Introduction

At Doug Nicholson LTD, respecting privacy is an important part of our commitment to our clients and employees. That is why we have developed The Doug Nicholson LTD, Privacy Policy. The Doug Nicholson LTD, Privacy Policy is a statement of principles and guidelines regarding the minimum requirements for the protection of personal information provided by us to their clients and employees. The objective of The Policy is to promote responsible and transparent personal information management practices in a manner consistent with the provisions of the Personal Information Protection and Electronic Documents Act (Canada).

We will continually review our Privacy Policy to make sure that it is relevant and remains current with changing industry standards, technologies and laws.

Summary of Principles

Principle 1 - Accountability

We are responsible for personal information under our control and to be accountable for our compliance with the following principles.

Principle 2 - Identifying Purposes for Collection of Personal Information

We will identify the purposes for which personal information is collected at or before the time the information is collected.

Principle 3 - Obtaining Consent for Collection, Use or Disclosure of Personal Information

The knowledge and consent of a client or employee is required for the collection, use, or disclosure of personal information, except where inappropriate or required by law.

Principle 4 - Limiting Collection of Personal Information

We will limit the collection of personal information to that which is necessary for the purposes identified by us. We will only collect personal information by fair and lawful means.

Principle 5 - Limiting Use, Disclosure, and Retention of Personal Information

We will not use or disclose personal information for purposes other than those for which it was collected, except with the consent of the individual or as required by law.

Principle 6 - Accuracy of Personal Information

We will strive to keep our personal information as accurate, complete, and up to date as is necessary for the purposes for which it is to be used.

Principle 7 - Security Safeguards

We will protect personal information by our implemented security safeguards appropriate to the sensitivity of the information.

Principle 8 - Openness Concerning Policies and Procedures

We will make readily available to clients and employees specific information about our policies and procedures relating to the management of personal information.

Principle 9 – Client and Employee Access to Personal Information

We will inform our client or employee of the existence, use, and disclosure of his or her personal information upon request and shall give the individual access to that information. A client or employee is able to challenge the accuracy and completeness of the information and have it amended as appropriate.

Principle 10 - Challenging Compliance

A client or employee will be able to address a challenge concerning compliance with the above principles to the Office Manager compliance with our Privacy Policy.

Scope and Application

The ten principles that form the basis of our Privacy Policy are interrelated and we will adhere to the ten principles as a whole. Each principle must be read in conjunction with the accompanying commentary. As permitted by the Personal Information Protection and Electronic Documents Act (Canada), the commentary in our Privacy Policy has been drafted to reflect personal information issues specific to Doug Nicholson LTD.

The scope and application of our Privacy Policy are as follows:

• Our Privacy Policy applies to personal information collected, used, or disclosed by Doug Nicholson LTD in the course of commercial activities.
  
  
• Our Privacy Policy applies to the management of personal information in any form, whether oral, electronic or written.



• Our Privacy Policy does not impose any limits on the collection, use or disclosure of the following information by Doug Nicholson LTD
  
  
  (a) an employee’s name, title or business address or telephone number;
  
  (b) information that we collect, use or disclose for journalistic, artistic or literary purposes and do not collect, use or disclose for any other purpose; or
  
  (c) other information about the individual that is publicly available and is specified by regulation pursuant to the Personal Information Protection and Electronic Documents Act (Canada).
  
  
• Our Privacy Policy will not typically apply to information regarding Doug Nicholson LTD corporate clients. However, such information may be protected by other policies and practices or through contractual arrangements.



• The application of our Privacy Policy is subject to the requirements and provisions of the Personal Information Protection and Electronic Documents Act (Canada), the regulations enacted there under, and any other applicable legislation or regulation.

Definitions

Collection: The act of gathering, acquiring, recording, or obtaining personal information from any source, including third parties, by any means.

Consent: Voluntary agreement for the collection, use and disclosure of personal information for defined purposes. Consent can be either express or implied and can be provided directly by the individual or by an authorized representative. Express consent can be given orally, electronically or in writing, but is always unequivocal and does not require any inference on the part of Doug Nicholson LTD. Implied consent is consent that can reasonably be inferred from an individual’s action or inaction.

Client: An individual who purchases or otherwise acquires or uses any of Doug Nicholson LTD products or services or otherwise provides personal information to Doug Nicholson LTD in the course of Doug Nicholson LTD commercial activities.

Disclosure: Making personal information available to a third party.

Employee: An employee of or independent contractor of Doug Nicholson LTD.

Personal information: Information about an identifiable individual, but does not include the name, title, business address or telephone number of an employee of an organization.

Third party: An individual or organization outside of Doug Nicholson LTD

Use: The treatment, handling, and management of personal information by and within Doug Nicholson LTD or by a third party with the knowledge and approval of Doug Nicholson LTD.