working to do the right thing to maintain the trust of our tenants, staff and stakeholders.
• We understand that everyone has a role to play in managing risk, and we work to establish clear accountability for understanding risks.
• We know that risk is dynamic, and we seek to evolve to ensure that we manage risk in a way that is aligned with the needs of our operating environment.

Risk Management Process

General Approach

Structure and consistency in process and approach is key to successful risk management. TSHC’s risk management processes are aligned to the principles of the ISO 31000 Risk Management standard. The steps of our general risk management method are depicted below:

1. Establish scope, context and criteria
2. Risk Identification
3. Risk Analysis
4. Risk Evaluation
5. Risk Treatment
6. Monitoring and Review

Reporting

The Corporation will provide regular reporting on its enterprise-wide risks to provide decision-makers with a comprehensive and integrated view of its key risks. Risk reporting will be conducted in accordance with the procedures and processes defined in the Corporation’s ERM Framework. Risk reporting will provide information on risks and risk levels (i.e., impact and likelihood), risk treatment plans and the status of risk mitigation activities, and risk indicators to support monitoring of changes in risk trends.

Regular reporting will include:

• Risk reports to be reviewed and actioned by the Leadership Team
• Risk reports on key/top risks (i.e., risks with the highest impact and likelihood) that describe planned risk treatment, status against risk treatment action items, overall status of risk action plans, and trends in risk ratings to the Leadership Team to focus detailed reviews of the most relevant risks
• Consolidated risk and performance reports on top/key risks and emerging risks to the Board of Directors and the AFRC

Related Legislation, Regulations, and TSHC Policies:

• TSHC Audit, Finance, and Risk Committee Terms of Reference (TOR)

Amendments (Revision History):

Initial policy approved by Board of Directors on October 24, 2024, effective November 1, 2024.

Next Scheduled Review Date: 2027

This Policy will be reviewed once every three years.

Policy Contact

Director, Strategy and Business Management

Appendices

• ERM Framework

Fraud Prevention Policy

Policy Sponsor: Finance Lead
Approver: Board of Directors
Initial Approval Date: February 26, 2025
Effective Date: February 26, 2025

Policy Statement

This Policy has been established as part of the Toronto Seniors Housing Corporation’s (TSHC’s) controls to assist in the prevention and detection of fraud. The Policy sets out responsibilities for reporting suspected fraud and provides guidelines for the conduct of investigations.

TSHC is committed to protecting its revenue, property, information, reputation and other assets from attempts, by those working for, or on behalf of TSHC, to improperly gain either financial or other benefits to the detriment of TSHC or its interested parties. TSHC requires its employees to act with personal integrity, ethics, honesty, and diligence in performing duties, and to safeguard the assets of the corporation. All employees have an obligation to immediately report any activity by a colleague, contractor, or tenant that appears to violate applicable laws, rules, regulations, TSHC Codes of Conduct or policies. This includes neither facilitating or ignoring current and/or past incidents of suspected fraud when identified. Fraud or misuse of TSHC assets will not be tolerated.

TSHC is committed to promoting integrity, ethics, accountability, and transparency, as well as maintaining an environment where people can raise concerns without fear of reprisal. TSHC is also committed to enhancing public trust and confidence in TSHC. TSHC will investigate all allegations of fraud or corruption, including but not limited to tenant misuse of TSHC Community Activities Funds and Rent-Geared-to-Income (RGI) fraud.

Every reasonable effort will be made to recover any gains obtained by, or receive compensation for any damages to TSHC caused by, fraud or misuse. Actions will be taken to deal with those who defraud TSHC or who are found to be corrupt.

TSHC will follow the protocol for housing providers, referenced in the City of Toronto’s Rent-Geared-to-Income (RGI) Administration Manual, when instances of fraud by RGI households are identified or comes to the attention of TSHC.

Policy Objectives

This Policy provides a framework within which TSHC can meet the following objectives:

• Take appropriate measures to prevent, detect and investigate fraudulent activities and other acts of misconduct.
• Provide staff and the public with an anonymous reporting channel when fraud or corruption is suspected, by implementing an ethics hotline.
• Provide guidelines and delineate responsibilities for investigations.
• Manage claims diligently with respect and discretion.

Scope

This policy applies to all current and former members of the Board of Directors, employees (whether they work on a full-time or temporary basis), volunteers, contractors, agencies, and organizations working for TSHC.

Out of Scope

This Policy covers matters that are in the public interest and for which there are no existing processes or mechanisms for reporting and investigation. For example, it is not intended to address matters through existing procedures where corporate policy and/or collective agreements (if applicable) are generally available to address individual complaints by employees of workplace discrimination or harassment.

Disclosures of fraud (that are not investigated or addressed under the Fraud Prevention Policy) will be referred to the appropriate investigator and/or investigated in accordance with the provisions of TSHC’S Whistleblower Protection Policy.

Definitions

Anonymous reporting channel: is a secure, anonymous and confidential way to raise concerns or report fraud or unethical behaviour to TSHC. Reports involving employees or members of the Board of Directors will be received by the Director, People and Culture. Where the Director, People and Culture is implicated in an allegation the report will be received by the Chief Executive Officer. For more information on how to report possible fraud to the anonymous hotline please refer to the Frequently Asked Questions document.

Contractor: Any person or entity, including their employees, that have been contracted, sub-contracted, or otherwise engaged to supply goods or services to the TSHC including a vendor, supplier, consultant, or service provider.

Fraud: A dishonest act that results in actual loss or risk of loss, deception, misappropriation of resources or the manipulation of data to the advantage or disadvantage of a person or entity. Fraud includes any misuse, or attempt to misuse:

• One’s position in the company, and/or
• TSHC asset or TSHC property for personal gain or purposes unrelated to company business.

Fraud includes corruption. Corruption is defined as offering, giving or soliciting, or accepting of an inducement or reward that may improperly influence the action of a person or entity.

Examples include, but are not limited to:

• Forgery or alteration of cheques, drafts, promissory notes, securities records, documents, or other similar instruments.
• Obtaining company funds or compensation through dishonesty.
• Falsifying accounts, records (including expense claims and time sheets), or other documents required for any accounting purpose with a view to personal gain, or gain for another, any claim for reimbursement of expenses that are not made for the exclusive benefit of TSHC, or any irregularity in the handling or reporting of money transactions.
• Unauthorized use or misuse of TSHC property (including equipment, materials, or records and proprietary or confidential information) and time.
• Any computer-related activity involving the alterations, destruction, forgery, or manipulation of data for fraudulent purposes or misappropriation of TSHC or Toronto Community Housing Corporation owned software.
• Profiteering as a result of insider knowledge of company activities.
• Violation of procurement policy or procedures.
• Improper dealings with tenants, vendors or agencies.
• Taking or diverting property, information or other assets belonging to TSHC or other parties (including tenants) through fraud, deception, extortion or other illegal means.
• Intentionally destroying or defacing TSHC property or assets, or disclosing confidential information to outside parties.
• Acts of bribery, which can include acceptance of secret commissions, seeking or accepting anything of material or personal value from vendors, consultants, or contractors doing business with TSHC, or from tenants or applicants for housing with TSHC (such as provision of an unauthorized benefit to a tenant including, but not limited to, an unauthorized reduction of the rent payable by a tenant, unauthorized internal transfers to another unit or unauthorized determination of eligibility for rent-geared-to-income assistance).
• Exercising authority or influence over a matter where a conflict of interest exists, including violations of TSHC’s Employee Conflict of Interest Policy, TSHC’s Board of Directors Conflict of Interest Policy, or violation of the conflict of interest provision in the Housing Services Act.
• Conspiracy, to commit fraud with others.
• Any similar or related irregularities.

This Policy also applies to:

• Stealing or removing company assets (theft), any misappropriation of funds, securities, supplies, furniture, fixtures, equipment, software or other assets, and
• Extortion, such as threatening action, unless some benefit is received.

Good faith: means an act which is not done trivially, frivolously, or for a vexatious purpose.

Investigator: A staff person or external resource that completes a structured, fact-finding inquiry regarding a fraud, waste, or misuse claim.

Manager: The supervisor or manager to whom an employee normally reports; or in the case of a disclosure of fraud involving the supervisor or manager to whom an employee normally reports, the next-above supervisor or manager in the employee’s chain of command.

Property: TSHC owned, controlled, leased or operated facilities, materials, resources, and assets, including (but not limited to) buildings, land, money, vehicles, phones, phone system, records, files, documentation, office equipment, cell phones, pass cards, computers, computer tools and network, supplies, cheques, and equipment.

Reprisal: Actions taken against another person as a direct result or in retaliation for making a report under this Policy, being suspected of making a report under this Policy, or participating in an investigation under this Policy. Examples of reprisal include but are not limited to:

• coercion
• demotion
• discipline
• discrimination
• dismissal
• harassment
• intimidation
• suspension
• termination

In the case of an employee, reprisal could include any other action which adversely affects their working conditions, or a threat to take any such actions and knowingly directing or counselling of another person to engage in reprisal.

Recovery: The process of attempting to obtain compensation to the Corporation for financial losses caused by proven acts of fraud and misuse.

Risk: the likelihood that there will be a positive or negative deviation from the expected objective. Risks can be threats or opportunities and are measured by likelihood or probability of occurrence and the impact or consequences should they occur.

Whistleblower: An employee, member of the Board of Directors, or tenant, who, in good faith and with reasonable belief that wrongdoing has occurred, makes a report under this Policy or TSHC’s Whistleblower Protection Policy.

Wrongdoing: in this Policy, refers collectively to any serious act (or failure to act) that is covered by this Policy and which:

• constitutes fraud or waste of TSHC resources or assets as defined under this Policy
• is a violation of TSHC’s policies, procedures, or directives
• risks the health or safety of tenants, employees, or visitors to TSHC sites
• is unlawful under any municipal, provincial or federals laws
• knowingly directs or counsels another person to engage in such acts
• is designed or intended to conceal conduct prohibited under this Policy

Roles and Responsibilities

TSHC’s Chief Executive Officer is responsible for:

• Delegating key responsibilities for the administration of this Policy.
• Leading and advancing a culture rooted in the highest ethical standards for TSHC employees.
• Ensuring TSHC employees understand their ethical rights and responsibilities, including their responsibilities under this Policy, and other TSHC policies including Employee Code of Conduct and Employee Conflict of Interest.
• Investigating or referring responsibility to TSHC staff to investigate alleged fraud, and ensure these investigations are appropriately conducted.
• Implementing corrective actions to strengthen management oversight and make improvements to internal control systems and procedures based on findings.
• Informing the Chair and members of the Audit, Finance and Risk Committee of any allegation of fraud involving an employee or member of the Board of Directors of TSHC.
• Ensuring recommendations made by an investigator in their report addressing fraud are implemented on a timely basis including identified systemic issues.

TSHC’s Managers/ Department Directors are responsible for:

• Promoting ethical conduct and supporting ethical decision-making in their areas of responsibility.
• Ensuring TSHC employees understand their ethical rights and responsibilities, including their responsibilities under this Policy, and other TSHC policies including Employee Code of Conduct and Employee Conflict of Interest.
• Assisting employees in the administration, interpretation and application of this Policy, where applicable.
• Instituting and maintaining a system of internal control to provide reasonable assurance for the prevention and detection of fraud, misappropriation, and other irregularities.
• Being familiar with the types of improprieties that might occur within their area of responsibility and be alert for any indicators of such conduct.
• Ensuring that TSHC employees under their supervision, who in good faith, report fraud are protected from reprisals in accordance with this Policy and TSHC’s Whistleblower Protection Policy.
• Immediately reporting allegations of fraud, upon notification from an employee of suspected fraud, or if they have reason to suspect that a fraud has occurred, to the Director of their Department, or to the Chief Executive Officer if the Director of their Department, Director, People and Culture, or Finance Lead are implicated in the allegation.

TSHC’s employees and contractors are responsible for:

• Acting honestly and with integrity, protecting company assets and observing internal controls to safeguard assets.
• Understanding and adhering to this Policy, the procedures and associated documentation.
• Certifying their receipt and review of this Policy. Existing employees will be required to certify their receipt and review of this Policy every year.
• Immediately notifying, in good faith, their manager, Director of their Department, or reporting to the ethics hotline (anonymous reporting channel) if they suspect or have knowledge of any occurrence of irregular conduct, fraud, corruption, or have reason to suspect that a fraud has occurred. Employees are encouraged to raise incidents or suspected incidents with their immediate supervisor or manager. However, employees may remain anonymous when reporting suspected fraud. TSHC uses an independent service provider for a secure, anonymous and confidential way (through the reporting channel) to raise concerns or report unethical behaviour to TSHC.
• Immediately notifying, in good faith, the Chief Executive Officer if they suspect or have knowledge of any occurrence of fraud involving the Director of their Department, Finance Lead, or Director, People and Culture.
• Immediately notifying, in good faith, the Director, People and Culture, if they suspect or have any knowledge of any occurrence of fraud involving the Chief Executive Officer.
• Employees who are proven to knowingly make false allegations or who fail to report serious irregularities will be subject to discipline up to and including dismissal.
• Co-operating fully, if required, in an investigation under this Policy, and will make all reasonable efforts to be available to assist with the investigation.
• Maintaining confidentiality. Employees shall not attempt to investigate suspected fraud or discuss the matter with anyone other than a person to whom the fraud was reported, TSHC staff conducting the investigation, the police, and any other resources deemed necessary. Employees who improperly breach confidentiality will be subject to legal action or disciplinary action up to and including dismissal as determined by the Chief Executive Officer or their designate.
• Directing individuals who want to report possible fraud or misuse to the hotline or appropriate staff person.
• Immediately notifying the Director, People and Culture if they believe they are the subject of a Reprisal, following a disclosure of fraud. An employee informed of, or who becomes aware of, a Reprisal against an employee has a duty to notify the Director, People and Culture, or Chief Executive Officer so that they will undertake to ensure that the employee is protected from any further reprisal. For more information, please see TSHC’s Whistleblower Protection Policy.

TSHC’s Finance Lead is responsible for:

• Providing overall direction on the implementation of this Policy.
• Investigating or referring responsibility to appropriate investigator to investigate alleged fraud, and ensure these investigations within scope of this Policy are appropriately conducted.
• Referring allegations that do not constitute fraud under this Policy to the appropriate contact or investigator for investigation and/ or appropriate action.
• Consulting with the Director, People and Culture, legal counsel, Chief Executive Officer, or their delegates, as appropriate.
• Implementing corrective actions to strengthen management oversight and make improvements to internal control systems and procedures based on findings to prevent future occurrences and minimize risk.
• Informing the Chair and members of the Audit, Finance and Risk Committee of any allegation of fraud involving an employee, contractor, member of the Board of Directors, or tenant of TSHC.
• Informing the Director, People and Culture of allegations of fraud in a timely manner. If the complaint involves the Director, People and Culture, or a member of the Board of Directors, then the Chief Executive Officer shall be informed. If the report involves the Chief Executive Officer, the Finance Lead will notify the Director, People and Culture, who shall confer with the Board Chair.

TSHC’s Director, People and Culture is responsible for:

• Undertaking preliminary review of allegations of fraud and corruption, and applying the Fraud Prevention Policy definitions, that they receive to determine next steps for allegation in accordance with related procedure.
• Investigating or referring responsibility to an investigator to investigate allegation, and ensuring the responsibility for investigations to be appropriately conducted remains with Finance Lead, or Chief Executive Officer if Finance Lead is implicated in allegation.
• Providing oversight, if required, of alleged fraud investigations led by the investigator. The responsibility to ensure such investigations are appropriately conducted remains with the Finance Lead, or Chief Executive Officer if Finance Lead is implicated in allegation.
• Ensuring that employees who, in good faith, report wrongdoing are protected from reprisal in accordance with TSHC’s Whistleblower Protection Policy.

TSHC’s Board of Directors Members are responsible for:

• Understanding and adhering to this Policy, as well as the Board of Directors Code of Ethics and Conduct and Board of Directors Conflict of Interest Policy.
• Immediately notifying the Board Chair if they suspect or have knowledge of any occurrence of fraud.
• Immediately notifying the Vice-Chair of the Board if they suspect or have knowledge of any occurrence of fraud involving the Board Chair.

TSHC’s Board of Directors Chair is responsible for:

• Consulting with the Director, People and Culture on the appropriate actions to take when any occurrence of fraud by Chief Executive Officer is reported. The Board Chair will inform the Board of Directors unless there are extenuating circumstances or where the integrity of the investigation might be compromised during the investigation process.

TSHC’s Audit, Finance and Risk Committee is responsible for:

• Overseeing management’s establishment of an adequate system of internal controls, and procedures and review and monitoring of effective performance of those internal controls and procedures

TSHC’s Director, Operations is responsible for:

• Receiving claims of fraud and misuse regarding tenants, (received through the ethics hotline, staff, or tenants).
• Ensuring claims of RGI fraud received and identified by TSHC follows the City of Toronto’s Rent-Geared-to-Income Administration Manual protocol for documenting and reporting suspected fraud.
• Redirecting claims of fraud related to the Community Activities Fund to the Manager, Community Programs and Partnerships for investigation

Policy Content

Investigation Guidelines

All investigations will be conducted in accordance with the principles of natural justice.

All investigations will be conducted in the strictest of confidence in an objective and impartial manner.

TSHC will investigate, in a timely manner, any suspected acts of fraud or corruption, misappropriation, or other similar irregularity. An objective and impartial investigation will be conducted regardless of the position, title, and length of service or relationship with TSHC of any party who is, might be or becomes, the subject of such investigation. Investigations may include the participation of Toronto Police Services, management representatives from Finance, and/or People and Culture Departments, or any other resources deemed necessary.

Any unionized employee against whom allegations are made will be given opportunity for union representation, as per collective agreement provisions.

Confidentiality

All participants aware of or participating in an internal investigation shall keep the details and results of any investigation confidential. Particulars of the investigation with potential witnesses may be disclosed only if such disclosure would further the investigation and only after consultation with legal counsel and labour relations (as applicable). Throughout the investigation, TSHC Department Directors who have a legitimate need to know will be informed of pertinent investigative findings. To the extent possible by law, the identity of individuals involved in an investigation including the identity of an individual alleging fraud and the identity of the individual alleged to have committed fraud will be protected.

