# EZtoFind.ca — Records Retention Policy **Effective:** February 26, 2026 **Version:** 1.0 **Owner:** Doug LeMaire, REALTOR® (Records Officer) **Brokerage:** Fraser Property Management Realty Services Ltd. **Address:** 1 – 22374 Lougheed Hwy, Maple Ridge, BC V2X 2T5 ## 1. Purpose This policy governs the storage, retention, and secure destruction of all personal information and business records collected via EZtoFind.ca. It is designed to satisfy: - **BCFSA / Real Estate Services Act (RESA) & Rules** — s. 8-2 record-keeping (minimum 7 years for trading services documentation); - **Personal Information Protection Act (PIPA, BC)** — s. 35 (retention only as long as reasonable); - **Canadian Anti-Spam Legislation (CASL)** — CRTC guidance requiring proof of consent for the life of the mailing relationship + audit period; - **CREA DDF® Data License Agreement** — audit trail obligations. ## 2. Record classes & retention periods | Record class | Storage collection | Retention | Rationale | |---|---|---|---| | Trading-services leads (buyer/seller/valuation intake, referral requests) | `leads` | **7 years** from date of collection | BCFSA RESA Rules s. 8-2 | | CASL express-consent log (email + timestamp + IP + policy_version) | `mls_consent_log` | **7 years** from last consent action | CRTC audit requirement + BCFSA | | Saved-search subscriptions + double-opt-in confirmations | `saved_searches` | **Life of subscription + 3 years** after unsubscribe | CASL proof-of-consent + suppression list | | Outbound email records (transactional + commercial) | `email_outbox` | **3 years** from send date | CASL audit | | Doogie AI chat logs | `chat_messages` | **30 days** (TTL index) | PIPA data-minimization; not a trading-services record | | MLS® listing snapshots | `listings` | **Refreshed live from CREA DDF®**; historical snapshots not retained | CREA license terms | | Admin action audit trail (approvals, generation runs) | `admin_audit_log` | **7 years** | BCFSA licensee accountability | | Retention-purge attestation records | `retention_purge_log` | **7 years** | Proof of destruction | ## 3. Secure destruction When a record reaches the end of its retention period: - A daily background job (`retention_purger`) permanently deletes the document from our production database (no soft-delete or shadow copy); - A hashed digest of the destruction event (record class + count + timestamp) is written to `retention_purge_log` so BCFSA/CRTC/OIPC auditors can verify the destruction happened, without the destroyed personal data being retained. ## 4. Access, correction, and DSAR Any individual may request: - Access to their personal information held by EZtoFind.ca (PIPA s. 23); - Correction of factual errors (PIPA s. 24); - Withdrawal of consent and deletion (PIPA s. 9); - Proof of destruction of their record after retention period ends. Requests should be sent to **info@eztofind.ca** with the subject line "DSAR" and will be responded to within 30 business days as required by PIPA. ## 5. Breach notification Any suspected or confirmed unauthorized access, use, or disclosure of personal information will be reported to: - The Office of the Information and Privacy Commissioner for BC (OIPC) where required by PIPA s. 34.1; - Affected individuals without unreasonable delay; - Doug LeMaire, REALTOR® as the designated Records Officer. ## 6. Amendments This policy is reviewed annually. The current version is published at <https://eztofind.ca/legal/retention> and is superseded only by a versioned successor with a new "Effective" date at the top of the file. --- **Signed:** Doug LeMaire, REALTOR® — Records Officer **Date:** February 26, 2026