A. INTRODUCTION

PJ White Hardwoods Ltd. (“PJ White”) is committed to protecting personal information in its possession or control, and ensuring that it is accurate, secure and confidential.

As part of our activities in conducting our business and managing our employees, we will only collect, use or disclose your personal information with the appropriate notice to you or consent in accordance with this Privacy Policy.

This Privacy Policy outlines our commitment to you.

For further information that is not outlined below, please contact us at:

smak@pjwhitehardwoods.com

B. SCOPE

This Privacy Policy applies to personal information about our employees and stakeholders that is collected, used, or disclosed by PJ White, which includes the management of personal information in any form whether oral, electronic or written.

The application of the this Privacy Policy is subject to the requirements and provisions of applicable federal and provincial privacy legislation and any other applicable legislation or regulations.

C. APPLICATION

1. Accountability

PJ White is accountable for personal information in its possession or control. To ensure accountability, we have trained our employees about our policies and practices.

PJ White has designated a Privacy Officer and other individuals who are accountable for PJ White’ compliance with the policy. The Privacy Officer oversees day-to-day collection and processing of personal information to ensure compliance with the policy.

PJ White will seek assurances regarding the privacy of personal information that has been transferred to a third party for use or processing by requiring that those third parties safeguard all personal information in a way that is consistent with PJ White’ practices and as required by law.

PJ White will implement procedures to protect the privacy of personal information with safeguards appropriate to the sensitivity of the information. For example, PJ White will safeguard personal information in its possession or control from loss or theft and from unauthorized access, use, disclosure, copying or modification through appropriate security measures depending on the sensitivity, format and storage of the personal information. As well, PJ White will use care when destroying or disposing of personal information to prevent unauthorized access, use or disclosure of any personal information.

PJ White’ employees with access to personal information are required to respect the confidentiality of such information.

2. Notice and Consent

PJ White will provide notice or obtain consent of its employees and stakeholders regarding the collection, use or disclosure of personal information. PJ White will collect, use or disclose personal information without stakeholder or employee notice or consent only as permitted by law.

PJ White will explain to stakeholders and employees in plain language the purposes for which personal information will be collected, used or disclosed. The purposes may be expressed orally or in writing.

PJ White collects, uses and discloses personal information for a variety of purposes, including the following:

(a) to maintain current employee information as required by government agencies, insurance companies and employee benefit programs.

(b) to establish and maintain relations with clients and customers, including providing further information about PJ White and its services and products through newsletters and other mail-outs;

(c) to develop, enhance, market or provide products and services to clients and customers;

(d) to establish and maintain relations with stakeholders;

(e) to understand employee and stakeholder needs and preferences;

(f) to develop, enhance, market or provide products and services to meet employee and stakeholder needs or expectations;

(g) to manage and develop PJ White’s business and operations, including personnel and employment matters;(h) to meet legal and regulatory requirements; and

(i) such additional purposes that are identified to an individual.

On request, persons collecting personal information will elaborate on the purpose or object for such collection for a file or refer the individual to the designated person within PJ White to do so.

Generally, PJ White will give notice or seek consent to use and/or disclose personal information before or at the same time it collects the information. Personal information will not be used or disclosed for any new purpose without first identifying the new purpose and providing notice to the employee or obtaining the consent of the stakeholder, unless permitted by law. Some examples of collection, use or disclosure of personal information without notice or consent may include circumstances where:

(a) seeking the consent of the individual might defeat the purpose of collecting the information, such as in the investigation of a breach of an agreement or law;

(b) it is clearly in the individual’s best interest and notice or consent cannot be obtained in a timely manner;(c) in the reasonable judgment of PJ White, it appears that there is imminent danger to life or property which could be avoided or minimized by disclosure of the information to a public authority or agent of a public authority; and

(d) it is to a lawyer representing PJ White, to comply with a subpoena, warrant or other court order, or as may be otherwise required or authorized by law.

In determining the appropriate form of notice or consent, PJ White will consider the sensitivity of the personal information and the reasonable expectations of its employees and stakeholders.

3. Limiting Collection, Use, Disclosure, and Retention of Personal Information

PJ White will take reasonable steps to limit the amount and type of personal information it collects uses and discloses. Personal information will be collected by fair and lawful means and in a fashion that is not unreasonably intrusive. PJ WHITE will keep personal information for only as long as necessary for the identified purposes or as required by law.

If personal information has been used to make a decision about a stakeholder or employee, PJ White will keep the personal information for a reasonably sufficient period to allow the stakeholder or employee to have access to it after the decision has been made. PJ White will maintain controls, schedules, practices and procedures for retention and destruction of personal information.

4. Access, Openness and Compliance

PJ White will be open about its policies and procedures used to manage personal information. PJ White will readily make available to employees and stakeholders this policy and information about its practices relating to the management of personal information.

PJ White will make information available to assist employees and stakeholders in understanding the collection, use and disclosure of their personal information. PJ White will also advise if and how an individual can access personal information held by it.

On written request, PJ White will inform you of the personal information it has in its possession and control relating to you. Stakeholders can seek access to their personal information by contacting the Privacy Officer. Employees can seek access to their personal information by contacting their immediate supervisor. Except for employee personal information, PJ White may charge a minimal fee according to the cost required to retrieve and provide the requested information. PJ White may provide an estimate of the fee in advance and in some cases, will require a deposit for all or part of the fee.

Upon request, PJ White will provide an account of the collection, use and disclosure of the personal information. Where reasonably possible, PJ White will identify from whom the personal information was collected, to whom it has been disclosed, and how and when disclosure took place.

In some cases, PJ White may not provide access to personal information that it holds about a stakeholder or employee. Examples of when this may occur are:

(a) when it is likely to reveal personal information about a third party;

(b) where disclosing the personal information could reveal confidential commercial information;

(c) if the personal information is protected by solicitor-client privilege;

(d) where the denial of access is required or authorized by law;

(e) where information relates to existing or anticipated legal proceedings against the employee or stakeholder making the request;

(f) where it is necessary to protect PJ White’ rights and property;(g) where the request is frivolous or vexatious; and

(h) where the information is collected for purposes of an investigation or the information is the result of an arbitration or other formal dispute resolution process.

If PJ White denies an individual’s request for access to personal information, PJ White will advise the individual of the reason for the refusal.

A stakeholder or employee will be able to challenge the accuracy and completeness of the information and in appropriate circumstances, PJ White will amend the information. Any differences as to accuracy or completeness that cannot be resolved will be noted in the individual's file.

An employee or stakeholder may address a challenge concerning compliance with this policy to the Privacy Officer.

PJ White takes any complaint about its privacy practices seriously. PJ White will investigate any complaint and will take all reasonable steps to resolve it.

PJ White will not dismiss, suspend, demote, harass or otherwise disadvantage an employee or stakeholder because the individual, acting in good faith, has invoked or may invoke, the provisions of this policy or any applicable federal or provincial privacy legislation.