Privacy Policy

1. Introduction

Welcome to Manor Payroll. We are a Canadian household staff management company specializing in providing employment, payroll, compliance, and human resources services for domestic staff (including nannies, housekeepers, private chefs, and estate managers) serving high-net-worth families across Canada.

This Privacy Policy explains how Manor Payroll collects, uses, discloses, and protects your personal information. It applies to all clients, employees we manage, prospective employees, and website visitors. We are committed to being transparent about our privacy practices and complying with all applicable Canadian federal and provincial privacy legislation.

If you have any questions about this policy or our privacy practices, please contact our Privacy Officer using the information provided at the end of this document.

2. Information We Collect

Manor Payroll collects different categories of personal information depending on your relationship with us:

Client Information

When you engage Manor Payroll's services, we collect:

• Contact information: name, email address, phone number, residential address, and mailing address
• Financial information: banking details for payroll processing, credit card information for invoicing, and tax identification numbers
• Household information: number of household members, special needs or requirements, preferences for household staff
• Employment history and references for verification purposes

Household Staff Information

For domestic staff managed through Manor Payroll, we collect:

• Identification information: full name, date of birth, home address, phone number, email address
• Employment information: resume, employment history, qualifications, certifications, and references
• Financial information: Social Insurance Number (SIN), banking details for direct deposit payroll, tax forms (T4, ROE)
• Emergency contact information and designated beneficiaries
• Health and safety information: workers' compensation claims, workplace accommodations, emergency medical information
• Criminal background check results (where legally required or requested)

Website Visitors

When you visit our website, we automatically collect:

• Technical information: IP address, browser type, pages visited, time spent on page
• Cookie and analytics data for improving user experience
• Contact form submissions with any information you voluntarily provide

3. How We Use Your Information

Manor Payroll uses personal information for the following purposes:

• Service Delivery: Administering HR and payroll services for household staff on behalf of client families
• Payroll Processing: Calculating wages, processing payments, and maintaining payroll records
• Employment Compliance: Ensuring compliance with provincial Employment Standards Acts, Occupational Health and Safety legislation, and human rights legislation
• Tax and Legal Compliance: Reporting to Canada Revenue Agency (CRA), provincial tax authorities, and other regulatory bodies as required by law
• Workers' Compensation: Managing and reporting to provincial WSIB or equivalent workers' compensation boards
• Communication: Sending service-related updates, invoices, payroll information, tax documents, and policy notifications
• Onboarding: Processing new staff documentation, employment agreements, and setting up payroll records on behalf of the client
• Quality Assurance: Following up on service quality, resolving complaints, and improving our services
• Analytics and Research: Understanding website usage patterns and improving our digital services (anonymized and aggregated data only)

We will not use your information for marketing or promotional purposes without your explicit consent.

4. Consent and Purpose

Under PIPEDA, Manor Payroll collects, uses, and discloses personal information only with meaningful consent and for purposes that a reasonable person would consider appropriate. We rely on the following forms of consent:

• Express Consent: Your explicit written or verbal consent to collect, use, and disclose your personal information for the stated purposes — obtained at or before the time of collection
• Implied Consent: Where the collection, use, or disclosure is reasonably expected as part of the service relationship (for example, processing payroll requires banking information)
• Consent Exemptions: In limited circumstances, PIPEDA permits collection, use, or disclosure without consent — including where required by law, for legal proceedings, or in emergencies. This includes compliance with:
  • Employment Standards Act (and provincial equivalents)
  • Occupational Health and Safety Act
  • Human Rights Code
  • Income Tax Act and provincial tax legislation
  • Canada Pension Plan and Employment Insurance Act
• Regulatory Reporting: Reporting obligations to Canada Revenue Agency, provincial employment authorities, workers' compensation boards, and other regulatory bodies as required by law

5. Accountability and Roles

Under PIPEDA's accountability principle, Manor Payroll is responsible for personal information in its possession or custody, including information transferred to third parties for processing on our behalf:

• Direct Accountability: When collecting personal information about website visitors and for our own business operations, Manor Payroll is directly accountable for how that information is handled and protected under PIPEDA.
• Third-Party Processing: When processing household staff payroll data on behalf of client families (who remain the employer), Manor Payroll acts as a service provider. We process personal information only in accordance with the client's instructions and our service agreement, and we are not permitted to use the data for our own business purposes.
• Contractual Safeguards: Manor Payroll uses contractual means to ensure that any third parties processing information on our behalf provide a comparable level of protection. Clients maintain decision-making authority over how their employees' information is used.