Whistleblower Protection

No person acting on behalf of TSHC, including the Board of Directors shall:

• dismiss or threaten to dismiss an employee
• discipline or suspend, or threaten to discipline or suspend, an employee
• discriminate or harass an employee
• demote an employee
• impose any penalty or reprisal upon an employee
• intimidate or coerce an employee because the employee has acted in accordance with the requirements of the policy

Violation of this section may result in discipline up to and including dismissal.

Actions Following an Investigation

TSHC will pursue every reasonable effort, including court ordered restitution, and/or civil judgments, to obtain recovery of the company losses.

At the discretion of the Chief Executive Officer or their designate, those found to be directly responsible for fraud or corruption will be subject to any or all of the following:

• the requirement to make full restitution of all direct and related costs
• referral to police and prosecution, as may be applicable
• discipline that may include termination of employment with TSHC

Media Inquiries

Any staff person or member of the Board of Directors who are contacted by the media regarding an investigation under this Policy must refer all inquiries to the Communications team. For further information, please see the Media and Issues Protocol.

Compliance and Monitoring

If there are any allegations of fraud involving a TSHC employee or member of the Board of Directors, covered by this Policy, the Finance Lead shall prepare a quarterly report to inform the Chair and members of the Audit, Finance and Risk Committee.

Related Legislation, Regulations, and TSHC Policies:

• Criminal Code
• Housing Services Act
• TSHC Employee Code of Conduct
• TSHC Employee Conflict of Interest Policy
• TSHC Board of Directors Code of Ethics and Conduct
• TSHC Board of Directors Conflict of Interest Policy
• TSHC Procurement Policy and Procedures
• TSHC Board of Directors Reimbursement Policyand Procedures
• TSHC Finance Policies
• TSHC Media and Issues Protocol
• Unions’ collective agreements

Amendments (Revision History):

Initial policy approved by Board of Directors on February 26, 2025.

Next Scheduled Review Date: 2028

This Policy will be reviewed once every three years.

Policy Contact

Finance Lead

Appendices

• Frequently Asked Questions (under review)
• TSHC Media and Issues Protocol

Investment Policy

Policy Owner: Finance
Approval By: Board of Directors
First approved: May 18, 2022
Effective Date: June 1, 2022

Policy Statement

The purpose of this policy is to establish investment principles and guidelines that are appropriate for the purposes of meeting the various capital, financial and other obligations of Toronto Seniors Housing Corporation (TSHC).

Scope

This policy is applicable to TSHC personnel who have been vested with the power and responsibility to transact and invest funds on behalf of the organization. This policy applies to all investments decisions and transactions.

Content

Investment decisions will prudently balance liquidity, risk, growth, and yield and produce a total return that will preserve the real purchasing power of the principal invested.

Cash that is surplus to TSHC’s current requirements may be invested in:

1. Government of Ontario or Canada Treasury Bills
2. Government of Ontario or Canada Bonds
3. Guaranteed Investment Certificates (GIC) issued by a Canadian Chartered

The maximum investment term for excess “in year” operating cash shall be for the period of up to one (1) year.

All investment transactions require the joint written approval of the Chief Executive Officer (CEO) and the Director of Finance.

Responsibilities

The CEO or designate and the Director of Finance have joint authority for transacting and investing funds on behalf of TSHC. The CEO designation of authority is to be in writing to the Director of Finance. The Director of Finance cannot designate his or her authority. The Director of Finance shall prepare a schedule of investments for presentation quarterly to the Audit and Finance and Risk Committee.

Review

The policy shall be reviewed every two years or earlier if deemed necessary by the Director of Finance and amendments shall be presented to the Audit and Finance and Risk Committee for recommendation to the Board of Directors.

Change History:

Revision #	Date of Review	Description of Changes	Approved by:
	May 3, 2022	New Policy

 

Procurement Policy

Policy Owner: Finance
Type: Board Policy
Approval By: Board of Directors
First approved: May 18, 2022
Effective Date:
Last Reviewed:

Policy Summary

This policy guides employees with respect to procurement of goods, services and construction. Toronto Seniors Housing Corporation’s (TSHC) Procurement business cycle is a shared service that Toronto Community Housing Corporation (TCHC) performs on the behalf of TSHC and therefore TSHC will use the procurement procedures in place at TCHC for all TSHC related procurements.

Policy Statement

This Procurement Policy will promote ethical, legal, efficient, effective, professional, and accountable sourcing strategies. Toronto Seniors Housing will use fair, open, and transparent processes to make procurement decisions based on a “value for money” criterion.

“Value for Money” means that the selection of goods, services and construction will be based on an optimal combination of relevant factors beyond the price by leveraging the aggregate spend to achieve economies of scale, where possible. This includes such factors as:

• total cost of acquisition
• quality and fit-for-purpose issues
• product or service lead time and delivery schedule
• vendor performance
• product or service support
• environmental and sustainability issues
• support and maintenance considerations
• end-of-life disposal
• other corporate objectives

Scope

This policy applies to all planning, acquisition and management of goods, services and construction by all officers, directors, employees, agents and designated representatives of Toronto Seniors Housing.

This policy must be read in conjunction with the Procurement Procedures, Procurement Protocols, and Financial Signing Authorities.

Exceptions

This policy does not apply to purchases of the following goods and services:

1. Sale or purchase of real property
2. Goods or services intended for resale to the public
3. Goods or services from other public sector bodies or non-profit organizations
4. Health care services, including services provided by medical doctors, dentists, nurses and pharmacists
5. Utilities, including hydro and electricity
6. Anything covered by the Employee Expense Policy or the Tenant Expense Policy.

Guiding Principles

Effective procurement is a critical support function for public institutions as they responsibly manage public funds. The objective of this policy is to ensure that Toronto Seniors Housing conducts procurement processes that conform to the following principles:

1. Compliance with all applicable laws, regulations, by-laws, policies and trade treaties
2. Consistency with other Toronto Seniors Housing policies and procedures
3. Open, fair, and transparent procurement that affords equal access to all qualified vendors
4. Reciprocal non-discrimination and geographic neutrality with respect to Ontario’s trading partners and avoidance of preferences for local vendors
5. Achieving best value for Toronto Seniors Housing for the expenditure of public funds through consideration of the full range of procurement formats and the adoption of commercially reasonable business practices
6. Achieving maximum benefit for the residents of Toronto Seniors Housing
7. Effective balance between accountability and transparency and efficiency
8. Adherence to the highest standards of ethical conduct

Policy Details

Notification of Procurement Opportunities

Notification of public procurement opportunities shall be listed by Toronto Community Housing on their website and appropriate tendering websites and other media on behalf of TSHC.

Award Information

Final award notifications for all public competitions will be posted online by TCHC.

Unsolicited Bids

Toronto Seniors Housing will not accept or consider unsolicited bids with a procurement value of $100,000 or greater. Unsolicited bids with a procurement value of less than $100,000 may be considered on a case-by-case basis with approval of the CEO, but Toronto Seniors Housing is under no obligation to consider or accept any unsolicited bid.

Conflicts of Interest

Toronto Seniors Housing must ensure that it effectively manages internal and external conflicts of interest. All conflicts must be declared in writing to TSHC Procurement who will then notify the TCHC Procurement Unit.

Internal Conflict of Interest

Toronto Seniors Housing must ensure that the management of all procurement projects is free from internal conflicts of interest.

All participants in the Procurement Project (including all procurement staff, all involved members of the TSHC Business Unit and all members of the evaluation team) must ensure that there are no undeclared internal conflicts of interest.

The Toronto Seniors Housing Board of Directors and staff must not have any direct or indirect involvement in any Procurement Project or decision outside of the required approvals and procurement roles set out in these procedures.

External Conflict of Interest

In addition to ensuring that there are not internal conflicts of interest, Procurement Projects must also be free of external conflicts of interest. All vendors must be required to declare, as part of their Bid in a procurement process, that there are no conflicts of interest, or they must provide details of any actual or apparent conflicts of interest. The TCHC Procurement Unit must ensure that all procurement templates include appropriate conflict of interest language and declarations.

Where a vendor is retained to participate in the development of a Solicitation Document or the specifications for inclusion in a Solicitation Document, that vendor must not be allowed to submit a Bid or directly or indirectly participate in the submission of any Bid in response to that Solicitation Document. While this restriction shall be deemed to apply to all Toronto Seniors Housing Procurement Projects, it must be disclosed in the initial procurement process by which the vendor is retained.

Procurement Record Keeping

Proper documentation must be maintained for all stages of the Procurement Project.

Access to Information

The maintenance, release and management of all procurement records must be in accordance with Toronto Seniors Housing’s Records Retention Policy. Toronto Seniors Housing is subject to the Municipal Freedom of Information and Access to Information

Act. TSHC Procurement and TSHC Business Units in co-operation with Toronto Community Housing will be responsible for any requests for access to procurement-related documents.

Confidentiality

Toronto Seniors Housing must ensure that Bidder and vendor information submitted in confidence as part of a Procurement Project is adequately protected. The TCHC Procurement Unit, TSHC Procurement and TSHC Business Units must ensure that all Bids and contracts are kept in a secure location and only accessible by those individuals directly involved with the Procurement Project.

Procurement Review and Audits

Toronto Seniors Housing shall conduct regular reviews and audits of its procurement activities, procedures and practices to ascertain compliance with this Policy.

Policy Review

The Procurement Policy will be reviewed by TSHC Procurement and the TCHC Strategic Procurement Unit and assessed once every two years to ensure its goals are being met.

The Procurement Procedures will be reviewed and assessed once a year to ensure the integrity of each process and that they are promoting the Procurement Policy objectives.

Accessible Customer Service Policy

Policy Sponsor: Director, Strategy and Business Management
Approver: Board of Directors
Initial Approval Date: May 17, 2022
Effective Date: June 1, 2022

Policy Statement

Toronto Seniors Housing Corporation (TSHC) recognizes that accessibility for persons with disabilities is an important issue that needs to be addressed throughout our portfolio. Toronto Seniors Housing Corporation is committed to the principles of accommodation outlined in the Accessibility for Ontarians with Disabilities Act, 2005 (AODA), the Accessibility Standards for Customer Service, Ontario Regulation 429/07 (the Customer Service Standard), and the Ontario Human Rights Code. The Accessibility Standards for Customer Service, Ontario Regulation 429/07 (the Customer Service Standards) is an accessibility standard created under the Accessibility for Ontarians with Disabilities Act, 2005 (AODA).

Toronto Seniors Housing Corporation will continue to provide customer service for persons with disabilities in a manner that respects their dignity and independence while allowing them the same opportunity as any other customer to access and benefit from our services.

As additional standards identified in the AODA pass into regulation, this policy will be adjusted to include these new standards.

Policy Objectives

In fulfillment of its obligations under the Customer Service Standards and in keeping with its values, this policy outlines Toronto Seniors Housing Corporation’s commitment to provide customer service that is inclusive, barrier free and meets the unique needs of persons with disabilities.

The purpose of this policy is to lay out Toronto Seniors Housing Corporation’s commitment to providing accessible customer service. This policy sets out key customer service commitments in several areas relating to accessibility.

Guidelines will set out detailed procedures and protocols that guide Toronto Seniors Housing Corporation in applying this policy. The policy and Guidelines will inform tenants and the public of our commitment and will guide them in requesting accommodation in service and providing feedback about our services.

Scope

This policy applies to all persons who interact with tenants, members of the public or third parties on behalf of Toronto Seniors Housing Corporation, as an employee, contractor, volunteer, member of the Board of Directors or otherwise.

Key Values

Toronto Seniors Housing Corporation shall provide accessible customer service in accordance with the following key principles:

Dignity

Service is provided in a respectful manner consistent with the needs of the individual.

Independence

Services for persons with disabilities shall support their independence while respecting their right to safety and personal privacy. As such, service delivery shall consider the nature of the service and alternative accommodation that may be required.

Equity/Equality of Outcome

Customers with disabilities will be provided with the same opportunity to access our services as all other customers.

Integration

Customers with disabilities shall fully benefit from the same services, in the same place and in the same or similar way as all other customers.

Definitions

Under the Customer Service Standards (O.Reg. 429/07):

Assistive Device: A device used to assist persons with disabilities in carrying out activities of daily life or accessing the services provided by Toronto Seniors Housing Corporation including, but not limited to, wheelchairs, walkers, canes, note-taking devices, portable magnifiers, recording machines, personal oxygen tanks and devices for grasping.

Barrier: Anything that prevents a person with a disability from fully participating in all aspects of society because oftheir disability, including a physical barrier, an architectural barrier, an information or communications barrier, an attitudinal barrier, a technological barrier, a policy a practice.

Disability: (a) any degree of physical disability, infirmity, malformation or disfigurement that is caused by bodily injury, birth defect or illness and, without limiting the generality of the foregoing, includes diabetes mellitus, epilepsy, a brain injury, any degree of paralysis, amputation, lack of physical co- ordination, blindness or visual impediment, deafness or hearing impediment, muteness or speech impediment, or physical reliance on a guide dog or other animal or on a wheelchair or other remedial appliance or device, (b) a condition of mental impairment or a developmental disability, (c) learning disability, or a dysfunction in one or more of the processes involved in understanding or using symbols or spoken language, (d) mental disorder, or (e) an injury or disability for which benefits were claimed or received under the insurance plan established under the Workplace Safety and Insurance Act, 1997.

Service Animal: An animal trained specifically to assist an individual with a disability, either where it is readily apparent that the animal is a service animal or where a letter has been provided by a doctor or nurse confirming that the person requires the animal for reasons related to a disability.

Support Person: Someone who accompanies a person with a disability and assists them with communication, mobility, personal care, medical needs or with access to goods or services.

Customer Service Commitments

Training

Toronto Seniors Housing Corporation will provide training to all Board Members, employees, volunteers and others who interact with the tenants, the public or other third parties on its behalf, and all those who are involved in the development and approvals of customer service policies and procedures. Training will include the following:

The purposes of the AODA; the requirements of the customer service standard; and any subsequent legislation.

Instruction on Toronto Seniors Housing Corporation’s policies, and procedures pertaining to the provision of goods and services to persons with disabilities, including the customer service standard.

How to interact and communicate with persons with various types of disabilities.

What to do if a person with a disability is having difficulty accessing Toronto Seniors Housing Corporation’s goods and services.

New staff will be trained upon their initial orientation. Following initial training, existing staff will receive training on a regular basis and when changes are made to these policies and procedures or regulations.

Service Animals

Toronto Seniors Housing Corporation is committed to welcoming persons with disabilities who are accompanied by a service animal on the parts of our premises that are open to the public.

If a service animal is excluded by law, Toronto Seniors Housing Corporation will suggest appropriate alternatives and provide assistance in order to ensure that the person is able to access, obtain, use or benefit from Toronto Seniors Housing Corporation’s services where possible.

Support Persons

Any person with a disability who is accompanied by a Support Person will be allowed to access any services provided by Toronto Seniors Housing Corporation with their Support Person. At no time will Toronto Seniors Housing Corporation prevent a person with a disability who is accompanied by a Support Person from having access to their Support Person.

Where there are barriers to access or attendance by a Support Person at sponsored meetings, consultations or events, Toronto Seniors Housing Corporation will seek to facilitate access so as to ensure the participation of persons with disabilities.

Assistive Devices

Persons with disabilities shall be permitted to obtain, use or benefit from goods or services through the use of their own assistive devices. Staff will be trained so as to be familiar with various assistive devices that may be used by customers with disabilities while accessing services.

In the event a person with a disability is hindered from accessing any goods or services offered, Toronto Seniors Housing Corporation will seek to accommodate the person by offering the use of another assistive device that is available or an alternative way of delivering the same service.

Toronto Seniors Housing Corporation will ensure that staff know how to use assistive devices available in their various locations for customers and inform customers of the assistive devices that are available.

Notice of Temporary Disruptions

Toronto Seniors Housing Corporation is aware that the operation of its services and facilities is important to its customers. However, temporary disruptions in services and facilities may occur.

Toronto Seniors Housing Corporation will provide its customers with notice of any disruption to its services, including information about the reason for the disruption, its anticipated duration, and a description of alternative facilities or services, if any, that may be available.

Notice of service disruptions will be provided as soon as staff is aware of the disruption, or in advance in the case of planned disruptions. Notice will be provided by a variety of methods, depending on the circumstances, and may include postings in conspicuous places at the affected premises, in other Toronto Seniors Housing Corporation facilities, on Toronto Seniors Housing Corporation’s website or by any other means that will ensure that the notice reaches those persons potentially affected by the temporary disruption in a manner that is accessible to them.

Feedback Policy

The goal of Toronto Seniors Housing Corporation is to meet and surpass expectations while providing services to customers with disabilities. Feedback on our services and whether expectations are being met are welcome and appreciated. Feedback may be provided by a person with a disability in the manner deemed most convenient to them, such as in person, by telephone, in writing, by email or otherwise. All feedback will be kept in strict confidence and used to improve customer service. In addition, the author of the feedback will be provided a response in the format requested (or the most appropriate format where no request was made) outlining actions taken. Where an individual is not satisfied with Toronto Seniors Housing Corporation’s response to their feedback, staff will direct their complaint to the appropriate individual to respond.

Related Legislation, Regulations, and TSHC Policies:

• Accessibility for Ontarians with Disabilities Act, 2005 (AODA)
• Accessibility Standards for Customer Service, Ontario Regulation 429/07
• Ontario Human Rights Code
• TSHC Human Rights and Harassment Policy – Tenants
• TSHC Accessibility Policy
• TSHC Multi-year Accessibility Plan
• TSHC Tenant Complaint Procedure
• TSHC Accessibility Customer Service Policy Guidelines (to be reviewed)

Amendments (Revision History):

NA

Next Scheduled Review Date: 2025

This policy will be reviewed once every 5 years.

