Privacy Policy

StratHR Solutions Inc. is committed to protecting and safeguarding the privacy of individuals in  all aspects of our business operations. Keeping personal information in strict confidence is a  cornerstone of our business. StratHR Solutions has implemented a Privacy Policy to comply  with the Personal Information Protection & Electronic Documents Act (PIPEDA) that came into effect on January 1, 2004, as well as other applicable legislation that may apply in other  provinces. The Privacy Policy sets out the principles and guidelines that StratHR Solutions has  adopted for the management of personal information of its clients (corporations, organizations  and individuals purchasing services from StratHR Solutions), clients (individuals utilizing  career transition from StratHR Solutions) employees and contractors of StratHR Solutions Inc. The Privacy Policy is based on the principles of the Canadian Standards Association Model Code  for the Protection of Personal Information (the “Privacy Principles”). Personal information is defined as information about an identifiable individual. The personal  information that StratHR Solutions may utilize includes: For Clients – personal information may include information about their current employees  (position, compensation, performance rating, length of service, employment history, career  plans, assessment results or training), their former employees (use of our services), purchase  orders, invoices or any records of dealings with us. This information is used to manage the  business relationship with the Client and to allow StratHR Solutions to complete assignments  on behalf of the Client. For Candidates – this may include contact information, services provided, records of consultant  meetings, resume information, employment preferences, job search plans, references or  assessment results. For career transition candidates, this information is used to help the  candidate to plan and execute an effective job search.  For Employees and Contractors of StratHR Solutions Inc., this may include contact information,  performance evaluations, employment history, employment arrangements, benefit plan  participation, career plans and assessment results. Personal information does not include information that is publicly available, such as person´s  name, address, telephone number and electronic address, when listed in a directory or made  available through directory assistance or other similar sources or that is the name, title or  business address or telephone number of an employee of an organization. 1. Accountability: StratHR Solutions is responsible for all client, candidate and employee personal information in  its possession and under its control. StratHR Solutions has designated a Privacy Officer to  oversee the organization’s compliance with its Privacy Policy and applicable privacy legislation.  There are other individuals within StratHR Solutions Inc. who are designated with the  responsibility for day-to-day collection and management of client, candidate and employee  personal information. StratHR Solutions has established policies and procedures to implement and comply with its  Privacy Policy, including internal guidelines and procedures relating to the collection, handling,  storage and destruction of personal information. StratHR Solutions staff has been provided the  education and training to protect personal information and how to deal with complaints on  privacy issues. StratHR Solutions is responsible for any personal information transferred to third parties for  service or processing on its behalf. StratHR Solutions uses contractual means to provide an  appropriate level of protection for such transferred information. Parties entering into a business  relationship with StratHR Solutions Inc. may be required to sign a non-disclosure agreement to  protect the confidentiality of information disclosed to such parties during the term and after the  termination or expiry of such agreement. StratHR Solutions may examine the policies and  procedures of any third-party practices with respect to personal information to safeguard the  personal information while it is being handled by a third party. 2. Identifying the purposes for collection of personal information: The purposes for which personal information is collected will be identified by StratHR Solutions at or before the time the information is collected, unless such purposes are obvious. StratHR Solutions will ensure that the purposes for which personal information is collected and  the way in which the information may be used are clear to the individual. In some cases, the  purpose will be clear from the context of the interaction, in other circumstances, a written or  verbal explanation may be required. Generally, StratHR Solutions Inc. collects personal information only for the following purposes: • to establish and maintain responsible commercial relations with clients and to provide  ongoing service and offers; • to understand clients and candidates’ needs; • to develop, enhance, market or provide products and services; • to manage and develop StratHR Solutions business and operations, including personnel  and employment matters;  • to meet legal and regulatory requirements including requirements or requests of  government agencies or pursuant to a subpoena or other legal proceedings. The Privacy Policy places no limits on the collection, use or disclosure of information that is  publicly available, such as person’s name, address, telephone number and electronic address,  when listed in a directory or made available through directory assistance or other similar source  or that is the name, title or business address or telephone number of an employee of an  organization. StratHR Solutions’s clients may obtain and, in some cases may require, personal information  pertaining to StratHR Solutions employee. Such information may be obtained and or used for  the purposes of business and employment communications, facility and equipment  management, video monitoring, accommodation management, travel or transportation  management, health, safety and security management, social communications and expense and  invoice payment processing. In the event that client, candidate, contractor or employee personal information is required to  be used or disclosed for a purpose that is not listed above and in respect of which the client,  candidate, contractor or employee has not previously granted his or her consent, the personal  information will not be used or disclosed without first identifying the new purpose and  obtaining consent. 