At Kootenay Talent + Recruitment, we are committed to providing our clients, candidates, and partners with
exceptional service. As providing this service involves the collection, use and disclosure of some personal
information about our clients, candidates, and partners protecting their personal information is one of our highest
priorities.

We have always respected the privacy of our clients, candidates, and partners and safeguarded their personal
information, and our commitment to protecting personal information as a result of British Columbia’s Personal
Information Protection Act (PIPA) and Canada’s Personal Informaion and Protection of Electronic Data Act (PIPEDA)
is outlined below.

We will inform our clients, candidates, and partners of why and how we collect, use and disclose their personal
information, obtain their consent where required, and only handle their personal information in a manner that a
reasonable person would consider appropriate in the circumstances.

This Personal Information Protection Policy, in compliance with PIPA and PIPEDA, outlines the principles and
practices we will follow in protecting clients, candidates, and partners personal information. Our privacy
commitment includes ensuring the accuracy, confidentiality, and security of our clients, candidates, and partners
personal information and allowing our clients, candidates, and partners to request access to, and correction of,
their personal information.

Scope of this Policy

This Personal Information Protection Policy applies to Kootenay Talent + Recruitment and its subsidiaries.
This policy also applies to any service providers collecting, using or disclosing personal information on behalf of
Kootenay Talent + Recruitment.

Definitions

Personal Information –means information about an identifiable individual, examples of personal informaiton
include; name, age, home address and phone number, social insurance number, income, education, employment
information, career history, reference information. Personal information does not include contact information(described below).

Contact information – means information that would enable an individual to be contacted at a place of business
and includes name, position name or title, business telephone number, business address, business email or
business fax number. Contact information is not covered by this policy or PIPA.

Privacy Officer – means the individual designated responsibility for ensuring that Kootenay Talent + Recruitment
complies with this policy and PIPA.

Policy 1 – Collecting Personal Information

1.1 Unless the purposes for collecting personal information are obvious and the clients, candidates, and partners voluntarily provides his or her personal information for those purposes, we will communicate the purposes for which personal information is being collected, either orally or in writing, before or at the time of collection.

1.2 We will only collect clients, candidates, and partners information that is necessary to fulfill the following purposes:

o To identify and contact clients, candidates, and partners for the purpose of providing services, garnering interest in services or a job, or offering the opportunity to apply for a job.
o To verify identity, work history and accomplishments, reviews, and performance in relation to recommending a candidate for a job or verifying potential clients.
o To identify clients, candidates, and partners preferences.
o To manage an account within our data system.
o To deliver requested services.
o To send out information related to the services the business provides to clients, candidates, and partners.
o To ensure a high standard of service to our clients, candidates, and partners.
o To meet regulatory requirements.

Policy 2 – Consent

2.1 We will obtain clients, candidates, and partners consent to collect, use or disclose personal information (except where, as noted below, we are authorized to do so without consent).

2.2 Consent can be provided orally, in writing, electronically, through an authorized representative or it can be implied where the purpose for collecting using or disclosing the personal information would be considered obvious and the client, candidate, or partner voluntarily provides personal information for that purpose.

2.3 Consent may also be implied where a client, candidate, or partner is given notice and a reasonable opportunity to opt-out of his or her personal information being used for mail-outs or the marketing of new services and the client, candidate, or partner does not opt-out. Consent is also implied when a candidate sends their application for a position or for general purposes.

2.4 Subject to certain exceptions (e.g., the personal information is necessary to provide the service or product, or the withdrawal of consent would frustrate the performance of a legal obligation), clients, candidates, and partners can withhold or withdraw their consent for Kootenay Talent + Recruitment to use their personal information in certain ways. A client, candidate, or partner’s decision to withhold or withdraw their consent to certain uses of personal information may restrict our ability to provide a particular service or product. If so, we will explain the situation to assist the clients, candidates, and partners in making the decision.

2.5 We may collect, use or disclose personal information without the client, candidate, or partners knowledge or consent in the following limited circumstances:

• When the collection, use or disclosure of personal information is permitted or required by law.
• In an emergency that threatens an individual’s life, health, or personal security.
• When the personal information is available from a public source (e.g., a telephone directory).
• When we require legal advice from a lawyer.
• For the purposes of collecting a debt.
• To protect ourselves from fraud.
• To investigate an anticipated breach of an agreement or a contravention of law.
• For other purposes listed under 12, 15, and 18 of PIPA in the unusual and unforeseen circumstance.