Policy Contact

Director, Strategy and Business Management

Accessibility Policy

Policy Sponsor: Director, Strategy and Business Management
Approver: Board of Directors
Initial Approval Date: May 17, 2022
Effective Date: June 1, 2022

Organizational Statement of Commitment

Toronto Seniors Housing Corporation (TSHC) is committed to providing an inclusive environment to tenants and employees with disabilities in accordance with the core principles of accommodation, dignity, independence, integration and equal opportunity outlined in the Human Rights Code, R.S.O. 1990, c.H.19 and the Accessibility for Ontarians with Disabilities Act, 2005, S.O. 2005, c.11, and the complimentary legislation of the Employment Standards Act, 2000, S.O. 2000, c.41, the Ontario Building Code, O. Reg. 332/12, and the Integrated Accessibility Standards, O. Reg.191/11.

Policy Statement

Toronto Seniors Housing Corporation recognizes the need to identify and remove barriers faced by people with disabilities and will achieve greater accessibility by aligning with a culture that recognizes the dignity and worth of every individual.​

This policy provides an overview of all of Toronto Seniors Housing Corporation’s policies, plans and programs as they relate to accessibility. While components of this policy are intended to address the corporation’s compliance with legislation, Toronto Seniors Housing Corporation’s commitment to accessibility extends beyond legislative compliance. As Toronto Seniors Housing Corporation continues to achieve accessible social housing and employment, this policy requires Toronto Seniors Housing Corporation staff to incorporate best practices in accessibility through all aspects of its business. Toronto Seniors Housing Corporation will engage and consult with stakeholders, tenants, and employees with disabilities in the development of its accessibility policies, plans, and programs.

Definitions

​​Accessible formats: ​Formats that are an alternative to standard formats and are accessible to people with disabilities. Accessible formats may include, but are not limited to, large print, recorded audio and electronic formats, braille and other formats usable by persons with disabilities.

​Communication supports: Supports that individuals with disabilities may need to access information. These include, but are not limited to, captioning, alternative and augmentative communication supports, plain language, sign language and other supports that facilitate effective communications.

Disability: From the Ontario Human Rights Code, R.S.O. 1990, c. H. 19:

• any degree of physical disability, infirmity, malformation or disfigurement that is caused by bodily injury, birth defect or illness;
• a condition of mental impairment or developmental disability;
• a learning disability, or a dysfunction in one or more of the processes involved in understanding or using symbols or spoke language;
• a mental disorder; or
• an injury or disability for which benefits were claimed or received under the Workplace Safety and Insurance Act, 1997, S.O. 1997, c. 16 sche. A, or Ontario Disability Support Program.

​In addition, the definition of disability under the Ontario Human Rights Code, R.S.O. 1990, c. H. 19, may include but is not limited to:

• Acquired Brain Injury
• Deaf, deafened, hard-of-hearing
• Low vision or blind
• Chronic health conditions (cancer, epilepsy, heart disease, etc.)

Accessibility Lead: The member of the leadership team who has been designated as the lead for this policy and all related accessibility initiatives.

Toronto Seniors Housing Corporation staff: All Toronto Seniors Housing Corporation employees, whether full or part-time, temporary or permanent, including secondees. ​

Volunteers: Any individual who works for or on behalf of Toronto Seniors Housing Corporation on an unpaid basis, or for nominal consideration, including, but not limited to, volunteers, tenant volunteers, interns, and students.

Scope

This policy applies to all Toronto Seniors Housing Corporation staff, volunteers, and third party contractors who interact with tenants or staff on behalf of Toronto Seniors Housing Corporation.

​Core Principles

In keeping with our values of respect, inclusion, accountability and innovation, Toronto Seniors Housing Corporation will implement this policy in accordance with the following principles:

Dignity

Tenants and staff are treated in a respectful manner.

Independence

Services, opportunities, programs, and facilities for persons with disabilities will support their independence while respecting their right to safety and personal privacy. Service delivery will consider the nature of the service and alternative accommodation that may be required.

Equity/Equality of Outcome

Tenants and staff with disabilities will be provided the same access to our programs, services, opportunities, and facilities as all other tenants and staff.

Integration

Tenants and staff with disabilities will fully benefit from the same programs, services, opportunities, and facilities, in the same places and in the same or similar way as all other tenants and staff. An emphasis on inclusion will focus on eliminating barriers for people with disabilities.

Governance and Legislation

Toronto Seniors Housing Corporation will meet or exceed the following legislative requirements:​

Accessibility for Ontarians with Disabilities Act, 2005 (AODA)

The AODA came into effect in 2005. It permits the Ontario government to establish Accessibility Standards to remove or prevent barriers for Ontarians with disabilities by 2025. For details on Toronto Seniors Housing Corporation’s compliance with the AODA and associated legislation refer to the relevant policies as listed in the Policy Details.

Employment Standards Act, 2000 (ESA)

The ESA sets out the minimum standards for working in Ontario and defines the rights and responsibilities of employees and employers. Toronto Seniors Housing Corporation is committed to complying with the standards outlined in the ESA as they relate to accessibility and accommodation on the basis of disability.

Ontario Human Rights Code (OHRC)

The OHRC was enacted in 1990 and ensures the rights of all people to be treated equally and without discrimination based on race, colour, gender identity, sex, sexual orientation, disability, creed and age. Toronto Seniors Housing Corporation is committed to upholding the OHRC in its entirety.

Integrated Accessibility Standards (IASR)

The IASR was enacted under the AODA in 2011, with phased implementation requirements commencing January 1, 2012 through to January 1, 2021.
​The IASR addresses three specific areas of relevance to Toronto Seniors Housing Corporation: accessible employment practices; accessible information and communication supports; and design of the built environment. Provisions that guide staff in complying with the IASR can be found in a number of policies, programs and standards and are noted in the Policy Details below.

Toronto Seniors Housing Corporation tracks the implementation of the IASR in its multi-year Accessibility Plan. The plan is posted on Toronto Seniors Housing Corporation’s website and is made available in accessible formats upon request. The plan is updated on an ongoing basis and is fully reviewed every five years.

Ontario Building Code (OBC)

The OBC is a set of mandated building design and construction standards aimed at minimizing the risk to the health and safety of the occupants of a building and to provide for the barrier-free access to buildings. Toronto Seniors Housing Corporation follows the standards set out in the OBC in order to make sure that the design and construction of all new buildings, and changes and additions to existing buildings serve to increase accessibility for tenants and meet legislative requirements by 2025.

​Accessibility Focus Areas

Accessible Customer Service

Toronto Seniors Housing Corporation will develop best practices to provide accessible customer service in a respectful and transparent manner. The relevant policies and programs are summarized below and the details can be found in the documents themselves.

• Accessible Customer Service Policy: outlines our commitment to provide customer service that is inclusive, barrier free and meets the unique needs of persons with disabilities.
• Communication Standards/Accessible Formats and Communications Supports: outlines the standards that Toronto Seniors Housing Corporation follows in all communications to tenants. These standards include the Information and Communications Standards as outlined in the IASR.
• Human Rights, Harassment & Fair Access Policy: Includes proactive measures to eliminate harassment and discrimination in accommodation, employment, delivery of services, and in all other contract arrangements. It reflects the requirements of the OHRC and policies established by the City of Toronto.
• Self-Service Kiosk Standards: Toronto Seniors Housing Corporation will ensure accessibility for persons with disabilities when designing, procuring and acquiring self-service kiosks, as indicated in the IASR.
• Tenant Transfer Policy: formalizes Toronto Seniors Housing Corporation’s commitment to priority transfers of persons who have a medically documented need for accessible accommodation.
• Tenant Complaints Process: ensures that complaints are heard, the facts of the complaints are established, and where required, remedial actions are taken. The primary objective of this process is to outline a simple process which is accessible to all.

Accessible Homes

Toronto Seniors Housing Corporation will ensure that tenants with disabilities can live in units, buildings and communities that accommodate their needs. The relevant policies and programs are summarized here and the details can be found in the documents themselves.

• Accessibility in the Built Environment Policy: TSHC strives to treat all individuals in a manner that allows them to maintain their dignity and independence and is committed to providing an inclusive environment to tenants with disabilities as outlined in the Human Rights Code, the Accessibility for Ontarians with Disabilities Act, and the complimentary legislation of the Ontario Building Code, and the Integrated Accessibility Standards. As the buildings TSHC manages are owned by Toronto Community Housing Corporation (TCHC), TSHC uses the TCHC’s Build Standards to provide guidance as they apply to minor accessibility modifications that TSHC may make to tenants’ units. TSHC’s Accessibility Plan sets out TSHC’s policy on how we will achieve accessibility generally, as well as in the built environment.
• Accessibility Program: Capital Planning: TSHC participates in TCHC’s capital planning and implementation process for planned capital improvements.
• Accessibility Program: Tenant Request Unit Modifications: includes standards and a process for accessibility-related unit modifications based on tenant request and documented medical need.

Accessible Workplaces

Toronto Seniors Housing Corporation will ensure that employees with disabilities are accommodated in a respectful and transparent manner. The relevant policies and programs are summarized here and the details can be found in the documents themselves.

• Hiring Policy: Outlines Toronto Seniors Housing Corporation’s commitment to meeting its statutory obligations in the hiring process, and ensures that employment accommodation is provided to all candidates in accordance with the OHRC and the ESA.
• Human Rights, Harassment & Fair Access Policy: Includes proactive measures to eliminate harassment and discrimination in accommodation, employment, delivery of services, and in all other contract arrangements. It reflects the requirements of the OHRC and policies established by the City of Toronto.
• Individualized Workplace Emergency Response Information: Individualized workplace emergency response information will be prepared for employees with disabilities where the disability is such that the individualized information is necessary and Toronto Seniors Housing Corporation is aware of the need for accommodation due to the employee’s disability. This will be prepared as soon as practicable after Toronto Seniors Housing Corporation becomes aware of the need for accommodation due to the employee’s disability. A detailed process can be found as part of Toronto Seniors Housing Corporation’s Workplace Accommodation Policy.
• Workplace Accommodation Policy: Facilitates effective responses to accommodation issues that arise in the workplace and ensures Toronto Seniors Housing Corporation meets its duty to accommodate under the OHRC.

Supports for Policy Implementation

• Staff Training: Toronto Seniors Housing Corporation will ensure that accessibility training is provided to all employees and persons who participate in developing our policies.

The training will consist of requirements under the IASR; the parts of the OHRC that pertain to people with disabilities.

​The training will be appropriate to the duties of the person being trained and will be provided as soon as practicable. A record will be kept of the dates of the training and the number of individuals trained.

Toronto Seniors Housing Corporation will also provide training on an ongoing basis when changes are made to the policies and programs listed above, and to new employees as part of the on-boarding process.

• Tenant & Staff Engagement: Toronto Seniors Housing Corporation will consult and work with tenants with disabilities and stakeholders in the development of the above accessibility policies, plans, and programs. Toronto Seniors Housing Corporation will consult with appropriate stakeholders, which may include tenants with disabilities, tenant accessibility advocacy groups, experts in the field of accessibility, and Toronto Seniors Housing Corporation staff when undertaking formal reviews of this policy and any other Toronto Seniors Housing Corporation policies related to accessibility.
• Procuring Goods and Services: Toronto Seniors Housing Corporation’s Procurement Department shall incorporate accessibility criteria and features into its procurement process, procurement documents shall specify the desired accessibility standards to be met and the related submission requirements, except where it is not practical to do so. Where it is impractical to incorporate accessibility criteria and features into the procurement process, the Procurement Department will provide an explanation upon request. The Procurement Department will also ensure that all selected vendors, where applicable, comply with the AODA and its regulations when providing accessible goods and services to Toronto Seniors Housing Corporation.​

Compliance and Monitoring

Accessibility Reviews

All new or revised policies and procedures will be reviewed to ensure legislative compliance. When developing, revising and implementing Toronto Seniors Housing Corporation’s policies and strategies, authorized Toronto Seniors Housing Corporation staff will conduct an accessibility review. This review will consider and address accessibility, with a particular focus on reducing barriers faced by people with disabilities and ensuring the principles guiding this policy are upheld.

Reporting

The accessibility lead will report regularly to the leadership team. Accessibility is an integral component of Toronto Seniors Housing Corporation’s business, and metrics on accessibility improvements will be reported  regularly to the Toronto Seniors Housing Corporation Board of Directors and annually through the annual report.

Related Legislation, Regulations, and TSHC Policies:

• Accessibility for Ontarians with Disabilities Act, 2005, S.O. 2005, c. 11
• Employment Standards Act, 2000, S.O. 2000, c. 41
• Human Rights Code, R.S.O. 1990, c. H. 19
• Integrated Accessibility Standards, O. Reg. 191/11
• ​Ontario Building Code, O. Reg. 332/12
• TSHC Accessible Customer Service Policy
• TSHC Hiring Policy
• TSHC Human Rights Policy – staff
• TSHC Human Rights, Harassment & Fair Access Policy – tenants
• TSHC Workplace Accommodation Policy

Amendments (Revision History):

NA

​Next Scheduled Review Date:

This policy will be reviewed once every five years.

Policy Contact

Director, Strategy and Business Management

Closed Circuit Television (CCTV)

Why Toronto Community Housing/Toronto Seniors Housing has this Policy:

Toronto Community Housing/Toronto Seniors Housing has decided that there may be the need for Closed Circuit Television (CCTV) systems in some of its buildings. CCTV may help provide Toronto Community Housing/Toronto Seniors Housing’s tenants, employees, visitors and properties with an increased perception of safety and security, along with other measures that the organization and the community may put in place. The use of CCTV in Toronto Community Housing/Toronto Seniors Housing communities may help to discourage people from committing crimes, and may help to identify people who commit crimes on Toronto Community Housing/Toronto Seniors Housing properties. Toronto Community Housing/Toronto Seniors Housing’s focus is to create safe, healthy communities and the use of CCTV equipment is one measure that may be used to assist with that goal.

Toronto Community Housing/Toronto Seniors Housing will keep control of and be responsible for the CCTV surveillance systems in its buildings. Toronto Community Housing/Toronto Seniors Housing recognizes that the use of CCTV systems must balance safety needs and a tenant’s reasonable expectation of privacy.

What does this Policy apply to?

This Policy applies to all surveillance systems, surveillance monitors and camera recording devices used for security purposes that have been or will be installed by Toronto Community Housing/Toronto Seniors Housing on its properties.

This Policy does not apply to the following CCTV surveillance systems: required by law or a court order or installed by third parties such as the police and commercial tenants.

What laws will Toronto Community Housing/Toronto Seniors Housing follow in using the CCTV system?

Toronto Community Housing/Toronto Seniors Housing will follow the applicable privacy sections of the Ontario Municipal Freedom of Information and Protection of Privacy Act (MFIPPA) and will use the Information and Privacy Commissioner’s guidelines in its practices related to the collection, use, sharing, storage and disposal of any information received from CCTV systems.

How will Toronto Community Housing/Toronto Seniors Housing decide if a building needs CCTV?

Toronto Community Housing/Toronto Seniors Housing will balance an individual’s right to privacy and the need to ensure the safety and security of its communities. Toronto Community Housing/Toronto Seniors Housing will work with the community to determine whether a CCTV system is a tool that fits with the community’s safe and secure plan. The following factors may be considered as to whether to install a CCTV system in a particular community:

• What other ways of preventing crime have not worked, or what other ways of preventing crime are not possible;
• What reports or incidents of crime or significant safety concerns have been received by Toronto Community Housing/Toronto Seniors Housing;
• Consideration of how CCTV will affect people’s privacy, and any privacy issues raised by use of CCTV on its properties; and
• Consultations with people who are affected about whether Toronto Community Housing/Toronto Seniors Housing needs CCTV, including tenants, employees, and the Toronto Police Services.

Where will Toronto Community Housing/Toronto Seniors Housing place the CCTV System and Equipment?

CCTV Cameras

Toronto Community Housing/Toronto Seniors Housing may place CCTV cameras in public areas of Toronto Community Housing/Toronto Seniors Housing property. Toronto Community Housing/Toronto Seniors Housing will not place CCTV cameras anywhere that tenants, employees, and the public should reasonably expect privacy. For example, Toronto Community Housing/Toronto Seniors Housing will not place cameras directly in front of a tenant’s door, or in washrooms and change rooms.

CCTV Recording Equipment

Toronto Community Housing/Toronto Seniors Housing will make sure that access to the CCTV recording equipment is kept away from the public. The equipment will be in places that only a few people can get into, such as a locked room. Toronto Community Housing/Toronto Seniors Housing will also make sure that the only people who can access the CCTV cameras and other equipment are Community Housing Managers, contract Property Managers, Toronto Community Housing/Toronto Seniors Housing Community Safety Consultants, Toronto Community Housing/Toronto Seniors Housing Community Safety Officers, and any other Toronto Community Housing/Toronto Seniors Housing employee, contractor or representative with permission to do so.

Retention Period of a CCTV Record

The information recorded by the CCTV will be kept for a period of 3 days or such lesser period as permitted by the system. Toronto Community Housing/Toronto Seniors Housing may keep a record longer than the retention period only if it is identified prior to disposal as being needed as part of a criminal, safety or security investigation or for evidentiary purposes.

Storage, Record Identification and Logbook

All of the CCTV records that Toronto Community Housing/Toronto Seniors Housing stores will be kept in a locked room with the CCTV equipment. Stored CCTV records will be clearly labelled with the date as its identification. For Digital Video Recorders (DVRs) that store information directly on a hard drive, Toronto Community Housing/Toronto Seniors Housing will use the computer time and date stamp as the identification. For Video Cassette Recorders (VCRs) that store information on videotapes, a label will be affixed to the videotape with the date as its identification.

A logbook will be kept in the locked room where the CCTV system and recording equipment is stored. Those individuals approved to access the system, as identified under section 5 (B) above, must sign the logbook to show when they access the record, how they used it, and when and how it was destroyed. The logbook must include the name of the person who had permission to access the record.

Disposal

Toronto Community Housing/Toronto Seniors Housing will do everything reasonably possible to keep CCTV records safe, and to destroy records when they are no longer needed. Old recording storage devices will be destroyed according to the applicable disposal process to ensure that recorded personal information is erased prior to disposal, and cannot be retrieved or reconstructed. Depending on the type of recording and storage device, Toronto Community Housing/Toronto Seniors Housing will shred, burn or erase the record.

