Creating a Document Compliance Process

Developing a Document Compliance Process

Condominium corporations are legally required to maintain and manage records in compliance with the Condominium Property Act (CPA), the Condominium Property Regulation (CPA Regulation), and the Real Estate Act (REA) Rules. A document compliance process ensures that records are properly retained, secured, and accessible.

A comprehensive document compliance system should include:

1. A retention schedule based on legislative requirements.

2. Access protocols to ensure authorized individuals can review records.

3. Security measures to protect documents from unauthorized access or loss.

Retention Schedule – CPA and CPA Regulation Requirements

The CPA Regulation specifies the documents that must be retained, including:

To ensure compliance, condominium managers must implement a document retention policy that clearly outlines:

• Where documents are stored (physical and electronic locations).

• Who is responsible for record-keeping.

• When records should be reviewed and archived.

Access Protocols – Ensuring Compliance with CPA

To comply with this requirement, condominium managers should:

• Establish a request process where owners submit written requests.

• Maintain a log of all access requests and responses.

• Ensure timely access to records—corporations must respond within 10 days under CPA Regulation.

• Implement a fee schedule for document copies, ensuring fees do not exceed those set in CPA Regulation.

Security Measures – Protecting Confidential Documents

Condominium managers must ensure that sensitive records are protected from unauthorized access or loss.

A condominium manager must ensure the security of records by maintaining control over who has access to those records and by implementing reasonable safeguards to prevent unauthorized access.

To comply with this requirement, managers should:

• Restrict access to financial and owner records to authorized personnel only.

• Use encryption and password protection for electronic records.

• Maintain physical security for paper records (e.g., locked cabinets, access-controlled rooms).

• Regularly back up digital records to prevent data loss.

Evaluating the Effectiveness of Document Management Systems

To ensure a document compliance process is effective, managers should evaluate:

If deficiencies are found, the condominium corporation must adjust its policies to improve compliance and efficiency.

Creating a Document Compliance Process

To create a structured document compliance process, condominium managers should:

1. Develop a document retention policy aligned with CPA and CPA Regulation requirements.

2. Establish access procedures ensuring compliance with disclosure obligations.

3. Implement security protocols to prevent unauthorized access.

4. Regularly audit records to ensure compliance and accuracy.

5. Train staff and board members on proper record-keeping practices.

Example Scenario:

A condominium manager receives a written request from an owner to review the most recent board meeting minutes.

• The manager must respond within 10 days.

• If the owner requests a copy, the manager may charge a reasonable fee, not exceeding the CPA Regulation limit.

• The manager ensures records are securely stored and only authorized personnel provide access.

Activity: Develop a Document Compliance Plan

Task:

You are managing a condominium corporation and need to create a document compliance process.

• Step 1: Define a retention schedule for board meeting minutes, financial records, and reserve fund studies.

• Step 2: Outline the process for handling document requests, ensuring compliance with CPA and CPR.

• Step 3: List the security measures you will implement to protect confidential records.