“Personal Information” means information about an identifiable individual, except Business Contact Information (as such term is defined below), and includes information about prospective, present or former employees and external parties such as landowners. Personal Information includes information in any form, such as:
- age, name, ID numbers, income, ethnicity, religion and social status (marital, family, economic);
- employee evaluations and disciplinary actions, credit records, loan records, medical records and intentions (re: acquiring goods/services, changing jobs);
- transactional history, which may include information about depositories and beneficiaries; and
- information about land or mineral rights in the case of a surface or mineral lease owner.
“Business Contact Information” means an individual’s name, position name or title, business telephone number, business address, business e-mail address, business fax number and other similar business information.
Collection, Use and Disclosure of Personal Information
Where possible, Birchcliff will collect Personal Information directly from the individual. If necessary, Birchcliff may collect Personal Information from another person or entity in reasonable circumstances and when permitted or required by law. Before Birchcliff collects Personal Information, Birchcliff will identify the purpose for which the Personal Information is being collected.
Purpose for Collection, Use and Disclosure
Birchcliff may collect, use and disclose Personal Information for various purposes, including the following:
- to effectively manage, develop and improve its business and operations;
- to establish and maintain an effective relationship with those persons and entities whom Birchcliff interacts, including marketers, suppliers, contractors and potential parties with whom Birchcliff conducts or may conduct business;
- for payroll and benefits/perquisites administration;
- with respect to employees only, to maintain and build our corporate culture, including by posting information on Birchcliff’s intranet and celebrating personal milestones;
- to determine eligibility for employment (or to provide services to Birchcliff);
- to provide notice of, or an effective response to, environmental incidents;
- to communicate effectively with interested individuals, including shareholders; or
- to meet all legal and regulatory requirements.
Birchcliff will obtain express or implied consent of individuals, except where otherwise permitted by law, to collect, use and disclose Personal Information for the reasonable business purposes for which it was collected.
Subject to applicable legal and contractual requirements and upon reasonable notice, any individual may withdraw his or her consent to further collection, use and disclosure of Personal Information by directly contacting Birchcliff’s Privacy Officer, identified below.
Personal Information will be retained only as long as necessary to satisfy the purpose(s) for which it was collected and will be disposed of in a manner that is appropriate to the sensitivity of the Personal Information.
Security of Personal Information
When Birchcliff collects, uses or discloses Personal Information, it will make reasonable efforts to ensure that all information is accurate and complete. It is the responsibility of all Birchcliff Personnel to ensure that his or her Personal Information is kept current.
Birchcliff recognizes its obligation to safeguard Personal Information in its possession. Birchcliff has therefore made reasonable arrangements to secure such information against unauthorized access, collection, use, disclosure, copying, modification or disposal. These arrangements include:
- limiting the access to and uses of Personal Information to those Birchcliff Personnel that reasonably require such Personal Information;
- storing physical files and documents containing Personal Information in locked or secure offices, rooms and/or filing cabinets;
- maintaining technological safeguards, such as passwords or encryption for Personal Information stored electronically; and
- informing all Birchcliff Personnel about the importance of privacy.
From time to time, Birchcliff may use third party vendors to process Personal Information on its behalf, including for information storage, payment processing, human resource administration and similar purposes. In all cases where third parties may be able to access Personal Information, Birchcliff will continue to protect it through confidentiality arrangements with such third parties and will not allow any Personal Information to be removed from Birchcliff’s control.
Requests for Access to Personal Information
Robyn Bourgeois, General Counsel & Corporate Secretary
1000, 600 – 3rd Avenue S.W.
Calgary, Alberta T2P 0G5
If an individual demonstrates the inaccuracy or incompleteness of any Personal Information, Birchcliff will promptly make amendments to the information, as required.
Changes to Policy