Restricted Access to CCTV system

Toronto Community Housing/Toronto Seniors Housing will make sure that only the individuals identified under section 5(B) above will have access to the CCTV records, and only those individuals will be allowed to authorize the removal of CCTV records out of storage.

Allowing the police to use the CCTV records

If the police need a CCTV record to help them investigate a crime, Toronto Community Housing/Toronto Seniors Housing will let them look at the record and take it with them. Toronto Community Housing/Toronto Seniors Housing will follow the rules set out in MFIPPA. Where appropriate, Toronto Community Housing/Toronto Seniors Housing may request the police to only use the CCTV record as evidence in a court proceeding. Before taking a record, police officers will be required to fill out a release form as provided in Appendix A.

Toronto Community Housing/Toronto Seniors Housing will ask the police to return or destroy the record when the police and courts are finished with it. Toronto Community Housing/Toronto Seniors Housing will keep these records for one year after their return or as required under MFIPPA, and then destroy it in line with the proper disposal method.

Who can ask to see what is recorded by CCTV?

Any person who has been recorded by a CCTV system has a right to see what the record shows if it is still stored by Toronto Community Housing/Toronto Seniors Housing. This right is guaranteed by the Ontario Municipal Freedom of Information and Protection of Privacy Act (MFIPPA).

Any person who wants to see a CCTV record must write to Toronto Community Housing/Toronto Seniors Housing’s Privacy Coordinator as soon as possible after the record was made. The person requesting the record must identify where and when the recording was captured. If a person asks to see a CCTV record, that person can only see images of himself/herself. As with all requests for records, Toronto Community Housing/Toronto Seniors Housing will make sure that any other person identified in the record are blocked out. As with all such requests a fee may be applicable. Requests for access to a record may be denied in certain circumstances as set out in MFIPPA and any other applicable law.

Telling the public about the CCTV system

To tell the public that Toronto Community Housing/Toronto Seniors Housing is using CCTV, Toronto Community Housing/Toronto Seniors Housing will post signs on any property that has CCTV.

The following information may be on the signs:

• That CCTV may be in use on the property;
• Which law allows Toronto Community Housing/Toronto Seniors Housing to make records of people;
• The purpose behind the use of CCTV; and
• The title, business address and telephone number of a person who can answer questions about CCTV.

What Toronto Community Housing/Toronto Seniors Housing employees need to know

Toronto Community Housing/Toronto Seniors Housing will communicate this policy to its employees and those representatives that manage Toronto Community Housing/Toronto Seniors Housing residential properties. Toronto Community Housing/Toronto Seniors Housing will also make sure that all employees who do anything related to the CCTV systems follow this policy and any related MFIPPA requirements.

What contracted service providers need to know

Any time Toronto Community Housing/Toronto Seniors Housing contracts with a service provider that may have a connection that relates to Toronto Community Housing/Toronto Seniors Housing’s CCTV system, Toronto Community Housing/Toronto Seniors Housing will tell the service provider that all records in its CCTV systems belong to Toronto Community Housing/Toronto Seniors Housing and must be handled according to this Policy. Where a service provider does not follow this Policy, Toronto Community Housing/Toronto Seniors Housing may consider that the service provider has breached its contract and may result in the termination of its contract with Toronto Community Housing/Toronto Seniors Housing.

What happens if CCTV information is accidentally made public?

If any information from a CCTV record is accidentally made public in breach of this Policy, Toronto Community Housing/Toronto Seniors Housing will deal with the problem quickly and effectively. Toronto Community Housing/Toronto Seniors Housing will:

• immediately report what happened to its Privacy Coordinator,
• try to get the record back,
• tell the person whose privacy has been violated,
• tell the Ontario Information and Privacy Commissioner, and
• investigate what happened.

Reviewing the CCTV system

Toronto Community Housing/Toronto Seniors Housing will review its CCTV equipment on a periodic basis to ensure that it complies with this Policy.

Reviewing this Policy

Toronto Community Housing/Toronto Seniors Housing will periodically review and update this Policy.

Toronto Seniors Housing Corporation has adopted this policy as of May 17, 2022 and is in effect for June 1,2022

Information Breach Policy

Policy Owner: CGHRC	Date Approved: 18 May, 2022
Type: Legal Policy	Approved By: Board of Directors
Last Reviewed:	Effective Date: 1 June, 2022

Policy Statement

Toronto Seniors Housing Corporation (Toronto Seniors Housing) collects and retains Confidential Information that must be properly managed to protect the privacy and security of the party whose information has been collected, including, but not limited to, tenants, employees and the corporation itself. If Confidential or Internal Information is lost, corrupted, accessed or disclosed without proper authorization, it can pose a high level of legal, reputational, financial and safety risks to Toronto Seniors Housing.

This Policy provides a framework within which employees of Toronto Seniors Housing are required to respond to an Information Breach, and sets out responsibilities within Toronto Seniors Housing and its employees for the reporting and handling of an attempted, actual or suspected Information Breach, in order to minimize its impact.

Scope

This Policy applies to any improper or unauthorized use, release, disclosure or disposal of Confidential or Internal Information in Toronto Seniors Housing’s custody and control, such as tenant, employee, third party or corporate information.

It covers both Information Breaches and Information Technology System Breaches.

Information Breaches can arise from cybersecurity attacks, as well as from the theft, loss, abuse, damage or unauthorized access to or disclosure of Toronto Seniors Housing information, whether the breach was intentional or inadvertent.

This Policy is applicable to all employees of Toronto Seniors Housing that have access to information in the custody or under the control of Toronto Seniors Housing and its Information Technology Systems. Toronto Seniors Housing will enter into agreements to ensure that contract management companies, vendors and third parties meet the relevant requirements of this Policy.

Values

Toronto Seniors Housing supports a climate and culture that protects both Confidential and Internal Information. Toronto Seniors Housing will implement this Policy in accordance with the following values:

Respect: All Toronto Seniors Housing employees will adhere to this Policy and will take appropriate measures to protect both Confidential and Internal Information to which they have access from an Information Breach in accordance with this Policy.

Accountability: Toronto Seniors Housing will designate Incident Response Leads within the Legal Services and Information Technology Services Divisions who will lead its response to an Information Breach.

Integrity: Toronto Seniors Housing employees will alert the organization of an Information Breach.

Definitions

Confidential Information: Information that is in the custody or control of Toronto Seniors Housing that is highly sensitive, protected from public disclosure and intended for use by a specified group of authorized users, such as Personal Information, and information related, generally, to Toronto Seniors Housing’s tenants, residents, contractors, employees, and members of the public that, if disclosed, may give rise to a significant risk of harm to both Toronto Seniors Housing and others.

Incident Response Lead: The employee within Toronto Seniors Housing’s Information Technology Services or Legal Services Division who is (depending on the nature of the breach) responsible for leading its response to an Information Breach.

Information Breach: The improper or unauthorized use, disclosure, release or disposal of either Confidential or Internal Information, resulting in the information being access by or disclosed to unauthorized parties. Examples of an Information Breach include, but are not limited to:

• an employee sending an email containing either Confidential or Internal Information to an unintended recipient in error;
• an individual (such as a tenant, vendor or other stakeholder) being mistakenly provided with or accessing either Confidential or Internal Information that they are not authorized to view;
• the removal of a tenant file from a Toronto Seniors Housing office resulting in the unauthorized disclosure of either the tenant’s Personal Information; or
• an Information Technology System Breach.

Information Technology System Breach: An Information Breach that occurs as a result of:

• unauthorized activity by parties internal and external to Toronto Seniors Housing;
• a technical vulnerability; or
• a combination of those or other causes; impacting Toronto Seniors Housing’s Information Technology Systems that results in the use, disclosure, release or disposal of either Confidential or Internal Information, resulting in the information being access by or disclosed to unauthorized parties of information systems or networks.

Internal Information: Information other than Confidential Information that is generally only available and intended for use by Toronto Seniors Housing employees and authorized third parties such as consultants and vendors. (e.g. Corporate policies, standards, and procedures unless they are intended for publication, general corporate internal announcements to staff, etc.), including but not limited to information related to Toronto Seniors Housing’s financial affairs, marketing plans, resources, proposed initiatives, and strategies, etc.

Personal Information: Has the same meaning as defined in Municipal Freedom of Information and Protection of Privacy Act, RSO 1990, c M.56, as amended, and includes recorded information about an identifiable individual which is collected, used, or disclosed by Toronto Seniors Housing. For the application of this Policy, Personal Information may include but is not limited to:

1. the personal address, telephone number or email address of an individual;
2. any identifying number, symbol or other particular assigned to an individual which can lead to their identification (e.g., Social Insurance Number or Tenant ID);
3. information relating to the race, national or ethnic origin, colour, religion, age, sex, sexual orientation or marital or family status of the individual;
4. financial information about an individual for the purposes of establishing Rent-Geared-to-Income assistance;
5. information about rent payment history; credit and rental history reports; and
6. employee information, including resumes, salary and benefits, tenant or client complaints about the individual and personnel issues.

With regards to applicants and tenants, Personal Information may include income, credit history, subsidy, arrears, utility consumption, personal circumstances, health information, information regarding conflicts between tenants, requests for transfers for personal reasons and any requests from tenants that are personal in nature. With regards to employees, Personal Information may include hiring, termination, disciplinary record, salary negotiations, tenant complaints and information regarding conflicts between employees or between employees and tenants.

Public Information: Information that is generally available to the public, with no special protection from disclosure required (e.g. a press release, a public request for proposals, external TSHC website content, and published reports).

Policy Details

Toronto Seniors Housing Responsibilities

Toronto Seniors Housing will:

• Promote a culture and implement business practices that support information security, cybersecurity and the prevention of Information Breaches.
• Provide education on information security to Incident Response Leads and employees who have access to or are responsible for either Confidential or Internal Information.
• Maintain appropriate administrative, physical and technical security safeguards to prevent the unauthorized access, use or disclosure of either Confidential or Internal Information.
• Maintain procedures and protocols to identify, contain, and recover from any Information Breaches that ensures there is a consistent and effective approach to the management of Information Breaches.

The General Counsel and Corporate Secretary will oversee Toronto Seniors Housing’s response to an Information Breach and will work with the Vice President, Information Technology Services and the Incident Response Leads to mitigate its impact.

Employee Responsibilities

In performing their duties and fulfilling their responsibilities, employees will learn information about Toronto Seniors Housing and its operations. This includes information in that is shared with the employee verbally and in writing, through formal documents, corporate files, e-mails, computers files, data records, etc. In most cases, this information is not generally known to the public. Examples include information related to our financial affairs, marketing plans, tenants, residents, resources, contractors, proposed initiatives, strategy, members of the public, employees, etc. This information is confidential and is Toronto Seniors Housing’s property.

Employees are required to take all reasonable steps to protect both Confidential and Internal Information from unauthorized use or disclosure. This includes safeguarding physical and electronic documents, laptops, and cell phones that have been entrusted to their care, as well as taking necessary steps to protect information when using computer systems and sending e-mail pursuant to the requirements of related policies, procedures or directives that have been issued by TSHC.

If an employee becomes aware of an Information Breach, he or she must immediately notify their manager, Division Head and the General Counsel and Corporate Secretary in accordance with the procedure set out in the Information Breach Procedure.

If an employee suspects that an Information Technology System Breach may have occurred, he or she must immediately notify their manager, Division Head and the Information Technology Service Desk. The Service Desk team will report the breach to the Incident Response Leads in accordance with the procedure set out in the Information Technology Security Incident Management Procedure.

Information Breach Standards

In the event of an actual or suspected Information Breach, Toronto Seniors Housing will, to the extent necessary in order to mitigate the impact of the Information Breach, undertake the following actions:

• Determine if an actual breach occurred and identify the type of information that was disclosed (i.e., Confidential Information, Internal Information or Public Information).
• Contain the incident to minimize impact (e.g. retrieving the information if possible, disconnecting devices affected or implicated by the Information Breach from the network, suspending access rights, quarantining any discovered malware).
• Investigate the cause of the Information Breach and depending on its nature, conduct any additional forensic analysis required to support any criminal or legal investigation as may be required.
• Conduct an assessment with relevant employees to determine the impact of the Information Breach and review the recovery actions required.
• Notify the affected stakeholders (e.g. employees, tenants, vendors) and if Personal Information may have been disclosed, notify the Information and Privacy Commissioner as necessary.
• Notify Toronto Seniors Housing employees and Directors, as appropriate.
• Conduct a post-incident analysis of the cause of the Information Breach, and identify lessons learned, preventative actions, and how to further improve Toronto Seniors Housing’s overall information security protocols.

Compliance and Monitoring

Compliance with this Policy will be assessed through various methods, including internal and external audits. Legal Services and Information Technology Services will monitor the volume and severity of Information Breaches and prepare an annual report of incidents to the Executive Leadership Team highlighting any actions that need to be taken to mitigate risk. At the direction of the President and CEO, the content of this annual report will be shared with the Toronto Seniors Housing Board of Directors through the Building Investment, Finance and Audit Committee.

Employees who do not follow this Policy or the related sections of the Privacy Policy and the Code of Conduct which require the protection of personal or confidential information may be subject to discipline, up to and including dismissal. Non-compliance with any provision of this Policy by employees or Toronto Seniors Housing affiliates may result in remedial action up to and including termination of any affiliate contract, and may result in possible civil, criminal, or regulatory action.

Toronto Seniors Housing will take appropriate steps to ensure vendors, contractors and third-parties comply with this Policy.

Governing and Applicable Legislation

• Municipal Freedom of Information and Protection of Privacy Act
• Personal Information Protection and Electronic Documents Act, 2000 

Related Policies and Procedures

Procedures Established pursuant to this Policy

• Information Breach Procedure
• Information Technology Security Incident Management Procedure

Related Policies and Procedures

• Employee Code of Conduct
• Acceptable Use of Information and Technology
• Records Management Policy Enterprise Risk Management Policy
• Conflict of Interest Policy
• Privacy Policy

Commencement and Review

Revision	Date	Description of changes	Approval
First Approval		New Policy

Next Scheduled Review Date:

Parking Policy Statements For Tenants / Non-Tenants / Agencies and Contractors

1. Toronto Seniors Housing Corporation will only register and permit roadworthy vehicles that are properly licensed – has current license plates and validated by Ministry of Transportation, not including tractor trailers, boats, buses, cube vans, or where the Vehicle Weight or Reg. Gross Weight exceeds 3000 kg.
2. Currently Toronto Seniors Housing Corporation does not have the facilities to accommodate the charging of hybrid vehicles. Until such a time as technological advances make this possible, Toronto Seniors Housing Corporation will be unable to provide power sources for these vehicles.
3. All Tenants, Non-Tenants, and Commercial Tenants will be “assigned” a parking space(s) in underground garages, where applicable.
4. Tenants are permitted to register personal vehicle(s) which they drive for personal use.
5. Non-Tenant Parker can request to register multiple vehicles, up to a maximum of 2 vehicles, to share the use of one parking space. This option is only available in underground parking facilities and through TCH’s Commercial Business Unit.
6. All Toronto Seniors Housing Corporation affiliated organizations’ vehicles, that are marked and identified with a logo are permitted to park on Toronto Seniors Housing Corporation property(ies) 24 hours a day, 7 days a week.
7. “Vehicle On Duty” Signs are available for rent for placement on Agencies’ & Contractors’ vehicles dashboards that attend multiple Toronto Seniors Housing Corporation sites and have regular frequent business  activities  on  Toronto  Seniors  Housing Corporation property.
8. Other Agencies, Contractors, or individuals that do not have regular business activities or agreement with Toronto Seniors Housing Corporation are to be treated as visitors, and are to follow the Visitor Parking Procedure.
9. All persons who park in a visitor parking space at a Pay & Display parking location need to purchase Pay & Display ticket and adhere to the display instructions, including already registered contractors’, agencies’ and employees’ vehicles.
10. Visitor Parking Permits must be used by all persons who park in a visitor parking space at a non-Pay & Display location, and must be completed and displayed as per the conditions listed on the back of the permit. Permits can be obtained from the Regional office or Superintendent (as applicable), free of charge for up to a maximum of 9 permits per unit per month, or as set by Toronto Seniors Housing Corporation.
11. Commercial Tenants that request to have “designated” parking are required to pay the Non- Tenant Parking monthly rate plus cover the expense of required signage and installation fee as set by Toronto Seniors Housing The number of fobs or access cards to be given will be equal to the number of parking spaces paid for. Toronto Seniors Housing Corporation does not enforce any “designated” parking spaces.
12. Lost or stolen or non-returned Permits are subject to a replacement fee, set by Toronto Seniors Housing Corporation, based on Parking Permit type.
13. Toronto Community Housing Corporation on behalf of Toronto Seniors Housing Corporation has the authority to tag and tow vehicles parked on Toronto Seniors Housing Corporation property which are not authorized to do so at the owner’s expense.
14. Tenants or Non-Tenants who are in arrears in excess of one month rent will not be registered for any new Tenant or Non-Tenant parking permit until their outstanding account is addressed through payment or repayment agreement.

Board and Board Committee Meeting Procedures

Policy Sponsor: Director, Strategy and Business Management
Approver: Board of Directors
Initial Approval Date: March 31, 2022
Date of Last Revision: September, 2024
Effective Date: October 17 2024

Rules of Order

All points of order or procedure for which rules have not been provided in this policy will be decided by the Chair of the Board of Directors as far as is reasonably possible first, in accordance with the rules of parliamentary procedure as contained in the current edition of Robert’s Rules of Order.

Schedule of Regular Board and Board Committee Meetings

At the beginning of each calendar year, the Board of Directors (the Board) will set a schedule of regular meetings for the year for the Board and for Committees of the Board.

Board of Directors or Board Committee Members are encouraged to attend meetings in person or electronically. Meetings of the Board of Directors or of a Committee of the Board can be held in person, electronically or in a hybrid mode. A Hybrid Meeting may be scheduled where the meeting takes place in a physical setting, but some Directors/Members attend using technology instead of being physically present.

Any Director/Member participating in such a meeting by such means is deemed to be present at the meeting.

Directors and members will be notified ahead of time of any changes to the schedule, time, and/or location of the meeting.