3. Obtaining consent: StratHR Solutions will not collect, use or disclose the personal information of a person without  the individual’s knowledge and consent, except in certain limited circumstances permitted by  law, such as where immediate health of a person is at risk, or in connection with the breach of an  agreement or a law. The knowledge and consent of the individual are required for the collection, use or disclosure of  personal information, except where noted below. The consent may be expressed, implied, or given through an authorized representative. In  determining the appropriate form of consent, the sensitivity of the information and reasonable  expectations of the individual is taken into account. Implied consent is generally appropriate  when the information is less sensitive. Any consent, including any implied consent, will apply to  information already in the possession of StratHR Solutions as of the date of the consent. StratHR Solutions makes reasonable efforts to inform its clients, candidates, contractors and  employees how any personal information collected will be used and disclosed. To achieve this  aim, the purposes for which the information will be used, if not obvious, will be explained in  such a manner that the individual can reasonably understand how the information will be used  or disclosed. Generally, consent to use and disclose personal information is sought at the same time it is  collected. In certain circumstances, however, StratHR Solutions may identify a new purpose and  seek consent to use and disclose the personal information after it has been collected. An individual can withdraw consent to use personal information at any time, subject to any legal  or contractual restrictions and reasonable notice. StratHR Solutions will inform individuals of  the implications, if any, of withdrawing consent and how to do so. Exceptions for collection, use and disclosure without consent Personal information may be collected without the knowledge or consent of the individual if: • the collection is clearly in the interests of the individual and consent cannot be obtained  in a timely way; • it is reasonable to expect that the collection with the knowledge or consent of the  individual would compromise the availability or the accuracy of the information and the  collection is reasonable for purposes related to investigating a breach of an agreement or  a contravention of the laws of Canada or a province;  • the information is publicly available and is specified by the regulations. Personal Information may be used without the knowledge or consent of the individual if: • in the course of its activities, StratHR Solutions becomes aware of information that it has  reasonable grounds to believe could be useful in the investigation of a contravention of  the laws of Canada, a province or a foreign jurisdiction that has been, is being or is about  to be committed, and the information is used for the purpose of investigating that  contravention; • it is used for the purpose of acting in respect of an emergency that threatens the life,  health or security of an individual; • it is used for statistical, or scholarly study of research purposes that cannot be achieved  without using the information, the information is used in a manner that will ensure its  confidentiality, it is impracticable to obtain consent and StratHR Solutions informs the  Privacy Commissioner of the use before the information is used; • it is publicly available and is specified by the regulations;  • it was collected under paragraph (a)(i) or (ii) above. Personal information may be disclosed without the knowledge or consent of the individual if the  disclosure is: • made to, in the Province of Quebec, an advocate or notary or, in any other province, a  barrister or solicitor who is representing the organization; • for the purpose of collecting a debt owed by the individual to StratHR Solutions Inc.; • required to comply with a subpoena or warrant issued or an order made by a court,  person or body with jurisdiction to compel the production of information, or to comply  with rules of court relating to the production of records; • made to a government institution or part of a government institution or an investigative  body that has made a request for the information and identified its lawful authority to  obtain the information. • made to a person who needs the information because of an emergency that threatens the  life, health or security of an individual and, if the individual whom the information is  about is alive, the organization informs that individual in writing without delay of the  disclosure; • of information that is publicly available and is specified by the regulations; • made by an investigative body and the disclosure is reasonable for purposes related to  investigating a breach of an agreement or a contravention of the laws of Canada or a  province; or • required by law. 4. Limiting collection of personal information: StratHR Solutions will collect only the amount and type of personal information needed for the  purposes it has identified. Personal information is collected by fair and lawful means. Although, StratHR Solutions will collect personal information primarily from clients,  candidates, contractors and employees, it may also collect personal information from other  sources such as credit bureaus, or other third parties who represent that they have the right to  disclose the information. 5. Limiting use, disclosure and retention of personal information: The personal information that StratHR Solutions collects is used or disclosed only for the  purposes specified above or for which it was collected, unless the individual gives consent or as  required by law. StratHR Solutions may disclose personal information without consent when it  is required to do so by law, e.g. subpoenas, search warrants, other court and government orders,  or demands from other parties who have a legal right to personal information, or to protect the  security and integrity of its network or system. In such circumstances, the interests of the  individual are protected by ensuring that: orders or demands appear to comply with the laws under which they were issued; and StratHR Solutions discloses only the personal information that is legally required, and nothing  more. The client, candidate, contractor or employee may be notified that an order requiring disclosure  has been received, if the law allows it. StratHR Solutions may disclose Information to: • any person who, in its reasonable judgment, is seeking the Information as the agent of  the customer, client or employee concerned; • a person involved directly or indirectly in supplying the product or service to a customer,  client or employee, including, without limitation, our sales and marketing agents, our  administration team for invoice printing and mailing, our employee benefits and pension  providers, and provided that such person is required to keep the Information  confidential; • a person retained by StratHR Solutions to collect amounts which are owed to it or to  enforce StratHR Solutions’ rights under its terms and conditions, if the Information is  required for, and is to be used only for that purpose and that person is required to keep  such Information confidential. StratHR Solutions may share Information with potential business contractors of, or potential  investors in StratHR Inc. StratHR Solutions may provide Information, including client information, as security for an  investment in StratHR Solutions Inc. StratHR Solutions may provide information, including  client information, to third parties who purchase assets from StratHR Solutions where such  information is