PRIVACY POLICY

Policy of Mintz Global Screening and its subsidiaries on privacy

At Mintz, the confidentiality and the protection of personal information are elements which are of extreme importance. Our primary concern is protecting the data and personal information gathered as part of our daily routine. Consequently, we have established a privacy policy in order to govern the actions of the employees of Mintz regarding the gathering, use, retention and disclosure of any personal information under our control. All employees must abide by our commitment to privacy in the handling of the personal information. Our commitment is definitive. We want to offer products and services of quality to support and accentuate the confidence of our clients and our employees. We adhere to the following principles in the treatment of personal information:

Collection, Use and Disclosure of Information

Mintz adheres to the Canadian Standard Association model for Privacy.

Mintz is responsible for personal information under its control and has designated Privacy officers in both our main data centres who are accountable for the organization’s compliance with the following principles:

Accountability – All employees at Mintz are responsible for the data under our control both collectively and individually. We maintain strict policies, ensure each employee receives appropriate training with annual refreshers, and are comminuted to continually improving our systems and storage to maintain a secure network.

Identifying Purposes – we only collect information for the purpose for which it was requested. No information will be collected unless the purpose is clear; that the individual is aware that we will be obtaining the information and that the data is the most up to date and accurate information available.

Consent – Mintz obtains the acknowledgement and consent of the individual when required for the collection, use, or disclosure of personal information; the consent will be clear, understandable and disclose the reason for the data collection.

Limiting the 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 those purposes; which include maintaining files for audit purposes and consumer disclosure as required by law. Our data retention policy is 2 years for paper forms and 7 years for electronic reports;

Accuracy - personal information shall be as accurate, complete and up-to-date as is necessary for the purpose for which it is used (recognizing that information is collected from fallible human sources); an defects or deficiencies in the information shall be investigated and corrected.

Safeguards - personal information shall be protected by security safeguards appropriate to the sensitivity of the information; we shall at all times maintain a secure environment; test and upgrade network security regular and maintain strong data protection policies within a secure business culture.

Openness - an organization shall make readily available to individuals specific information about its policies and practices relating to the management of personal information; our Privacy officers can be contacted at 1 877 359 8130 ext 3772 (English) or ext. 7038 (French).

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 our Privacy Officer at 1 877 359 8130 ext 3772 (English) or ext. 7038 (French).