Cancellation and Rescheduling of Meetings

Meetings may be rescheduled or cancelled in the event there is not quorum or for any reason necessitating the meeting change. The Board Secretary shall, in consultation with the Chief Executive Officer (CEO) and the Board/Board Committee Chair, take appropriate steps to advise all Directors/Members of the cancellation and/or rescheduling of meetings. Notice of change is also to be posted on the Toronto Seniors Housing Corporation website and in regional offices.

If a regularly scheduled meeting of the Board/Board Committee is cancelled without rescheduling, the next regularly scheduled meeting cannot be cancelled.

Special Meetings

The Board Chair or any two Directors may convene a special meeting of the Board at any time by giving formal notice to all Directors not less than 24 hours before the meeting. Notice must be delivered or sent electronically or in another form of written transmission to each Director. Notice, along with any agenda material, must indicate the time, place, and matter to be dealt with.

Special Board Committee meetings will be referenced in the Committee’s Terms of Reference. TSHC will strive to provide the notice and distribute materials well in advance of the meeting whenever possible.

Board Workshops

Throughout the year, orientation sessions, workshops or training sessions for the Board may be called. No formal business of the Board will be carried out at these sessions. These sessions will not be open to the public.

Attendance

Each Director/Member shall make reasonable efforts to advise the Board Secretary as far in advance as possible of any Board/Board Committee meeting which such Director/Member expects not to attend. Directors/Members will notify the Board Secretary if they:

• will not be attending
• will be arriving late for, or
• will be leaving early from any Board/Board Committee meeting

The Board Secretary will advise the Board/Board Committee Chair of any Director/Member who has been or will be absent from meetings of the Board/Board Committee for three consecutive months and advise the Board/Board Committee Chair of the explanation provided by the Director/Member, if any. The Board/Board Committee Chair will then decide whether to authorize the Director’s/Member’s absence by a Board/Board Committee resolution.

The Board Secretary will notify City Council of a vacancy if any Director is absent from any Board meetings for three consecutive months without authorization of the Board.

Quorum

The quorum for a meeting of the Board/Board Committee shall be a majority of the total number of all voting Directors/Members presently sitting on the Board/Board Committee, not including any vacancies that have yet to be filled.

A meeting will be cancelled if:

• no quorum is present within fifteen minutes after the time fixed for a meeting, or the continuation of a meeting after a recess, or
• if quorum is lost for fifteen consecutive minutes

If a meeting is cancelled due to lack of quorum:

• the Board Secretary will record the names of the Directors/Members present, and
• the meeting will be considered adjourned until the next scheduled meeting or until the Board/Board Committee Chair calls a special meeting

If a quorum is not possible because of declared conflicts of interest the remaining Directors/Members will constitute a quorum provided that quorum is never less than two Directors/Members.

Board of Director Meetings

In the absence of both the Chair and the Vice-Chair for a period of fifteen minutes after the appointed time of the meeting, if a quorum is present, the Board Secretary shall call the meeting to order and preside over the appointment of one of the other Directors as Acting Chair to preside and discharge the duties of the Chair during the meeting, and until the arrival of the Chair or Vice-Chair.

Board Committee Meetings

In the absence of the Chair for a period of fifteen minutes after the appointed time of the meeting, if a quorum is present, the Board Secretary shall call the meeting to order and preside over the appointment of one of the other Committee Members as Acting Chair to preside and discharge the duties of the Chair during the meeting, until the arrival of the Chair.

Chair of Board of Directors Meeting

The Chair of any meeting of the Board of Directors shall be the Board Chair. If the Board Chair is not available, the Vice-Chair, if available, will assume the Chair of the meeting. If neither the Board Chair nor the Vice-Chair are available, another Director who is present at the meeting and selected by the Directors who are present, may assume the Chair of the meeting.

Chair of Board Committee Meeting

The Chair of any Board Committee meeting shall be the Committee Chair. If the Committee Chair is not available, another Committee Member who is present at the meeting and selected by the Committee Members who are present, may assume the Committee Chair of the meeting.

Agendas and Minutes

The agenda and any other agenda material such as minutes and reports shall be delivered the Board of Directors or the Board Committee Members no less than 24 hours before the meeting.

Toronto Seniors Housing Corporation has a standard practice of sending agenda materials out to Directors/Members seven calendar days prior to the meeting. Meeting notices are posted in tenant buildings and the agenda materials are posted on the Toronto Seniors Housing Corporation website seven calendar days in advance of the meeting.

While the standard is to have all agenda items available in advance of the meeting, there are times where this is not always possible (for example, items are not available or come up after the agenda has been issued). At the Board/Board Committee Chair’s discretion, reports may be tabled at the meeting.

The Board Secretary will keep minutes of all Board/Board Committee meetings.

The minutes will record:

• the place, time and date of the meeting
• the name of the Chair, the Directors/Members present, and the members absent
• any correction to, and the adoption of, the minutes of the previous meeting
• all resolutions
• any declarations of a conflict of interest, including the Director’s/Member’s name and the reason for the conflict of interest

Reference will be made in the minutes to an agenda item discussed in a closed meeting and the reason why the discussion was closed to the public.

The minutes will record that a motion was carried or defeated, with no count of the vote, unless the vote was recorded. For recorded votes, the members’ names and corresponding votes will be recorded in the minutes after the Board/Board Committee Chair has announced the results.

The minutes of the previous meeting will be considered at the next meeting and, after the minutes have received approval, or approval as amended, by the majority of the Directors/Members present, they will be signed by the Board Chair or the appropriate Committee Chair.

Review of Agenda

Upon calling the meeting to order, the Board/Board Committee Chair will request Directors/Members to identify any conflicts of interest with any item on the agenda.

Declaration of Conflict of Interest

Directors/Members must observe the requirements of the Conflict of Interest Policy by declaring any conflict of interest they have, directly or indirectly, in any matter before the Board/Board Committee.

A Director/Member must declare any conflict of interest at the beginning of the meeting, on arrival at the meeting, or if not present at the meeting, at the next meeting attended. During the meeting, a Director/Member shall declare a conflict of interest following the moment where they realize they have a conflict of interest.

A Director/Member who has declared a conflict of interest in a matter must not take part in the discussion, must not vote, and must not try to influence the voting, on the matter.

If the discussion takes place in a closed meeting, the Director/Member must leave the room or by electronic means if attending by telephone or videoconference.

All declarations of conflict of interest are recorded in the public minutes. Declarations of conflict of interest made in public must also specify the general nature of the interest declared.

Voting on Motions

All matters will be decided by a majority vote of the Directors/Members present.

A Director/Member must be present when the motion is put in order to vote.

All Directors/Members present when the motion is put to the vote must vote, unless prohibited by statute, in which case it shall be so recorded. Any Director/Member who refuses to vote is deemed to have voted against the motion except where prohibited from voting by statute.

During a Board of Directors meeting, any Director may propose a motion and/or second the motion. However, during a Board Committee meeting only a Board Committee Member is allowed to propose a motion and/or second the motion, with the exception of the Board Chair who serves as an Ex-Officio. Voting on all motions will be by a show of hands. The Board/Board Committee Chair or Acting Chair must vote with the other Directors/Members on all questions.

In the case of an equality of votes on any question at a meeting of the Board/Board Committee, the Board/Board Committee Chair of the meeting shall be entitled to a second or casting vote. A motion to reconsider is required to reopen a matter once the result of the vote is announced.

Recorded Vote

The Board/Board Committee Chair will conduct a recorded vote if requested by any member.

The request must be made immediately before or after the taking of the vote.

The Board Secretary will record the name and vote of every Director/Member for the minutes and announce the results to the Board/Board Committee Chair.

Results of the vote, including the name and vote of every Director/Member, will be announced by the Board/Board Committee Chair immediately after the recorded vote has taken place.

Resolution in Lieu of Meeting

A resolution in writing signed by all the Directors/Members entitled to vote on that resolution at a meeting of the Board/Board Committee, is as valid as if it had been passed at a meeting of the Board/Board Committee, provided that a copy of every such resolution shall be kept with the minutes of the proceedings of the Board/Board Committee.

Public Proceedings

Public proceedings of the Board/Board Committee are open to members of the public. As such, the public is notified of all public meetings. Reports and other items which are part of the public proceedings and any debate and voting of such items are open to the public.

Conduct of Public at Meetings

Members of the public will be courteous and will not engage in any action which disturbs the meeting.

Members of the public should observe agreed-upon meeting protocol and display courteous and respectful conduct toward each other, Board Directors/Committee Members, and staff in all Board and Board Committee meetings.

Members of the public will not:

• make any noise or disturbance that prevents members from being able to participate in the meeting
• address the Board without permission
• use unparliamentary or offensive language, or
• display signs or placards

The Board/Board Committee Chair may exclude any person from the meeting for improper conduct.

“In Camera” and Closed Proceedings

Board/Board Committee meetings of TSHC are required to be open to the public except for items that satisfy specific criteria as indicated in Toronto Seniors Housing Corporation By-law number 1 Section 4.19. “In camera” and closed proceedings (meetings that are not open to the public) may take place to discuss matters specified in Section 4.19 of the Toronto Seniors Housing Corporation By-law number 1. This section establishes the process by which items can be confirmed for discussion in closed session according to By-Law criteria.

Normally, items to be considered in Closed session are determined by the Board Chair/Board Committee Chair and Chief Executive Officer or delegate in the process of developing the Board/Board Committee agenda.

From time to time, an individual Board Director/Committee Member may request items for consideration in closed session, in which case the request must be made at least three business days prior to the Board/Board Committee materials being sent out to Directors/Members. During this time period, the Board/Board Committee Chair will determine whether the item fits the specified criteria. If the item is determined by the Board/Board Committee Chair not to fit the specified criteria and the Director/Member bringing the item forward disagrees with the assessment, the whole Board/Board Committee shall vote on whether to include the item in the closed session at the time of closed session agenda approval at the Board/Board Committee meeting.

If during a Board/Board Committee meeting a Director/Member wishes to have a discussion of an additional issue in closed session not previously identified and not on the meeting agenda, this must be declared at the time of the open session agenda approval. At that time the Director/Member will identify the issue. The Board/Board Committee will go into closed session and the Director/Member will make the case for the item to be discussed there including why it satisfies the specified criteria and why it should be discussed at the current meeting. The Board/Board Committee will then vote as to its inclusion on the agenda for the closed session. After a positive vote the item can be discussed in closed session. As with all closed session agenda items, any motions stemming from the discussion shall be voted on in the public proceedings.

Prior to the commencement of an “in camera” or closed meeting, a motion must be made to move “in camera” or to closed meeting, stating the reason(s) the matter requires a closed meeting under Section 4.19, Subsections (1) and (2) of the By-law. At the conclusion of the “in camera” or closed meeting, the Board/Board Committee Chair, if applicable, will announce the time of the resumption of the public meeting.

Deputations

Any member of the public may ask to make a deputation at a Board or Board Committee meeting. A deputation is a way for people to speak at a Board or Board Committee meeting about a specific subject on the public agenda. Deputations can be spoken or in writing, however they need to be about items that are on the public meeting agenda.

Any person wishing to make a deputation to the Board or Board Committee regarding items for action or information on the agenda will be heard by the Board/Board Committee provided:

• A request to speak at a meeting or to submit a written deputation is made to the Board Secretary in writing by 12:00 p.m. on the business day prior to the Board/Board Committee meeting.
• Include the name, address, telephone number and electronic mail address of the person or organization wishing to address the Board.
• Include an outline of the submission to be made, and any relevant documentation.
• The Board/Board Committee Chair, in consultation with the Board Secretary, may waive the above requirements if, in the Chair’s opinion, there were extenuating circumstances or the deputation would no longer be relevant if made at another meeting.

The Board/Board Committee may hear a deputation about a matter not on the agenda with the approval of the Board/Board Committee Chair in consultation with the Board Secretary. Any request to present to the Board on a matter not on the agenda must:

• pertain to matters within the Board’s jurisdiction
• be received prior to the deputation deadline
• be in writing and sent to the Board Secretary
• include the name, address, telephone number and electronic mail address of the person or organization wishing to address the Board or Board Committee
• include an outline of the submission to be made and any relevant documentation

The Board/Board Committee Chair and the Board Secretary may agree to schedule the deputation on the agenda of the following Board/Board Committee meeting or another future Board or a Committee meeting. The Board/Board Committee Chair and the Board Secretary may refer matters to the CEO or a TSHC department.

While it is preferred that deputants inform the Board Secretary of their intention to depute it is not a requirement, however deputants who wish to ensure that their concerns can be adequately addressed by Directors/Members at the meeting may submit a written or alternate format[1] copy of their deputation at least three business days ahead of the meeting in order to allow enough time for:

• the distribution of deputation materials to Board/Board Committee members for their review prior to the meeting
• information-gathering by the Board/Board Committee Chair and/or Board/Board Committee members
• briefing of Board/Board Committee members on the issues raised, and
• clarification of issues/concerns raised

Deputants may only depute once on the same item. Each deputation is limited to five minutes per item (excluding questions from Board/Board Committee members). This time may be reduced or extended at the discretion of the Board or Board Committee Chair.

Presentations from groups or organizations shall have no more than three speakers. The number of speakers does not affect the total time limit for a presentation (five minutes).

Any person making a presentation to the Board/Board Committee shall:

• only speak on the subject(s) for which they have received approval
• obey the rules of procedure and any decision of the Board/Board Committee Chair
• refrain from using offensive or disrespectful language
• refrain from speaking disrespectfully of another person
• refrain from displaying signs or placards, applauding debating participants, or engaging in conversation or other behaviour that may disrupt the meeting

Failure to abide by these rules is grounds for the Board/Board Committee Chair to conclude or curtail a deputation. If the Board/Board Committee Chair rules that the deputation is concluded, the person or persons appearing before the Board/Board Committee shall immediately withdraw.

Conduct of Directors/Members at Meetings

A Director/Member will be courteous and will not engage in actions which disturb the meeting.

Directors/Members should observe agreed-upon meeting protocol and display courteous and respectful conduct toward each other and staff in all board/board committee meetings.

Directors/Members are to refrain from any behaviours that may not be appropriate in a work environment.

Directors/Members will inform the Board/Board Committee Chair each time they leave or re-enter the meeting.

A Director/Member will not:

• use unparliamentary or offensive language
• make any noise or disturbance that prevents members from being able to participate in the meeting
• interrupt another member who is speaking, except to raise a Matter of Privilege or a Point of Order
• disobey the rules of the Board or disobey a decision of the Board/Board Committee Chair or the Directors/Members on questions of order, practice, or the interpretation of the rules of the Board

The Board/Board Committee Chair may exclude a Director/Member from the meeting who has been given a warning but continues to disregard the Board/Board Committee Chair’s rulings.

The same expectations and etiquette for Directors and Members apply to virtual meetings and hybrid meetings. Directors and Members are expected to have the same level of participation and conduct regardless of the methods of how they participate in the meeting. Remote participants are to use video to increase their presence in the meeting and raise a hand (or virtual hand) before responding to questions or offering feedback.

New Business from Board Directors/Committee Members

A Director/Member who wishes to add new business to a meeting agenda brings a main motion before the Board/Board Committee and will provide the Board/Board Committee with the following:

Notice of Motion during a Board/Board Committee Meeting:

Notices of Motion by Directors/Members submitted before the agenda deadline must be in writing and in a form that the Board Secretary approves and be signed by the Director/Member moving it and the Director/Member who seconds it. No signatures are required for notices received via email, but the seconder’s name must be included in the correspondence and the seconder must be copied on the email.

Notice of Motion by Directors/Members after the agenda deadline, but before the Board/Board Committee meeting:

• Must be in writing and in a form that the Board Secretary approves and be signed by the Director/Member moving it and the Director/Member who seconds it. No signatures are required for notices received via email, but the seconder’s name must be included in the correspondence and the seconder must be copied on the email.
• Must relate to an urgent matter as determined by the Board/Board Committee Chair and the Board Secretary.

If the Board Secretary and Board/Board Committee Chair do not agree that the motion deals with an urgent matter, the Board Secretary will refer it to the next Board/Board Committee meeting and present a list of these motions to the Board/Board Committee for information only.

A Motion that fails to comply with the notice requirements may be considered by the Board/Board Committee if a two-thirds majority of the Directors/Members present vote in favour of its introduction.

Motion Without Notice during a Board/Board Committee Meeting:

A Director/Member may make a motion without notice during a meeting if it complies with the requirements outlined here;

• the Board/Board Committee Chair reviews it in advance and agrees that it concerns an urgent matter and allows the Director/Member to ask the Board/Board Committee’s permission to introduce the motion without notice, and
• two-thirds of all Directors/Members vote in favour of its introduction

Communications

Communications may be made in writing addressed to the Board/Board Committee, to the Board/Board Committee Chair, or to the Board Secretary.

Communications must:

• pertain to matters over which the Board has jurisdiction
• be in a legible hand-written or printed form
• contain a name, address and/or telephone number, and an electronic mail address if delivered by electronic mail
• contain a signature unless delivered by electronic mail
• not contain offensive language

All communications, including personal information and opinions contained in a communication, that the Board/Board Committee receives about a matter on the agenda becomes part of the public record, unless the Board Secretary determines the disclosure of personal information would contravene the Municipal Freedom of Information and Protection of Privacy Act.

Communications that form part of the public record are available to the Board and to the public and may be distributed prior to, or during, the Board/Board Committee meeting.

Communications that the Board/Board Committee receives about a matter on the agenda may be provided to the Board/Board Committee if received by the Board Secretary by 12:00 p.m. on the business day prior to the Board/Board Committee meeting. The Board/Board Committee Chair in consultation with the Board Secretary may waive these requirements if, in the Board/Board Committee Chair’s opinion, there were extenuating circumstances.

For communications about matters not on the agenda the Board/Board Committee Chair, with the recommendation of the Board Secretary may:

• put the communication before the Board/Board Committee
• allow the Chief Executive Officer to consider the communication and to report to the Board/Board Committee, in response to the communication, or
• allow the Chief Executive Officer to respond to the communication as the Chief Executive Officer deems appropriate

Related Legislation, Regulations, and TSHC Policies:

• Toronto Seniors Housing Corporation By-Law number 1
• Municipal Freedom of Information and Protection of Privacy Act
• TSHC Board of Directors Conflict of Interest Policy
• TSHC Board of Directors Code of Ethics and Conduct Policy

Amendments:

Initial policy approved by the Board of Directors on March 31, 2022.

