Privacy Policy - T1 Fulfillment

1. Statement of Policy
It is the policy of the T1 FULFILLMENT to control the collection, use, and disclosure of personal information in accordance with all requirements set out in the Personal Information Protection and Electronic Documents Act. In certain circumstances personal information may be collected, used, or disclosed without the knowledge and consent of the individual. Exemptions include, but are not limited to personal information gathered for:

Legal, medical, or security reasons.
Detection and prevention of fraud or for law enforcement.
Journalistic, artistic or literary purposes if its use is confined to those purposes.

1.1 Requirements
The following requirements shall be met by T1 FULFILLMENT unless exempted by the Personal Information Protection and Electronic Documents Act.

1. Accountability
T1 FULFILLMENT is responsible for personal information under its control and shall designate a Privacy Coordinator to be accountable for T1 FULFILLMENT’s compliance with the Act.

2. Identifying Purposes
The purposes for which personal information is collected shall be identified by T1 FULFILLMENT at or before the time the information is collected.

3. Consent
The knowledge and consent of the individual are required for the collection, use, or disclosure of personal information.

4. Limiting Collection
The collection of personal information shall be limited to that which is necessary for the purposes identified by T1 FULFILLMENT.

5. Limiting Use, Disclosure and Retention
Personal information shall not be used or disclosed for purposes other than those for which it was collected, except with the consent of the individual or as permitted by law. Personal information shall be retained only as long as necessary for the fulfillment of those purposes.

6. Accuracy
Personal information shall be as accurate, complete, and up-to-date as is necessary for the purposes for which it is to be used.

7. Safeguards
Personal information shall be protected by security safeguards appropriate to the sensitivity of the information.

8. Openness
T1 FULFILLMENT shall make readily available to individuals specific information about its policies and practices relating to the management of personal information.

9. Individual Access
Upon request, an individual shall be informed of the existence, use, and disclosure of his or her personal information and shall be given access to that information. An individual shall be able to challenge the accuracy and completeness of the information and have it amended as appropriate.

10. Challenging Compliance
An individual shall be able to address a challenge concerning compliance with the above principles to the designated individual or individuals accountable for T1 FULFILLMENT’s compliance.

1.2 Responsibility
All T1 FULFILLMENT employees, who collect, maintain and/or use personal information, are responsible for insuring that the collection, use and disclosure of this information is carried out in accordance with this policy and relevant procedures.

The Corporate Secretariat is the department responsible for supervising compliance with the legislation and for initiating procedures, guidelines and schedules that will be developed to effect this policy.

The Privacy Coordinator is accountable for T1 FULFILLMENT’s policies and practices, with respect to the management of personal information, and is the individual to whom complaints and inquiries can be forwarded. 2. Operating Principles

All questions related to the interpretation and application of this policy should be directed to the Privacy Coordinator.

Privacy Standards
T1 FULFILLMENT’s privacy provisions are based on the CSA International’s Model Code for the Protection of Personal Information, recognized as a national standard in 1996. The standard addresses the ways in which organizations collect, use and disclose personal information. It also addresses the rights of individuals to have access to their personal information and to have it corrected if necessary.

The code’s 10 principles are:

Accountability
An organization is responsible for personal information under its control and shall designate an individual or individuals who are accountable for the organization’s compliance with these principles.

Identifying Purposes
The purposes for which personal information is collected shall be identified by the organization at or before the time the information is collected.

Consent
The knowledge and consent of the individual are required for the collection, use or disclosure of personal information, except where inappropriate.

Limiting Collection
The collection of personal information shall be limited to that which is necessary for the purposes identified by the organization. Information shall be collected by fair and lawful means.

Limiting Use, Disclosure, and Retention
Personal information shall not be used or disclosed for purposes other than those for which it was collected, except with the consent of the individual or as required by law. Personal information shall be retained only as long as necessary for the fulfillment of these purposes.

Accuracy
Personal information shall be as accurate, complete, and up-to-date as is necessary for the purposes for which it is to be used.

Safeguards
Personal information shall be protected by security safeguards appropriate to the sensitivity of the information.

Openness
An organization shall make readily available to individuals specific information about its policies and practices relating to the management of personal information.

Individual Access
Upon request, an individual shall be informed of the existence, use and disclosure of his or her personal information and shall be given access to that information. An individual shall be able to challenge the accuracy and completeness of the information and have it amended as appropriate.

Challenging Compliance
An individual shall be able to address a challenge concerning compliance with the above principles to the designated individual or individuals accountable for the organization’s compliance.