Policy 3 – Using and Disclosing Personal Information

3.1 We will only use or disclose clients, candidates, and partners personal information where necessary to fulfill the purposes identified at the time of collection or for a purpose reasonably related to those purposes such as:

• To conduct client, candidate, and partner surveys in order to enhance the provision of our services;
• to contact our clients, candidates, and partners directly about products and services that may be of interest.

3.2 We take our commitment to privacy seriously and we will not use or disclose clients, candidates, and partners personal information for any additional purpose unless we obtain consent to do so.

3.3 We will not sell clients, candidates, and partners lists or personal information to other parties.

Policy 4 – Retaining Personal Information

4.1 If we use clients, candidates, or partners personal information to make a decision that directly affects the clients, candidates, and partners we will retain that personal information for at least one year so that the clients, candidates, and partners has a reasonable opportunity to request access to it.

4.2 Subject to policy 4.1, we will retain clients, candidates, and partners personal information only as long as necessary to fulfill the identified purposes or a legal or business purpose. This includes retaining data for the purpose of continued services.

Policy 5 – Ensuring Accuracy of Personal Information

5.1 We will make reasonable efforts to ensure that clients, candidates, and partners personal information is accurate and complete where it may be used to make a decision about the clients, candidates, and partners or disclosed to another organization.

5.2 Clients, candidates, and partners may request correction to their personal information in order to ensure its accuracy and completeness. A request to correct personal information must be made in writing and provide sufficient detail to identify the personal information and the correction being sought. A request to correct personal information should be forwarded to any staff member or the Privacy Officer.

5.3 If the personal information is demonstrated to be inaccurate or incomplete, we will correct the information as required and send the corrected information to any organization to which we disclosed the personal information in the previous year. If the correction is not made, we will note the clients, candidates, and partners correction request in the file.

Policy 6 – Securing Personal Information

6.1 We are committed to ensuring the security of clients, candidates, and partners personal information in order to protect it from unauthorized access, collection, use, disclosure, copying, modification or disposal or similar risks.

6.2 The following security measures will be followed to ensure that clients, candidates, and partners personal information is appropriately protected:

o Password protected digital files are used in all possible circumstances. The use of user IDs, passwords, encryption, firewalls for digital files are enforced.
o Printed filles containing personal information are avoided. In the case that personal information is stored in print, we use locked filing cabinets and physically secure offices where personal information is held in print.
o Print files containing personal information will be shredded when no longer required.
o Clients receiving candidate information will be responsible for maintaining confidentiality and securing personal information. Kootenay Talent + Recruitment will make every effort to ensure client compliance.
o Restricting employee access to personal information as appropriate.

6.3 We will use appropriate security measures when destroying client, candidate, and partner personal information such as shedding paper files and deleting digital files and folders, along with removing from databases.

6.4 We will continually review and update our security policies and controls as technology changes to ensure ongoing personal information security.

6.5 Our commitment is to work with data management systems that store the information in Canada and are compliant with PIPA and PIPEDA

Policy 7 – Providing clients, candidates, and partners Access to Personal Information

7.1 Clients, candidates, and partners have a right to access their personal information, subject to limited exceptions where disclosure would reveal personal information about another individual without consent.

7.2 A request to access personal information must be made in writing and provide sufficient detail to identify the personal information being sought. A request to access personal information should be forwarded to the Privacy Officer.

7.3 Upon request, we will also tell clients, candidates, and partners how we use their personal information and to whom it has been disclosed if applicable.

7.4 We will make the requested information available within 30 business days, or provide written notice of an extension where additional time is required to fulfill the request.

7.5 A minimal fee may be charged for providing access to personal information. Where a fee may apply, we will inform the clients, candidates, and partners of the cost and request further direction from the clients, candidates, and partners on whether or not we should proceed with the request.

7.6 If a request is refused in full or in part, we will notify the clients, candidates, and partners in writing, providing the reasons for refusal and the recourse available to the clients, candidates, and partners.

Policy 8 – Questions and Complaints: The Role of the Privacy Officer or designated individual

8.1 The Privacy Officer is responsible for ensuring Kootenay Talent + Recruitment compliance with this policy and the Personal Information Protection Act.

8.2 clients, candidates, and partners should direct any complaints, concerns or questions regarding Kootenay Talent + Recruitment compliance in writing to the Privacy Officer. If the Privacy Officer is unable to resolve the concern, the clients, candidates, and partners may also write to the Information and Privacy Commissioner of British Columbia.

Contact information for Kootenay Talent and Recruitment

Privacy Officer:

Mia Gardiner
250-608-1876, mia@wkra.ca
PO Box 83 Winlaw BC V0G 2J0