Policy reviewed in September 2024 with the following revisions, approved by the Board of Directors on October 17, 2024:

• edits made to align with Toronto Seniors Housing Corporation By-Law number 1
• integration of the Board Meeting Closed Session Policy
• review and update of the Deputation section to align with current practice
• additional content included in relation to hybrid meetings
• additional content included to enhance clarity regarding conducts in the meeting
• review cycle of this procedure identified as once every five years
• additional content added to include Board Committees

This Policy replaces the former Interim Deputation Policy and the former Board Meeting Closed Session Policy, both retired on October 24, 2024.

Next Scheduled Review Date: 2029

This Policy will be reviewed once every five years.

Policy Contact

Director, Strategy and Business Management

[1] Alternative formats will be accepted in cases where accommodation for a disability is required.

Hiring Policy

Effective date: 19 April 2022
Approval by: Executive Leadership Team
Approval Date: 19 April 2022

Policy Statement

Toronto Seniors Housing Corporation is committed to fair, equitable, and transparent hiring practices, and to employing qualified, high performing candidates who reflect the diversity of Toronto, our communities, and the organization’s core values.

Scope

 This policy applies to all internal and external hiring (full-time, part-time, casual, or seasonal) for Toronto Seniors Housing Corporation positions, including:

• vacancies in the management/exempt category;
• vacancies in the bargaining unit; and
• paid student placements.

Where this policy conflicts with the requirements of a collective agreement, the collective agreement will govern.

Values

Toronto Seniors Housing Corporation is committed to hiring practices from assessment to selection of candidates that:

• are fair, equitable, consistent, and transparent;
• meet statutory obligations, including the Ontario Human Rights Code, Employment Standards Act, Accessibility for Ontarians with Disabilities Act, Municipal Freedom of Information and Protection of Privacy Act (MFIPPA), and the Municipal Act;
• support the unique requirements of each community and business unit;
• are linked to business and operational needs;
• hire persons with the qualifications required by Toronto Seniors Housing Corporation for the corresponding job. Qualifications include but are not limited to education, training, skills, experience, and/or ability to perform the work satisfactorily;
• consider seniority in accordance with the collective agreement, where applicable; and
• support workforce diversity as per the Toronto Seniors Housing Corporation Diversity Policy.

Standards

Conflict of Interest

All employees involved in the hiring process must abide by the Toronto Seniors Housing Corporation Conflict of Interest Policy. If an employee is in or will be in a conflict of interest during the hiring process or upon hire of a candidate, the employee must immediately declare the conflict of interest. For more information, please see the Toronto Seniors Housing Corporation Conflict of Interest Policy.

As per the Code of Conduct, information gathered during the hiring process should be kept confidential and only shared with employees who need to know the information for purposes directly associated with their work (i.e. the Hiring Manager, employees who are on the interview panel, Recruiters involved in the hiring process for the particular job, etc.).

Confidentiality

All interview panel members must also maintain the confidentiality of the interview process. This means the identity of the interviewees, interviewee scores, the questions that are asked, the interview answer key, or the results of the interview(s) should be kept confidential and only shared with employees who need to know the information for purposes directly associated with their work (i.e. other panel members or the Hiring Manager).

Definitions

Vacancy: a position that has become available at Toronto Seniors Housing Corporation when:

• a permanent or temporary position becomes available and it is determined by Toronto Seniors Housing Corporation that the vacancy should be filled; or
• a temporary or permanent position is created and approved.

Acting Assignment: the temporary placement of an existing employee who occupies a base position and who is temporarily placed in an alternate position on a continuous basis for a period of 30 days or more. For more information see the Toronto Seniors Housing Corporation Acting Assignment Policy.

Advertisement(s): any vacancy that is advertised externally via the external careers pages, websites, and print media such as newspapers, journals, or trade publications.

Candidate: any individual, whether internal or external, who has applied for a vacancy and/or in response to a posting.

Collective Agreement(s): the most recent collective agreement between Toronto Seniors Housing Corporation and a union(s). 

Conflict of Interest: any situation in which an employee’s personal or business interests may compete or appear to compete with their duties as an employee of Toronto Seniors Housing Corporation or may cause the employee to act contrary or appear to act contrary to the best interests of Toronto Seniors Housing Corporation. A conflict of interest can be an actual conflict, a potential conflict, or an apparent conflict of interest as per the Conflict of Interest Policy.

Divisional Lead: the Vice-President (or other member of the Executive Leadership Team) responsible for a specific division within the organization.

Hiring Manager: an employee who has direct or indirect supervisory responsibilities to the new hire or rehire.

HR Connect: an electronic system used to manage the hiring process at Toronto Seniors Housing Corporation.

New Hire(s): all individuals being hired by Toronto Seniors Housing Corporation who are not or have not previously worked at Toronto Seniors Housing Corporation.

Permanent Position: a position where employment is for an indefinite period of time based on the operational needs of the organization.

Posting: refers to a vacancy that is advertised on Toronto Seniors
Housing Corporation’s internet/intranet and/or other external websites.

Recruiter: A member of Talent Acquisition team in the Human Resources division of Toronto Seniors Housing Corporation.

Rehire(s): refers to any individuals who previously worked at Toronto Seniors Housing Corporation prior to resigning, retiring, or being terminated.

Salary, Vacation or Benefits Exception: a situation that falls outside of the standards or past practice for Toronto Seniors Housing Corporation with regards to compensation, vacation, or benefits (this applies to management/exempt employees only).

Temporary Position: a fixed-term temporary position that is not an acting assignment, where employment is for a pre-determined period of time based on the operational needs of the organization. .

Union: refers to employees represented by any of the following: Canadian Union of Public Employees (CUPE) Local 79; Toronto Civic Employees Union Local 416; Ontario Public Service Employees Union Local 529; United Association of Plumbers and Steamfitters Local 46 (Plumbers and Steamfitters); International Brotherhood Electrical Workers Local 353; United Brotherhood of Carpenters and Joiners of America Local 27. Also referred to in this policy as a “bargaining unit.”

Policy Details

Pre-Posting Approval Phase

 All vacancies must be entered into HR Connect by the Hiring Manager to create the job requisition, which initiates the hiring process. All necessary approvals must be completed in HR Connect before the hiring process can proceed. Budgeted positions require the approval of the Divisional Lead and unbudgeted positions require additional levels of approvals as outlined in HR Connect. All new permanent positions must first be approved through the annual budgeting process.

A job description and job information questionnaire must be completed by the Hiring Manager for newly created temporary or permanent positions. The job must be evaluated before a job requisition can be created and before the hiring process can proceed.

The Recruiter will also work in consultation with the Hiring Manager to determine the appropriate recruitment strategy, which includes timelines for filling the vacancy, appropriate selection and assessment criteria, hiring panel composition, and methods for attracting qualified candidates.

Notices regarding new job requisitions will be provided to unions as required by the respective collective agreements.

Job requisitions that have been approved but have not been actioned within four (4) months will be cancelled. The Recruiter will notify the Hiring Manager in advance of cancelling the hiring process and will work with them to determine the best course of action. If the job was posted, candidates will be notified of the cancellation.

Posting of Positions

All vacancies must be posted internally on the Toronto Seniors Housing Corporation intranet careers page for a minimum of fourteen (14) calendar days. The vacancy may be advertised externally at the same time as the internal posting with no minimum posting requirement. Human Resources is responsible for and must approve all internal and external job postings or other job-related advertisements. 

The Human Resources division will be responsible for costs for job postings or other job-related advertisements at their discretion and as budget permits. The costs of any job advertisement requested by the hiring department that are not covered by Human Resources will be the responsibility of the department at their discretion. Any external advertisements must be approved by Human Resources before posting. Advertisements or postings for similar vacancies may be combined into one advertisement in order to make more efficient use of resources.

All temporary positions and management/exempt acting assignments will specify the following language in the job posting: “Please note: This temporary position may be extended or become permanent in order to meet business needs. If this occurs, the position may not be reposted”.

Exceptions to Posting Requirements

The HR Director, Talent Acquisition and Compensation may make exceptions to the fourteen (14) calendar day posting requirement:

• when it is required to place a qualified employee who many otherwise be displaced (e.g. due to a restructuring-related job elimination); and/or
• when the organization is obligated to accommodate an employee in accordance with relevant legislation.

In addition, exceptions to post positions may be made if the same role was recently filled no more than three (3) months since the time of the interviews for the initial competition, and where there are additional qualified candidates. Approval must be received by the Human Resources Director, Talent Acquisition and Compensation. In these cases, the job description for the roles must be the same.

Application Process

All candidates must create a profile and apply to vacancies through HR Connect. Candidates will be manually added to HR Connect as deemed necessary by the Recruiter and/or to satisfy Toronto Seniors Housing Corporation’s obligations under AODA or Ontario Human Rights Code.

Late resume submissions and unsolicited applications are not accepted. The Talent Acquisition team reserves the right to add candidates identified by approved recruitment sourcing techniques to the competition (i.e. candidates found through sourcing and networking). 

Eligibility

Former Toronto Seniors Housing Corporation employees may be considered for employment as per the procedures outlined in Re-Hiring Employees After Separation Policy.

Management and exempt employees cannot start another position until they have completed six (6) months in their current position.

 Employees who are members of CUPE Local 416 who have recently been hired or transferred into a new role at TSHC may not apply for another position unless the start date for this position is more than twelve (12) months after their start date.

Screening

Screening must be completed using objective selection criteria related to the minimum skills, experience, and qualifications required for the job as outlined in the applicable job description. The selection criteria must be consistent throughout competition for the position.

Once a job posting closes, the Recruiter screens all applications and identifies a shortlist of candidates. The screening results are to be documented in HR Connect.

 In order to recognize and retain our top talent, where experience is comparable, qualified internal candidates are given priority consideration over external candidates.

Interviewing

In compliance with the Ontario Human Rights Code, Toronto Seniors Housing Corporation is committed to conducting interviews that are evaluated on a consistent and objective scale.

 Interview guides, assessments, scoring and hiring panelists are to be approved by the Recruiter. In addition, the Recruiter may choose to participate in the interview process at their discretion (typically in cases where Hiring Managers are new to the organization or interview infrequently). All interview panelists are required to complete interview training offered by Human Resources prior to their participation in any interview.

Secondary selection methods such as presentations, assignments, practical/written tests, psychometric testing may also be used with the approval of the Recruiter.

 Interview notes are to be restricted to the assessment of the candidates’ qualifications. Completed interview guides must be returned to the Recruiter within five (5) days of scoring and will be retained by Human Resources for two (2) years after the date the successful candidate commences their position.

Candidate Selection and Job Offer

Candidate selection is based on an assessment of the candidate’s ability to perform the duties and responsibilities of the job as outlined in the applicable job description. In determining suitability for a position, Toronto Seniors Housing Corporation will consider factors such as the candidate’s education, experience, knowledge, abilities and where applicable, seniority or other relevant provisions within a collective agreement. Internal candidate selection for management and exempt positions also takes into consideration the candidates past performance at TSHC.

The Recruiter, in consultation with the Hiring Manager, will approve the selected candidate as well as any offer details, including appropriate compensation, benefits and start date.

Once the offer details are confirmed, the competition will then proceed to the final stages in accordance with the following guidelines:

1. Reference checks will be conducted in accordance with the Employment Reference Checking section of this policy. Reference checks must be conducted before any verbal offer is made. In limited cases, and only with the approval of the Head of People and Culture or designate, offers can be made conditional on a satisfactory reference check.
2. If required, the Hiring Manager must prepare a business rationale for any Salary, Vacation or Benefits Exception requests. Approval must be obtained by both the Divisional Lead and the Head of People and Culture or designate prior to any verbal or written offers being made to the candidate.
3. Verbal offers will be made by the Recruiter and will highlight the main terms of employment including compensation, benefits, and start date.
4. After the verbal offer is accepted, a written offer will be sent through HR Connect for e-signature by the successful candidate. Any verbal offers are subject to the final written offer, which will contain all terms and conditions of employment.
5. If required, Police Background or Criminal Record Checks must be conducted before the start of employment and any verbal or written offers should be conditional until they are completed.

Upon e-signature by the successful candidate, all other candidates will be notified that they were not the successful candidate in the competition. Internal candidates may request feedback from the Hiring Manager, Recruiter, or as otherwise set out in the collective agreement. 

For successful internal candidates, the Hiring Manager, the employee’s current Manager, and the candidate must arrange a mutually agreed upon transfer date. The Hiring Manager will advise the successful candidate prior to contacting their current manager to discuss the transfer date. The transfer date is to occur no later than six weeks after the employee has accepted the verbal offer, unless otherwise approved by the Head of People and Culture or designate. Vacancies created by a transferring employee will, wherever possible, be treated as priority.

Employment Reference Checking

Reference checks are an important and integral component of the hiring process. Toronto Seniors Housing Corporation ensures that the procedure for the collection and disclosure of reference information is practiced confidentially and consistently.

All new hires and rehires to Toronto Seniors Housing Corporation are required to have two (2) employment references completed before a verbal or written offer is made. The employment reference checks must meet the following criteria: be former direct supervisors, cover as much of the new hire or re-hire’s last five (5) years of work history as possible, and one reference must be from the candidate’s most recent employer.

In cases where the individual is a recent graduate and/or has less than one (1) year of work experience, other references or documentation may be accepted (i.e. non- supervisor references, recent performance appraisals, and teacher references). These decisions will be made on a case-by-case basis and with the approval of the Recruiter.

Internal candidates may be subject to an internal reference check as part of the hiring process, unless otherwise prohibited by the Collective Agreement. Where an internal reference check is required, the reference checks must be completed with any manager the employee has reported to in the last one (1) year period.

 Consent must be obtained from the candidate (internal or external) prior to any references being conducted. No other references will be contacted under any circumstances.

Reference checks may be completed by the Hiring Manager and/or the Recruiter. In either case, the Recruiter will review and approve any reference checks.

Records Retention and Auditing

The Recruiter is responsible for ensuring all applicable documentation in the recruitment process is retained onsite in the job requisition and candidate pages in HR Connect during active competition and for a minimum of two (2) years after.

Audits of the hiring process are completed quarterly to ensure that the requirements of the Hiring Policy, legislation, collective agreements, procedures and guidelines are met.

 A copy of the successful candidates resume, references and police record check (if applicable) will be kept on their personnel file.

New Hire and Rehire Documentation

All new hire and rehire documentation must be received from the successful candidate no later than the deadline provided by the Hiring Manager or Recruiter. If there are any delays in receiving the required documentation prior to the employment start date, Human Resources will notify the Hiring Manager and a new start state will be determined.

Age Requirements

Candidates must be legally entitled to work in Canada. Candidates for entry-level positions in the Active Living Unit and candidates for positions created as part of the work of the Economic Opportunities Unit must be at least 14 years of age.

Conversion of Temporary Positions or Acting Assignments to Permanent Positions

If an employee has been placed on an acting assignment or hired externally to fill a non- union position on a temporary basis, the employee will qualify to be placed permanently in the same job classification without further competition. See Acting Assignment Policy for more details.

Compliance and Monitoring

All hiring files are subject to periodic audits in order to ensure compliance to this policy. Complaints on this policy will be addressed by Recruitment through the Recruitment Complaints Process and grievance process, where applicable.

Governing and Applicable Legislation

• Municipal Act;
• Ontario Human Rights Code;
• Employment Standards Act;
• Occupational Health and Safety Act;
• Accessibility for Ontarians with Disabilities Act;
• Municipal Freedom of Information and Protection of Privacy Act.

Ontario Human Rights Code (OHRC)

Toronto Seniors Housing Corporation is committed to hiring and retaining a diverse workforce in accordance with the Toronto Seniors Housing

Corporation Diversity Policy. Toronto Seniors Housing Corporation is also committed to preventing discrimination in its hiring practices based on any prohibited grounds identified by the Ontario Human Rights Code.

Accessibility for Ontarians with Disabilities Act, 2005 (AODA)

Toronto Seniors Housing Corporation is committed to accessible hiring practices in accordance with its obligations under the Accessibility for Ontarians with Disabilities Act, 2005 and its regulations and the Toronto Seniors Housing Corporation Accessibility Policy. Should an employee require accommodation during the hiring process, they are encouraged to contact accessibility.hr@torontohousing.ca or 416-981-4119.

To improve accessibility in its hiring practices, Toronto Seniors Housing Corporation will also:

• include a notification in all job postings about the availability of accommodation in the hiring process for candidates with disabilities;
• inform candidates who are chosen to participate in an assessment or selection process that accommodations in relation to materials and processes are available upon request;
• consult with candidates requesting accommodation to determine a suitable accommodation that takes into account his/her accessibility needs;
• upon hire, inform successful candidates about Toronto Seniors Housing Corporation’s policies for accommodating and supporting employees with disabilities; and
• comply with all other requirements of the Accessibility for Ontarians with Disabilities Act, 2005 or company policy regarding accessibility.

For more information see Accessibility Policy and Accessible Customer Service Policy and Human Rights, Harassment and Fair Access Policy.

Employment Standards Act, 2000 (ESA)

Toronto Seniors Housing Corporation complies with the ESA as it relates to its hiring practices.

Municipal Freedom of Information and Protection of Privacy Act (MFIPPA)

Toronto Seniors Housing Corporation is committed to respecting privacy and protecting the personal information of employees and other candidates in accordance with MFIPPA. Toronto Seniors Housing Corporation also requests consent for reference information collected during the hiring process.

Related Policies and Procedures

• Accessibility Policy
• Accessible Customer Service Policy
• Acting Assignment Policy
• Applicable Collective
• Conflict of Interest Policy
• Human Rights, Harassment and Fair Access Policy
• Police Reference Check Policy (in draft)
• Re-Hiring Employees After Separation Policy
• Student Placement Policy (draft complete, pending approval)

Use of Community Space

Policy Sponsor: Director, Engagement, Partnerships and Communication
Approver: Board of Directors
Initial Approval Date: October 17, 2024
Date of Last Revision, if applicable: [N/A]
Effective Date: January 1, 2025

Policy Statement

Eligible tenants and agencies may use Toronto Seniors Housing Corporation’s (TSHC) community spaces for events and programming activities. The objective of this policy is to govern the use of community space by tenants and agencies providing programs and services to tenants. The proper allocation and use of these community spaces help the Toronto Seniors Housing Corporation meet the community’s needs.

