Definition of Personal Information
Personal information is information that can identify an individual such as name, home address and telephone number, and includes employee personal information, but does not include the business contact information, or work product information of a McElhanney employee.

Purposes for Collection of Personal Information
McElhanney will collect, use and disclose personal information to:

• establish maintain and terminate the employment relationship with its employees,
• provide products and services to its shareholders and clients, and
• comply with applicable laws such as the Income Tax Act and Employment Standards.

Disclosure of Personal Information to Third Parties
McElhanney considers that personal information disclosed to it, is done with the understanding that this information may be disclosed to third parties such as:

• affiliated companies,
• regulatory authorities,
• benefits providers in accordance with McElhanney’s policies; or
• legal authorities.

Consent
McElhanney will obtain consent for the collection, use or disclosure of an individual’s personal information except in special circumstances such as where it is clearly in the interest of the individual and consent cannot be obtained in a timely way, where necessary for medical treatment and the individual is unable to consent, where consent would compromise an investigation or where otherwise authorized or required by law.

With respect to its employees’ personal information, McElhanney will collect, use and disclose such personal information without consent where reasonable to do so for the purpose of establishing, maintaining or terminating its relationship with employees. McElhanney will, however, notify employees with respect to the purposes for which information will be collected, used or disclosed, such as:

Personal information of employment candidates will be used:

• to assess the suitability of candidates for a particular job or task, and
• to negotiate and make offers of employment to selected applicants.

Personal information for current employees will be used:

• for the supervision, management and remuneration of employees;
• to promote the company’s business interests;
• to establish an employee’s abilities and training /development requirements;
• to record significant events during the employment relationship;
• to monitor use of McElhanney’s facilities and equipment including email and Internet access;
• in connection with illness or injury of an employee that affects their work including workers compensation claims;
• in connection with the administration of benefit plans;
• to maintain a safe workplace; and
• for due diligence review purposes in connection with any merger or acquisition.
Personal information of former employees will be used:
• for any post employment-related activities of McElhanney in respect of an employee, including but not limited to the provision of references; and
• for matters relating to benefit plans and payments.

Withdrawal of Consent
An individual may withdraw consent by contacting McElhanney’s Privacy Officer at the address or telephone number listed unless the withdrawal of consent would frustrate McElhanney’s performance of a legal obligation. At the time the request to withdraw consent is received, McElhanney will advise the individual of any consequences that will result from the withdrawal of consent.

Retention of Personal Information
McElhanney will retain personal information only so long as it is needed to fulfill the purposes for which the personal information was collected, and for a reasonable length of time thereafter as needed to meet any legal or business purposes. If McElhanney uses personal information to make a decision that directly affects an individual, the personal information will be kept for at least one year following the collection and use of such information.

Protection of Personal Information
Whether in electronic or paper-based format, McElhanney will maintain reasonable and appropriate security systems to safeguard personal information in its custody or under its control from unauthorized access, collection, use, disclosure, copying, modification, disposal or similar risks.

McElhanney will use reasonable contractual and other means to ensure that third parties to which McElhanney transfers personal information for the purpose of providing products or services on the company’s behalf or for other purposes protect the confidentiality of the personal information in a manner consistent with McElhanney’s security measures.

Access to Personal Information
A request to access your own personal information must be made in writing to McElhanney’s Privacy Officer at the address or telephone number listed. McElhanney will respond within 30 days to each request subject to any legal restrictions or rights of refusal of McElhanney. Circumstances in which McElhanney has the right or legal obligation to refuse a request for access to personal information include:

• the information is protected by solicitor-client privilege;
• doing so could reasonably be expected to cause immediate or grave harm to the safety or to the physical or mental health of the individual who made the request;
• the disclosure would likely reveal the identity of an individual who has provided personal information about another individual and the individual providing the personal information does not consent to the disclosure of his or her identity; or
• the information would likely reveal personal information about another individual.

McElhanney may charge individuals, other than employees, a reasonable fee for providing access to the personal information.

Keeping Information Accurate
McElhanney will strive to ensure that the personal information it has on file is as accurate and up-to-date as necessary for the purposes for which it will be used. If McElhanney is satisfied on reasonable grounds that a request to correct an error or omission of personal information should be implemented, the personal information will be amended and McElhanney will endeavour to advise other parties having access to this personal information.

Contact Information
Queries or complaints related to this Personal Information Policy or any of McElhanney’s procedures with respect to the privacy of personal information should to be directed to McElhanney’s Privacy Officer at the telephone, email address, or mailing address listed below.

For more information, to file a complaint, or to make enquiries, please contact:

PRIVACY OFFICER
L100-780 Beatty St.
Vancouver, B.C. V6B 2M1
Telephone No.: 604-683-8521
Fax No.: 604-683-4350
Email address:
Internet: www.mcelhanney.com