relevant to the assets so sold. Only employees with a business need-to-know, or whose duties so require, are granted access to  client, candidate, contractor and employee personal information. StratHR Solutions will retain personal information only as long as necessary to fulfill the  identified purposes. Depending on the circumstances, personal information used to make a  decision about a client, candidate, contractor or employee is kept long enough to allow the client or employee access to the information after the decision has been made. StratHR Solutions has established reasonable guidelines and procedures for information and  records retention, and any personal information no longer needed for its identified purposes or  for legal requirements will be destroyed, erased or made anonymous within a reasonable period  of time. 6. Ensuring accuracy of personal information: StratHR Solutions will make reasonable efforts to ensure that personal information of  individuals is as accurate, complete, and up-to-date as is necessary for the purposes for which it  is to be used. Personal information will not be updated without the consent of the individual and it will only  be updated if it is necessary for the continued use of the personal information. StratHR Solutions will make reasonable efforts to obtain information from individuals in order  to update information on hand if required to fulfill the purposes for which the information was  collected. Once informed by a person that personal information held by StratHR Solutions about  them is inaccurate, StratHR Solutions will update the information as soon as possible. 7. Safeguarding personal information: StratHR Solutions will protect personal information with safeguards appropriate to the  sensitivity of the information. StratHR Solutions has implemented appropriate safeguards to  protect personal information against such risks as loss or theft, unauthorized access, disclosure,  copying, use, modification or destruction. StratHR Solutions’ employees and contractors are made aware of the need to maintain the  confidentiality of all personal information. The methods of protection used by StratHR Solutions will include: • physical measures, for example, locked filing cabinets and restricted access to offices; • organizational measures, for example, limiting access on a “need-to-know” basis; and • technological measures, for example, the use of passwords and encryption. 7.3 StratHR Solutions will ensure that its employees or contractors, who are in contact with  personal information are trained in the appropriate protection of personal information and that  they are aware of the importance of maintaining the confidentiality of personal information.  Employees and contractors are required to abide by this Privacy Policy. 8. Making information about policies and procedures available to clients,  candidates, contractors and employees: StratHR Solutions’policies and practices for the protection of personal information are made  available to clients, candidates, contractors, employees and the general public. StratHR  Solutions’Privacy Policy is posted on the StratHR Solutions website and informs individuals  about the type of personal information it collects, what it is used for and to whom the  information is disclosed. 9. Providing access to personal information: When clients, candidates, contractors or employees request it, StratHR Solutions will disclose to  them what personal information StratHR Solutions has about the client, candidate, contractor or employee, what it is being used for, and to whom it has been disclosed, and will give them  reasonable access to their information. StratHR Solutions will provide a list of the third parties  to which it may have disclosed the personal information when it is not possible to provide an  actual list. Wrong or incomplete information will be amended and the amended information  transmitted to third parties where appropriate. Any dispute over amending a file will be  recorded and details of disputed data provided to third parties where appropriate. However, in certain situations, StratHR Solutions may not be able to give candidates,  contractors or employees access to all personal information it holds about the client, candidate,  contractor or employee. This may, for example, be the case when the information is  unreasonably costly to provide, the information contains references to other individuals, the  information cannot be disclosed for legal, security or commercial proprietary reasons or the  information is subject to solicitor-client or litigation privilege. StratHR Solutions will explain the  reasons for denying access in writing, and the recourse available to the client, candidate,  contractor or employee. StratHR Solutions will make reasonable efforts to respond to an individual’s request for access  to his or her personal information no later than 30 days after receipt of the written request, and  at minimal or no cost. The individual will be informed of any extensions to the time limit and his  or her right to complain to the Privacy Commissioner. StratHR Solutions may not provide access to personal information to an individual if doing so  would likely reveal personal information about a third party, unless: • the information about the third-party can be severed from the record containing the  information about the individual, in which case it will be severed prior to providing the  access; • the third-party consents to the access; or • the individual needs the information because an individual’s life, health or security is  threatened. Access to personal information will not be given if: a) the information is protected by solicitor-client privilege; b) to do so would reveal confidential commercial information; • to do so could reasonably be expected to threaten the life or security of another  individual; or • the information was generated in the course of a formal dispute resolution process. • A customer or client can obtain information or seek access to his or her personal  information by contacting a StratHR Solutions representative at the StratHR Solutions Inc. office. • An employee can obtain information or seek access to his or her individual personal file  by contacting the StratHR Solutions Privacy Officer. 10. Handling complaints and questions: Clients, candidates, contractors or employees may challenge StratHR Solutions compliance with  its Privacy Policy. StratHR Solutions has implemented an internal escalation policy to deal with  the receipt, investigation and responses to complaints and questions regarding privacy issues. All complaints and questions will be responded to in a timely manner under the circumstances.  All complaints will be investigated and appropriate measures taken to correct deficient policies  and practices. Clients, candidates, contractors or employees have the right to contact the Privacy  Commissioner in the event of any dispute. Any complaints or concerns regarding personal information and this Privacy Policy may be  addressed to StratHR Solutions: StratHR Solutions Inc. 7th floor 177 Lombard Ave, Winnipeg, MB R3B 0W5  Phone: 204-221-975