Policy Objective(s)

The purpose of this policy is to establish clear guidelines, procedures, and standards for anyone wishing to use community space in TSHC-managed buildings.

Scope
This Policy applies to all TSHC tenants, Agencies providing programming, Toronto Seniors Housing employees, and Community space operated by TSHC.

Out of Scope
This Policy does not apply to Agencies leasing space, commercial space, and residential space.

Definitions

Agency: In this Policy, an agency is an incorporated not-for-profit organization, a registered charity with the Canada Revenue Agency, a healthcare service provider as defined by the Regulated Health Professions Act, 1991, SO 1991, c 18, a City of Toronto department or subsidiary. In this Policy, in order to be considered an agency at TSHC, they must have an approved Agency-led Community Event, or Recurring Use of Community Space agreement and the appropriate insurance in place.

Casual Use: The availability of a room for drop-in use by tenants during opening hours when the room is not pre-booked for any activity or event.

Commercial Space: Space within a Toronto Seniors Housing Corporation building designated by Toronto Seniors Housing Corporation for commercial, retail or industrial use permits commercial or mercantile activity and can be leased out in exchange for rental revenue. Commercial space is not available for tenants to use under this Policy.

Community Event: A one-time event:

• that is open to all tenants;
• that is free for tenants; and
• where the activities and purpose of the event are to improve the health and well-being of tenants.

Community Space: Shared use of space by tenants, guests, and agencies at various times of the day or week on a recurring basis to provide programs, services, and activities that benefit tenants, such as a community room, library or recreation room. For example, an agency that provides a weekly Exercise and Falls Prevention class on a recurring basis in the recreation room at a building. These spaces are not intended for commercial, retail, or industrial use.

Exclusive Use of Space: An agreement exists with a service provider for use of the space by a sole occupant for a defined time period, when programs, services and activities are provided.

Nominal Fee: This is a small charge for participating in a program or service. This is a recovery cost associated with providing a program or service. In this Policy, only agencies can charge a nominal fee.

Non-Residential Space: Space within a Toronto Seniors Housing Corporation-managed building used for purposes other than providing residential housing. All non-residential space is further designated into one of the following categories:

• community space; or
• commercial space.

One-Time Use of Community Space: Use of the community space by a tenant, tenants, or an agency for a defined, non-recurring time for a:

• private event; or
• community event.

Private Event: A one-time event that is not open to all tenants or the public, such as a birthday party or a wedding. Only tenants can use community space for private events. Agencies are not allowed to book space for private events.

Residential Space: Space that is used for residential housing pursuant to the Residential Tenancies Act, 2006, SO 2006 c 17 (the “RTA”), as amended from time to time.

Tenant: A person who, pursuant to a residential lease agreement with Toronto Seniors Housing Corporation or a Toronto Seniors Housing Corporation-approved sub-landlord, lives in a Toronto Seniors Housing Corporation-managed building.

Roles and Responsibilities

Community Programs and Partnerships (CPP) Team

• Responsible for reserving space for one-time and recurring events in community spaces. In consultation with Regional Operations, Community Programs and Partnerships, staff are responsible for monitoring activity to ensure compliance with this policy and related procedures.
• Responsible for organizing building meetings to determine tenant priorities for programming at their buildings.

Regional Operations Manager(s)

• Responsible for reviewing and approving Use of Community Space applications.

Tenant Engagement and Services Supervisor (TESS)

• Responsible for assisting staff with submitting the Use of Community Space application and coordinating the space by supporting the process for key access.

Senior Services Coordinator (SSC)

• Responsible for assisting tenants in applying for the Use of Community Space and coordinating the space by allowing key access. The SSC can also print flyers for any community events.
• Responsible for collecting fees from tenants hosting a private event and sending them to their Programs and Partnerships Clerk for processing.

Policy Content

Equity Impact Statement

Toronto Seniors Housing Corporation is committed to providing an inclusive living environment free of discrimination and harassment consistent with the principles outlined in the Ontario Human Rights Code (“Code”), and the Accessibility for Ontarians with Disabilities Act (“AODA”).
The use of community space must not conflict with Toronto Seniors Housing Corporation’s policies, including but not limited to Toronto Seniors Housing Corporation’s Human Rights, Harassment and Fair Access Policy or applicable legislation, including but not limited to the Code and AODA.

Guiding Principles

Having a set of guiding principles is crucial for making well-informed decisions. These principles act as a compass, helping us navigate complex situations and ensuring our decisions are fair and just.

• Limited Time: Private bookings and community events should not exceed five (5) hours. All other agency and tenant-led programming should not exceed three (3) hours per program. Additional hours require approval from the Regional Operations Manager. Attendees must exit at least 15 minutes earlier than their allocated time to allow for the next event set-up.
• Notify All: Signage in buildings is essential to convey what is happening and who is welcome (casual use, community event, community program, or private event).
• Event Clean-up: Those hosting and/or participating in activities are responsible for cleaning the room promptly after use and leaving it in a condition suitable for the next group by following the community room and kitchen guidelines.
• Triaging requests: Tenant-led and recurring activities should be prioritized over others. Larger inclusive events have priority over private events.
• First-come, first-booked: Those who book first should be favoured (though there may be instances when conversations about rescheduling are necessary).
• Watching the numbers: Clear capacity limits for each room should be established and communicated during planning.
• Link to Tenant Priorities: The activity or program should be tied to an identified need or interest expressed by the tenant community in a building. This does not apply to private events.
• Addressing Access: If tenants have ongoing difficulty accessing a program or activity in their building, the situation should be reviewed, and solutions should be explored with the hosts.

Criteria for Use of Community Space

Toronto Seniors Housing Corporation oversees allocation and decision-making for community space. Regional Operations, in partnership with the Community Programs and Partnerships team, assesses and approves Use of Community Space agreements. To remain compliant with applicable laws, TSHC has the sole discretion to restrict agencies in any particular residential complex and/or restrict services agencies are allowed to provide.

Tenants and agencies must satisfy all eligibility criteria to be considered for use of community space.

1. One-time Community Events led by Tenants and Agencies

To be eligible for community events and non-exclusive use of community space, tenants and agencies must:

• • primarily serve and benefit tenants by meeting a community need or priority
  • have a mandate and conduct activities that do not conflict with TSHC’s Policies, or applicable legislation, including but not limited to the Code, AODA, and the RTA
    • tenants wanting to hold a community event must complete a Tenant-led Recurring Programming or Community Booking Form
  • agencies wanting to hold a community event must complete an Agency-led Community Event form

2. One-time Private Events for Tenants

To be eligible for private events, tenants must:

• • conduct activities that do not conflict with TSHC’s Policies, or applicable legislation, including but not limited to the Code, AODA, and the RTA
  • complete a One-Time Use of Community Space Application Form and Insurance form and submit it to TSHC’s Community Programs and Partnerships team at least thirty (30) days before a private event or as otherwise advised by TSHC
  • leave the room in the same condition it was given. If tenants fail to leave the room in the same condition it was given, they will lose the privilege of applying to use the space for up to two (2) years from the event in question
  • follow the Guiding Principles listed in this policy and the Community Kitchen guidelines (guests attending an event must also follow these guidelines)

3. Agency-led Recurring Programming (Non-Exclusive Use of Community Space)

To be eligible for recurring programming, agencies must:

• • primarily serve and benefit tenants by meeting a community need or priority
  • submit a completed Recurring Use of Community space Agreement to useofspace@torontoseniorshousing.ca at least thirty (30) days before the first date of a recurring event, or as otherwise stated by TSHC
  • have at least seventy-five percent (75%) of program attendees be TSHC tenants
  • ensure that all program marketing materials, such as posters in buildings, are available in the top three (3) languages spoken by the building’s tenants
  • ensure that any supplies or items brought to the building are returned with them at the end of the program

4. Tenant-led Recurring Programming

To be eligible for recurring programming, tenants must:

• • primarily serve and benefit tenants by meeting a community need or priority
  • complete a Tenant-Led Recurring Programming or Community Event Booking Form and email it to useofspace@torontoseniorshousing.ca to book community space for recurring programming
  • not charge a fee to attendees for any tenant-led recurring programming
  • be inclusive to all tenants in the building

Bookings will be on a first-come-first-served basis. All bookings must align with the building’s tenant priorities. TSHC has the right to stop any programming that does not adhere to its guidelines and policies.

Bookings can last up to one year. At the end of their term, tenants must renew their bookings with a new booking form. Tenants are not required to obtain separate insurance for low-risk tenant-led recurring programming such as hiring an entertainer to perform, dancing, crafting, and playing indoor games.

Tenants are responsible for running programming independently or with other tenants.

Although the room is reserved for recurring programming led by tenants, other tenants can still access the space and not participate in the program. For example, if a tenant would like to host a game night every Thursday, other tenants can still access the Community Space and read their books. Tenants are required to be respectful and considerate of the booking.

5. Casual Use

• • All building tenants can use community spaces for casual use when no events or programs are scheduled. Tenants cannot exclude other tenants from using this space.
  • If tenants would like exclusive use of community space for themselves and their guests, please refer to this Policy’s One-Time Private Use for Tenants section.
  • If tenants fail to comply with the points above, they may be prohibited from using community spaces for a maximum of two (2) years.

Fees, Deposit and Insurance, and Additional Requirements

The following outlines fees and costs for the use of community space:

1. One-time Community Events led by Tenants and Agencies

Tenants or agencies holding a community event will not be subject to a deposit to occupy the agreed-upon community space for the community event.

• TSHC’s liability insurance covers community events held by tenants, which may eliminate the requirement for tenants to purchase separate insurance (unless otherwise stated by TSHC). However, tenants may purchase their own insurance to protect their own interests.
• Tenants and agencies must include Toronto Seniors Housing and Toronto Community Housing as additional named insured on the general liability Policy for liability arising from the insured’s operations.
• Tenants and agencies must provide TSHC with a Certificate of Insurance at least fourteen (14) days before their event.
• Tenants and agencies must maintain the insurance coverage for the entire duration of their event.

2. One-time Community Events led by Tenants and Agencies

All tenants using community space must obtain valid and appropriate insurance as required by Toronto Seniors Housing and provide proof of coverage for the duration of the event, as listed in the One-Time Use of Community Space application form. Tenants are required to have insurance coverage before submitting their application.

All tenants submitting a One-Time Use of Community Space application form must:

• obtain $5,000,000 general liability insurance coverage for the event
• include Toronto Seniors Housing and Toronto Community Housing as additional insured on the general liability Policy for liability arising from the insured’s operations
• provide Toronto Seniors Housing with a Certificate of Insurance at least fourteen (14) days before the event
• maintain the insurance coverage for the entire duration of the event

Tenants must pay a $75 non-refundable fee to book a private event. Tenants can coordinate payments with their local Senior Services Coordinator (SSC).

Related Legislation, Regulations, and TSHC Policies:

• Accessibility for Ontarians with Disabilities Act, 2005, SO 2005 c11
• Human Rights Code, RSO 1990, c H19
• Residential Tenancies Act, 2006, SO 2006, c 17
• TSHC Community Activities Fund Policy
• TSHC Visitor and Guest Policy
• TSHC Non-Residential Use of Space for Agencies Policy
• TSHC Translation and Interpretation Policy (under review)

Amendments (Revision History):

The initial policy was approved by the Board of Directors on October 17, 2024, effective January 1, 2025.

This Policy replaces the former Non-Residential Use of Space for Tenants Policy and Non-Residential Use of Space for Agencies Policy, retired on January 1, 2025.

Next Scheduled Review Date: 2028

This policy will be reviewed once every three years.

Policy Contact

Manager, Community Programs and Partnerships

Appendices

• Procedure – One-time or Recurring Use of Community Space for Tenants
• Procedure – Recurring Use of Community Space for Agencies

Absences from rent-geared-to-income units Guidelines

Guidelines Sponsor: Director, Operations
Approver: Board of Directors
Initial Approval Date: April 28, 2022
Effective Date: June 1, 2022

For a household paying rent-geared-to-income, the City of Toronto’s guideline for social housing sets 90 days as the maximum number of days that all members of the household can be “absent” or not living in their unit while continuing to receive a rent-geared-to-income subsidy. However, there are some exceptions to this rule.

This rule only applies if all members of your household are away at the same time.

Short absences of up to seven days in a row or less are not counted toward the 90-day limit within a 12-month period.

If all members of a household are away for more than 90 days in a row or more than 90 days within a 12-month period, and have not informed Toronto Seniors Housing Corporation, they could lose their rent-geared-to-income (RGI) subsidy. Informing Toronto Seniors Housing Corporation of any absence longer than 90 days will also help us to address safety and repair needs while a tenant is away.

Please tell us if you are in hospital, in rehabilitation, awaiting trial or have documentation to support another valid reason for being away from your unit longer than 90 days.

Learn more by reviewing the City of Toronto Absence from Unit from City Guideline 2013-9 https://www.toronto.ca/community-people/community-partners/social-housingproviders/rent-geared-to-income-administration/

Next Scheduled Review Date: 2027

This policy will be reviewed once every five years.

Guidelines Contact

Manager, Business Operations and Compliance

Appendices

City of Toronto Absence from Unit from City Guideline 2013-9

Who does the guideline apply to?

The guideline applies to tenants who live in a rent-geared-to-income (RGI) unit.

What is the guideline?

The guideline 2013-9 Local Eligibility Rule – Absence from Unit states the maximum number of days that all members of a household can be “absent” or not living in their unit and continue to receive a rent-geared-to-income (RGI) subsidy is 90 days. It also outlines the exceptions to this rule.

The maximum number of days that a household can be away from their unit is 90 days in a row or 90 days within a 12-month period.

This rule only applies if all members of your household are away at the same time. If at least one member of your household will be living in your unit during your absence, this rule does not apply. A member of your household is anyone listed on your Lease Agreement with Toronto Seniors Housing Corporation.

Short absences of up to seven days in a row or less are not counted toward the 90-day limit within a 12-month period.

Will I be eligible for RGI assistance if I am away for more than 90 days?

You will not be eligible for RGI assistance if you are away for more than 90 days unless you have given notice to Toronto Seniors Housing Corporation in writing of the reason you are away and the reason meets one of the exceptions as stated in the City’s guideline.

If you plan to be away for more than 90 days, call the Tenant Support Centre at 416-945-0800, email: support@torontoseniorshousing.ca or visit your Regional Office.

What happens if I lose my subsidy?

If you lose your subsidy, you will not lose your unit, but you will have to pay market rent.

What if I am the only member of my household and I have a medical condition that requires me to stay in hospital or be away from my unit?

If you are the only member of your household and have a medical condition that makes it necessary for you to be away from your unit for 90 days in a row or longer to receive treatment, call the Tenant Support Centre at 416-945-0800, email: support@torontoseniorshousing.ca or visit your Regional Office so we can help you keep your subsidy.

What happens if another member of my household (anyone listed on the Lease Agreement with Toronto Seniors Housing Corporation) has a medical condition and I have to be away from my unit to take care of them?

If all members of your household will be away due to this reason, call the Tenant Support Centre at 416-945-0800, email: support@torontoseniorshousing.ca or visit your Regional Office so we can help you keep your subsidy.

Will I be able to keep my subsidy if I am being held in jail while awaiting trial?

Yes. If a household has one member, and the member is absent because they are being held in jail while awaiting trial, they will not be considered absent from the unit. Paperwork/proof of the reason for absence must be provided to your Tenant Services Administrator. However, rent must also be paid while you are away.

What if the condition of my bail does not allow me to live in my unit for 90 days or longer?

If a household has one member, and a bail condition of release prevents the member from living in the unit, the household will not be considered absent from the unit. Paperwork/proof of the reason for absence must be provided to the Tenant Services Administrator. However, rent must be paid while you are away.

Will I lose my unit if I am convicted of a crime and serving a sentence?

If a household has one member, and the member has been convicted of criminal offence, the household will be considered absent from the unit for more than 90 days if the jail time served is greater than 90 days.

Note: Being convicted of a criminal offence does not make someone ineligible for RGI subsidy, unless the conviction is for RGI fraud or misrepresentation.

Someone who is convicted and serves a sentence leading to an absence of 90 days or more will lose their subsidy but not their unit and will have to pay market rent.

What are my options if I lose my RGI subsidy?

You can request a review of your eligibility for RGI subsidy by completing a Request for Review Form:

• in person at your Regional Office;
• by email to support@torontoseniorshousing.ca;
• by phone with a Tenant Services Administrator;
• by mail or fax.

Note: Requests for review must be made within 30 calendar days (plus five mailing days, if the request is mailed by the tenant) after the notice of decision has been given to the household by Toronto Seniors Housing Corporation. When you have completed your form, submit it to:

Toronto Seniors Housing Corporation

Attention: Review Body
423 Yonge St., 2nd Floor, Toronto, ON M5B 1T2

Addition to Family Composition Directive

Directive Sponsor: Director, Operations
Approver: Leadership Team
Initial Approval Date: May 17, 2022
Effective Date: June 1, 2022

Introduction

Toronto Seniors Housing Corporation (TSHC) recognizes that tenants may request that additional person(s) be added to their household composition from time to time due to changes in circumstances.

The Addition to Household Composition Directive will provide the framework to govern the standard practice and procedure in reviewing these requests, while supporting Toronto Seniors Housing Corporation’s commitment to equitable quality services and adhering to legal requirements as set out in the applicable legislation.

Directive Statement

TSHC is committed to a fair and equitable approval process for assessing tenants’ requests to add members to their household composition.

Application of Directive

This directive applies to all Toronto Seniors Housing Corporation Rent-Geared-to-Income (RGI) and Market Rent households who wish to add new member(s) to their household composition.