6. Information Sharing

Manor Payroll may share your personal information with the following third parties only as necessary and for the purposes described:

• Tax Authorities: Canada Revenue Agency (CRA) and provincial tax authorities for income tax, GST/HST, and payroll tax reporting
• Employment Authorities: Provincial Employment Standards boards and Human Rights commissions for regulatory compliance and complaints resolution
• Workers' Compensation: Provincial WSIB or equivalent workers' compensation boards for workplace injury claims and reporting
• Payroll Service Providers: Wagepoint (wagepoint.com), our payroll processing platform, which receives employee payroll data to process pay runs, tax remittances, and year-end filings on behalf of our clients (bound by confidentiality agreements)
• Background Check Providers: Certn (certn.co), our background check provider, which processes applicant information when a client requests pre-employment screening
• Insurance Providers: Employer liability and workers' compensation insurers for claims processing
• Financial Institutions: Your banking institution for direct deposit payroll transfers (account number and routing information only)
• Legal and Compliance: Legal counsel, accountants, and auditors when necessary for legal proceedings, financial audits, or regulatory investigations

We do not sell or rent your personal information to marketing companies or other third parties for commercial purposes. All third parties with whom we share information are bound by confidentiality agreements and are required to use your information only for the specific purposes authorized by Manor Payroll.

7. Data Security

Manor Payroll takes the security of your personal information seriously. We have implemented appropriate physical, technological, and organizational safeguards to protect your information against unauthorized access, disclosure, alteration, and destruction:

• Encryption: Sensitive information is encrypted in transit using SSL/TLS protocols and at rest using industry-standard encryption
• Access Controls: Personal information is accessible only to Manor Payroll employees and authorized contractors who require it for their job functions
• Secure Storage: Paper records containing personal information are stored in locked, secure facilities with restricted access
• Password Protection: All electronic systems use strong password requirements and multi-factor authentication where applicable
• Regular Audits: We conduct regular security assessments and penetration testing to identify and address vulnerabilities
• Employee Training: All Manor Payroll staff receive privacy and data security training

While we take reasonable steps to protect your information, no security system is completely impenetrable. We cannot guarantee absolute security, but we are committed to protecting your information to the highest standards reasonably possible.

8. Data Retention

Manor Payroll retains personal information only for as long as necessary to fulfill the purposes for which it was collected, or as required by law:

• Tax and Payroll Records: Retained for a minimum of 7 years in accordance with Canada Revenue Agency requirements
• Employment Records: Retained according to provincial employment standards legislation (typically 2-7 years depending on the province and type of record)
• Workers' Compensation Records: Retained for the duration of the statute of limitations for claims (typically 2 years from incident or longer if a claim is filed)
• Litigation Files: Retained until the conclusion of any legal proceedings plus applicable limitation periods
• Onboarding Records: Retained for 1 year following termination of services
• Website Analytics: Retained for up to 2 years in aggregated and anonymized form

After the retention period expires, we securely destroy personal information through shredding, secure deletion, or other appropriate methods. Notwithstanding the above, we may be required to retain certain information longer if there is an outstanding legal claim or regulatory inquiry.

9. Your Rights Under PIPEDA

Under the Personal Information Protection and Electronic Documents Act (PIPEDA) and equivalent provincial legislation, you have the following rights:

• Right of Access: You have the right to request access to your personal information held by Manor Payroll. We will provide this information within 30 days in a format that is understandable to you
• Right of Correction: You may request correction of inaccurate, incomplete, or outdated personal information
• Right to Withdraw Consent: You may withdraw consent for the collection, use, or disclosure of your personal information (however, this may affect our ability to provide services)
• Right to Know: You have the right to know what personal information we hold about you, how we use it, and to whom we disclose it
• Right to Challenge Compliance: If you believe Manor Payroll is not complying with this Privacy Policy or applicable privacy legislation, you have the right to lodge a complaint

To exercise any of these rights, please submit a written request to our Privacy Officer at the contact information provided below. We will respond to your request within the timeframes specified by law.