Directive Guidelines General Principle

Addition to Household Composition requests should generally be used to reunite families, however, doing so cannot create an underhoused situation that is in breach of the Occupancy Standards set out in the Toronto Municipal Code, Property Standards section.

Household refers to the people who live in a housing unit. Household can refer to one person who lives alone, or to a group of people who live together in a unit.

Rent-Geared-to-Income Households

Households may allow guests to stay with them for up to 30 days, in a twelve-month period, without asking for permission from Toronto Seniors Housing Corporation.

Households must report any guest who wishes to stay longer than 30 days, in a twelve-month period, as per Toronto Seniors Housing Corporation’s Visitor and Guest Policy.

Households requesting person(s) to be added as a Tenant (Leaseholder) or as an Occupant:

• To have guest(s) either become a tenant of an RGI unit or be added as an occupant of an RGI unit, the current tenant(s) must submit a completed Addition to Household Composition Request Form to Toronto Seniors Housing Corporation within 30 days of household composition change.
• The person(s) to be added and existing household members must be willing to provide the information, documentation and authorization necessary to determine whether they are eligible for RGI subsidy.

Limitations

Toronto Seniors Housing Corporation may decline to add an individual to an RGI Household if:

• The person(s) to be added does not meet basic eligibility criteria set out in social housing legislation.
• The addition(s) to the household would result in noncompliance with the Occupancy Standards set out in the Toronto Municipal Code, Property Standards.
• The existing household or the person(s) to be added has an outstanding balance with a social housing provider in Ontario, does not have a repayment agreement and/or is not up to date with repayments.
• The person(s) to be added was evicted from Toronto Seniors Housing Corporation for a non-arrears related issue in the last two (2) years or has been given a trespass notice and is no longer allowed on the property.

Important Note

• As per the current social housing legislation and Toronto Seniors Housing Corporation’s Visitor and Guest Policy, Addition to Household Composition requests must be submitted to Toronto Seniors Housing Corporation within 30 days of a change to the household composition as a result of a guest intending to reside in the RGI unit.
• The Household may become ineligible for RGI subsidy if new and/or existing members of the household do not meet the basic eligibility criteria set out in the social housing legislation.
• Households must not use Addition to Household Composition requests to assist any person to bypass the centralized waiting list or to assign^[1] or sublet^[2] the tenancy to another person.
• Toronto Seniors Housing Corporation may proceed with an application to the Landlord and Tenant Board or Court for an eviction if the addition of new a member was for the purpose of assigning the tenancy to another person.
• All applicable penalties as prescribed under the social housing legislation apply to any person who inappropriately helps another person obtain RGI subsidy.

Decision on Request

Toronto Seniors Housing Corporation will inform the household in writing of whether the addition to household composition request is approved or denied.

Approved

If the request is approved:

• A new lease agreement must be signed by all household members who are 59 or older.
• The rent will be recalculated based on the new total household income.
• The new member(s) will be deemed to be adequately housed and will be removed from the centralized waiting list where applicable, with the exception of new member(s) added to a rooming house household.

Denied

If the request is denied:

The household may appeal to the Regional Manager in writing.

If the person(s) to be added is not eligible for RGI subsidy, but the household continues to allow the person(s) to live in the unit, Toronto Seniors Housing Corporation will begin the Loss of Eligibility process and provide the household with 90 days written notice.

Market Rent Households

A Tenant is a leaseholder that has a contractual relationship with Toronto Seniors Housing Corporation. The Tenant(s) has sole responsibility for the rent, the unit, and is responsible for the actions of all non-tenants whom they permit to be on the Leased Premises.

An Occupant is a non-leaseholder adult who resides in a unit, but has not signed a lease with Toronto Seniors Housing Corporation. An Occupant does not have a contractual relationship with Toronto Seniors Housing Corporation, and has no legal rights, entitlements, or responsibilities to the Leased Premises.

A Market Rent Tenant may allow an Occupant(s) to reside in their rental unit. The Market Rent tenant may not, however, assign or sublet all or any part of the Leased Premises.

A Market Rent Tenant is required by their lease to report any changes in household composition within the same month the change occurs.

A Market Rent Tenant may request to add another Tenant to their unit and sign a new lease. It is up to the current Market Tenant to apply and not the proposed new tenant.

Reporting Occupants

Even where a Market Rent Tenant does not wish to add an Occupant as an additional Leaseholder, it is important that the Tenant reports all persons living with them in their unit. It is essential for safety and emergency purposes that TSHC knows who is living in its units.

Where a Tenant has reported that an Occupant resides in their unit, the Occupant may be entitled to apply for parking at the same rate that the Tenant pays for parking, provided other set of key requirements are met.

Household requesting person(s) to be added as a Tenant (Leaseholder)

• To have a person(s) become an additional Leaseholder, the original Market Tenant must submit a completed Addition to Household Composition Request Form.
• The person(s) to be added must be willing to provide the information, documentation and authorization necessary to determine whether they are eligible to be added to a Market Rent household.

Limitations

Toronto Seniors Housing Corporation may decline to sign a new lease to add an individual as an additional Tenant to a Market Rent household if:

• The person(s) to be added has no legal status in Canada as prescribed by Citizenship and Immigration Canada (i.e. legal status in Canada includes, but is not limited to, having a student visa, work permit, citizenship, permanent residency, being a refugee, etc.).
• The addition(s) to the household would result in noncompliance with the Occupancy Standards set out in the Toronto Municipal Code, Property Standards section.
• The person(s) to be added has an outstanding balance from a current or former tenancy with Toronto Seniors Housing Corporation or Toronto Community Housing Corporation.
• The person(s) to be added was evicted from Toronto Seniors Housing Corporation or Toronto Community Housing Corporation through an order of the Landlord and Tenant Board based on an illegal act (commonly referred to as an “N6”) in the last five (5) years.

Important Note

Toronto Seniors Housing Corporation will not sign a new lease to add an individual as an additional Tenant if either:

• The existing household has an outstanding balance with TSHC; or
• There is an active legal proceeding against the existing household for any arrears or non-arrears issue.

Decision on Request

Toronto Seniors Housing Corporation will inform the household in writing of whether the addition to household composition request is approved or denied.

Approved

If the request is approved to add new member(s) as Market Tenants (Leaseholders):

• A new lease agreement must be signed by all Tenant(s) of the household (existing and new).

If the request is to add a new member as an Occupant and not a Leaseholder, then:

• A new lease agreement is not required, but the Market Tenant may choose to sign a new lease with the new Occupant(s) listed in the “Occupants” section of the lease.
• The Occupant(s) shall have no rights or responsibilities to the unit.
• The existing Tenant(s) continues to be solely responsible for the rent, maintains all legal rights and responsibilities in relation to the unit, and is responsible for Occupant(s)’ actions on the leased premises.
• The Occupant(s) do not have any right to remain in the unit after the Market Tenant(s) (Leaseholder) moves out.

Denied

If the request is denied:

• The household may appeal to the Regional Manager in writing.

Accountability

• The Tenant Engagement and Services Supervisor will monitor application of this directive on an on-going basis.
• Random sampling reviews will be conducted on an annual basis by the Business Operations and Compliance Team.

Related Legislation, Regulations, and TSHC Policies:

• Housing Services Act, 2011
• Municipal Freedom of Information and Protection of Privacy Act
• Occupancy Standards of the Toronto Municipal Code, Property Standards section – Bylaw
• Ontario Human Rights Code
• Residential Tenancies Act, 2006
• TSHC Visitor and Guest Policy
• TSHC Human Rights, Harassment and Fair Access Policy – Tenants
• TSHC Market Rent Tenancy Agreement
• TSHC Rent-Geared-To-Income Tenancy Agreement

Amendments (Revision History):

Directive reviewed on May 17, 2022 by Board of Directions, effective June 1, 2022.

Next Scheduled Review Date: 2027

This policy will be reviewed once every five years.

Directive Contact

Manager, Business Operations and Compliance

^[1] When a Tenant(s) transfers their rights to occupy the rental unit and legal interests to someone else, and the Tenant(s) does not intend to return to the rental unit.

^[2] When a Tenant(s) moves out of the rental unit, lets another person live there for a period of time, but returns to live in the unit before the tenancy ends.

Visitor and Guest Policy

Policy Sponsor: Director, Operations
Approver: Board of Directors
Initial Approval Date: April 28, 2022
Effective Date: June 1, 2022

Policy Statement

This policy explains the way Toronto Seniors Housing Corporation will manage visitors and guests of all Toronto Seniors Housing Corporation tenants. Tenants may have visitors or guests in their homes. Toronto Seniors Housing Corporation and other social housing providers know that from time to time tenants may have guests who stay with them in their homes for a number of days at a time. These might include out-of-town guests, or persons who tenants have personal relationships with and are not part of their households.

A tenant may have a guest in their home for a maximum of 30 days, in total, within a 12-month period. The 30 days may be consecutive or non-consecutive days and applies to any one individual that stays in the tenant’s unit. In special cases, as defined below, guests may stay in a unit longer than 30 days.

Tenants are responsible for the actions and behaviours of anyone that they invite onto the residential complex including their visitors and guests.

This policy defines Toronto Seniors Housing Corporation’s practice for dealing with visitors and guests. It supports Toronto Seniors Housing Corporation’s commitment to equitable and quality service and meets legislative requirements.

Policy Objectives

The purpose of this policy is to make sure that all tenants understand their responsibilities related to visitors and guests, and for Toronto Seniors Housing Corporation to meet the following objectives:

• explain when a person is considered a visitor or a guest;
• explain when a market rent household is required to inform Toronto Seniors Housing Corporation of changes to their household composition as required by this policy;
• explain when a rent-geared-to-income household is required to inform Toronto Seniors Housing Corporation of changes to their household composition as required by this policy;
• establish the maximum length of time tenants can have guests;
• establish exceptions to the maximum permitted time for guests;
• balance the tenant’s right to use their home and Toronto Seniors Housing Corporation’s requirement to assess household eligibility for housing;
• make sure that subsidies are based on the true household income, including anyone who moves into the unit;
• help to make sure that subsidies are available to households that qualify; and
• ensure that residential units are not improperly transferred or sublet.

Scope

This policy applies residents in Toronto Seniors Housing Corporation households.

Out of Scope

Live-in caregivers are not covered by the scope of this policy. If a member of a household requires a live-in caregiver, the tenant must make the request in writing to have the live-in caregiver stay in their unit through their Regional office.

Definitions

Guests: Persons who require temporary accommodation with a tenant (guests do sleep in the tenant’s unit, but only for a maximum of 30 days within any 12-month period unless they are a special case as defined below). Guests are not part of the tenant’s household. Guests maintain a home address outside the tenant’s unit.

Live-in caregivers: Persons who provide support services needed because of a household member’s disability or medical condition. They are not considered tenants, visitors or guests.

Occupants: For rent-geared-to-income tenancies, an occupant is a person who is a declared member of a rent-geared-to-income household, who has been added to the household with Toronto Seniors Housing Corporation’s consent, but who has not signed a lease with Toronto Seniors Housing Corporation. For market rent tenancies, an occupant is a person who has been added to a market household, with Toronto Seniors Housing Corporation’s consent, but has not signed the lease, or an undeclared person who is living in a market rent unit together with the tenant.

Occupants have no right to live in the tenant’s unit once the tenant moves out.

Tenants: Persons who have signed a lease and have all tenant rights and responsibilities related to the tenancy[1].

Toronto Seniors Housing Corporation staff: This includes, but is not limited to, all Toronto Seniors Housing Staff.

Unauthorized occupants: Any person who is not a tenant, occupant, visitor, guest, or live-in caregiver as defined by this policy. An unauthorized occupant has no lawful authority to be at a Toronto Seniors Housing Corporation residential complex and has no rights to the rental unit in question.

Visitors: Persons who visit a tenant and do not require temporary accommodation with the tenant (visitors do not sleep in the tenant’s unit). Visitors are not part of the tenant’s household. Visitors maintain a home address outside the tenant’s unit.

Roles and Responsibilities

Toronto Seniors Housing Corporation staff are responsible for:

• investigating cases where tenants appear to have guests staying with them for more than 30 days.

Tenants are responsible for:

• the actions and behaviours of their occupants, visitors and guests;
• telling their guests and visitors that they may be asked to prove that they have a home address outside of the unit they are visiting;
• reporting a person that they wish to add to their household composition as outlined in the Addition to Household Composition Directive; and
• complying with this policy.

Policy Content

Visitors

Visitors may come to the unit as often as the tenant invites them. Frequent visitors may be asked to prove that they have a home address outside of the unit they are visiting. Tenants are responsible for telling all visitors about this rule.

Guests

Tenants may have a guest stay in their unit for a maximum of 30 days in total, within a 12-month period and are encouraged to report to Toronto Seniors Housing Corporation all persons staying in the unit for safety and emergency purposes.

Guest who stays longer than 30 days – special cases

If Toronto Seniors Housing Corporation staff receive information that a person has been staying in a tenant’s unit longer than 30 days, Toronto Seniors Housing Corporation staff will investigate and request documentation from the tenant explaining the reason for the stay and information about how long the person is staying to ensure that the person qualifies as a special case guest.

Special cases where a guest may stay longer than 30 days might include, but are not limited to:

• an accommodation-related issue as defined in Toronto Seniors Housing Corporation’s Human Rights, Harassment and Fair Access Policy – Tenants and the Ontario Human Rights Code, such as the need for someone to provide short-term supportive care to a person with a disability as prescribed by a qualified licensed healthcare professional; or
• the guest lives outside the country and has travel documents to prove their planned return date and leaves on that date.

Additional detail about special cases is provided in the Visitor and Guest Policy Guideline.

Limitations to stays longer than 30 days

In all cases other than the special cases outline above, Toronto Seniors Housing Corporation will decline to allow the person to stay with the tenant.

Toronto Seniors Housing Corporation staff may determine a situation is not a special case and a guest is not allowed to stay longer than 30 days for the following reasons including, but not limited to:

• the tenant does not provide appropriate documentation as outlined in the Visitor and Guest Policy Guideline to explain why the guest needs to stay longer than 30 days;
• the guest does not intend to leave at the end of the agreed-to term;
• staff or tenants have complained about the guest’s behaviour, and Toronto Seniors Housing Corporation is satisfied the complaints are well founded; and
• the guest(s)’ stay would result in non-compliance with Occupancy Standards under the Toronto Municipal Code Property Standard[2].

Any person located in a residential unit who is not a tenant, occupant, visitor, guest, or live-in caregiver as defined by this policy is an unauthorized occupant and has no lawful right to be on the premises.

Unreported stay

If a person remains longer than 30 days in breach of this policy, Toronto Seniors Housing Corporation may pursue any legal rights available to it including, but not limited to:

• possible termination of subsidy if it is a rent-geared-to-income household due to failure to notify the landlord of changes in household composition as required by the Housing Services Act, 2011;
• enforcement of any rights available to Toronto Seniors Housing Corporation under the Trespass to Property Act against the unauthorized occupant; and
• any action against the tenancy available to Toronto Seniors Housing Corporation.

If a rent-geared-to-income household loses their subsidy, they will have to pay the market rent for the unit and will no longer qualify for a rent-geared-to-income subsidy. The tenant has the right to request a review of decisions related to their continued eligibility for rental subsidy.

Rights to unit

If the tenant moves out of the unit, all other persons in the unit must also leave. Any occupant, guest, visitor, live-in caregiver, unauthorized occupant, or anyone else found in the unit after the tenant moves out will be:

• ineligible for receipt of the household’s rent-geared-to-income subsidy; and
• identified as trespassing.

Toronto Seniors Housing Corporation will reclaim the unit.

Market rent households

A market rent tenant:

• may allow a guest to stay in their rental unit. The market rent tenant may not, however, assign or sublet all or any part of the unit[3];
• is required by their lease to report any changes in household composition within 30 days of the change;
• may request to add another tenant to their unit and sign a new lease[4];
• should report all persons living in the unit even if the tenant does not wish to add the proposed person to their lease as a tenant. It is essential for safety and emergency purposes that Toronto Seniors Housing Corporation knows who lives in its units. Occupants do not have any legal rights or entitlements to a tenant’s unit.

Compliance and Monitoring

The Regional Manager, or designate, will monitor compliance with the policy on an ongoing basis by reviewing a random sampling of tenant files.

Frequency of incidents involving unauthorized occupants will be monitored via reports to the fraud and waste hotline and complaints entered into the HoMES system.

Related Legislation, Regulations, and TSHC Policies:

• Housing Services Act, 2011
• Municipal Freedom of Information and Protection of Privacy Act, 1990
• City of Toronto Occupancy Standards
• Ontario Human Rights Code
• Residential Tenancies Act, 2006
• Trespass to Property Act, 1990
• TSHC Addition to Household Composition Directive
• TSHC Human Rights, Harassment and Fair Access Policy – Tenants
• TSHC Evictions for Cause Policy
• TSHC Tenant Charter

Amendments (Revision History):

Initial policy approved by Board of Directors on April 28, 2022, effective June 1, 2022.

Next Scheduled Review Date: 2027

This policy will be reviewed once every five years.

Policy Contact

Manager, Business Operations and Compliance

Appendices

• Visitor and Guest Policy Agreement

[1] In certain circumstances, as defined by the Residential Tenancies Act, the spouse of a tenant may become a tenant when the tenant dies or vacates the unit. This provision does not apply to some or all of Toronto Seniors Housing Corporation’s rental units. Anyone faced with this situation must speak with their Regional Manager.

[2] CHAPTER 629-25, Occupancy Standards, Toronto Municipal Code Property Standard:

“The maximum number of persons living in a habitable room shall not exceed one person for each nine square metres (96.8 sq. ft.) of habitable room floor area.”

“The minimum floor area of a room used by two or more persons for sleeping shall be four square metres (43 sq. ft.) for each person using the room.”

http://www.toronto.ca/legdocs/municode/1184_629.pdf

[3] Toronto Seniors Housing Corporation reserves the right to take any legal action available against a tenant who has illegally sublet or assigned their tenancy, and reserves the right to take legal action in relation to unauthorized occupancy of a rental unit.

[4] Toronto Seniors Housing Corporation reserves the right to refuse to enter into any tenancy in accordance with its normal leasing practices.