10. Cookies & Analytics

Manor Payroll's website uses cookies and analytics tools to improve user experience and gather information about how visitors use our site:

Cookie Categories

We use cookies in the following categories:

• Strictly Necessary Cookies: Essential for website functionality and security. These cookies maintain your session while browsing our website and protect against unauthorized access. They do not require opt-in consent as they are necessary for the website to function properly.
• Analytics/Performance Cookies: We use Google Analytics 4 (GA4) with data stored in Google Cloud to track aggregated website usage patterns, including pages visited, time on site, and referral sources. Google Tag Manager is used to manage these analytics tags. IP anonymization is enabled to protect visitor privacy. For more information about Google's data practices, please review Google's Privacy Policy and install the Google Analytics Opt-out Browser Add-on if you wish to opt out.
• Marketing/Advertising Cookies: We use Meta Pixel (formerly Facebook Pixel) to measure advertising effectiveness and deliver targeted advertising. Meta Pixel collects data about your website visits, actions taken on our site, and uses cookies to track your interactions. This data is shared with Meta Platforms, Inc. for advertising purposes to help us reach relevant audiences and assess campaign performance. You can opt out of Meta Pixel tracking through your Facebook ad preferences or browser settings.
• Functional Cookies: We may use cookies to remember your preferences, language settings, and other functional choices to enhance your experience on our website.

Privacy Statement

Analytics data is collected and stored in anonymized, aggregated form and cannot be used to identify you personally. You can disable cookies through your browser settings, although this may affect the functionality of our website. Users can manage their cookie preferences through their browser settings at any time.

11. Data Breach Notification

Manor Payroll is committed to transparency and timely communication regarding data breaches in accordance with PIPEDA's breach notification requirements:

• Breach Assessment: In the event of a data breach, Manor Payroll will promptly investigate and assess whether the breach poses a real risk of significant harm to affected individuals.
• Notification Timeline: If a breach poses a real risk of significant harm, Manor Payroll will notify affected individuals and the Privacy Commissioner of Canada as soon as feasible after discovery, as required by PIPEDA.
• Notification Content: Breach notifications will include a description of the breach, information about the personal information affected, likely consequences, and measures individuals can take to mitigate the risk.
• Breach Response Plan: Manor Payroll maintains a comprehensive data breach response plan that outlines procedures for containment, investigation, notification, and remediation.
• Client Notification: For breaches involving household staff data, Manor Payroll will promptly notify affected clients so they can inform their employees and take necessary protective measures.

12. Canada's Anti-Spam Legislation (CASL) Compliance

Manor Payroll complies fully with Canada's Anti-Spam Legislation (CASL) and the Compliance Code of the Canadian Marketing Association. In accordance with CASL:

• Express Consent: We only send commercial electronic messages (emails, texts, etc.) to individuals who have provided express or implied consent
• Clear Identification: All commercial messages clearly identify Manor Payroll and provide accurate contact information
• Unsubscribe Mechanism: Every commercial email contains a clear, functional unsubscribe link. You may request to be removed from our mailing list at any time
• No Purchased Lists: We do not send unsolicited commercial emails to purchased or rented contact lists
• Transactional Messages: Service-related messages (invoices, payroll notices, tax documents) are not considered commercial messages under CASL and will be sent regardless of consent preferences, but you can opt out of non-essential communications

If you receive any commercial communication from Manor Payroll that violates CASL, please notify our Privacy Officer immediately.

13. Changes to This Policy

Manor Payroll may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. We will notify you of any material changes by updating the "last updated" date at the top of this policy and, where required by law, by sending you notice via email or other appropriate means.

Your continued use of Manor Payroll's services following notification of changes constitutes your acceptance of the updated Privacy Policy. We encourage you to review this policy periodically to stay informed about how we protect your information.

14. Contact Us

If you have questions about this Privacy Policy, concerns about our privacy practices, or would like to exercise your rights under PIPEDA, please contact our Privacy Officer:

Privacy Commissioner of Canada

If you are not satisfied with Manor Payroll's response to your privacy concern or believe that we are not in compliance with PIPEDA, you have the right to file a complaint with the Privacy Commissioner of Canada:

• Website: www.priv.gc.ca
• Phone: 1-800-282-1376
• Toll-free line: 1-866-999-6779

Thank you for trusting Manor Payroll with your privacy. We are committed to maintaining the highest standards of data protection and transparency in all our operations across Canada.

Disclaimer: Manor Payroll provides fractional HR and payroll processing services. We are not a law firm, accounting firm, or licensed financial advisor. Nothing in this Privacy Policy or on our website constitutes legal, tax, or financial advice. For questions about your legal obligations as an employer, please consult a qualified professional.