The privacy of individuals connected with our business, including our customers, clients, and employees, has always been of great importance to H.B. Fenn and Company Ltd. Our commitment is to respect and protect the privacy and confidentiality of personal and business information that is entrusted to us. No personal, financial or business information is released to a third party without your consent or knowledge.

This policy describes the principles on which H.B. Fenn and Company Ltd. will protect the privacy of personal information. This policy is part of our commitment to ensure that all personal information of individuals in its possession is protected and used in accordance with the law.

Personal Information is any information about an identifiable person, other than the name, title, business address and business telephone number of a person. It includes such things as a person's home address, date of birth, social insurance number, and financial information. With respect to customers, such information is collected primarily in connection with services and products provided by H.B Fenn and Company Ltd. Employees may be asked to provide such information in connection with matters relating to their employment. In all cases, H.B. Fenn is committed to protecting the privacy of individuals and the integrity of their personal information.


Accountability
H.B. Fenn and Company Ltd is responsible for personal information under its control. With respect to personal information that has been transferred to a third party for processing, H.B. Fenn and Company Ltd. will use contractual or other means, to safeguard personal information while it is being handled by a third party.


Consent
H.B. Fenn & Company Ltd. will not collect, use or disclose the personal information of a person without the individual's knowledge and consent, except in certain limited circumstances permitted by law. H.B. Fenn and Company Ltd. will obtain consent, for the use or disclosure of personal information at the time of the collection of the information. Consent may be expressed or implied, given orally, electronically or in writing and provided by an action or inaction. Consent may be given through a legally appointed representative or a legal guardian.

An individual, subject to legal or contractual limitations, may withdraw his or her consent at any time on sufficient notice to H.B. Fenn and Company Ltd. Withdrawal of consent may result in H.B. Fenn and Company Ltd. becoming unable to provide or continue to provide the person with certain services, products or benefits, and the individual will be given notice of the implications of the withdrawal of his or her consent.


Limits on the Collection of Personal Information
The collection of personal information will be limited to that which is necessary for the purposes identified by H.B. Fenn and Company Ltd. At all times, we will collect personal information by fair and lawful means.


Limits on the Use, Disclosure and Retention of Personal Information
Personal information will not be used or disclosed by H.B. Fenn and Company Ltd. for purposes other than those for which it was collected, except with the consent of the individual or as required or permitted by law. Personal information will be retained only as long as reasonably necessary for the fulfillment of those purposes or as required by law.


Safeguarding Personal Information
H.B. Fenn and Company Ltd. will protect personal information by the use of security safeguards appropriate to the sensitivity of the information.

If personal information is disclosed to third parties for the purpose of processing or another administrative purpose, H.B. Fenn and Company Ltd. will make reasonable efforts to ensure that the third party uses safeguards to protect personal information which are comparable to those used by H.B. Fenn and Company Ltd.


Individual Access to Personal Information
With reasonable notice, an individual may review their personal information and request corrections if necessary. We are committed to maintaining accurate information.


Our Responsibilities
Each of our employees is responsible for maintaining the confidentiality of all personal information to which they have access. These individuals are required to sign a confidentiality agreement binding them to this responsibility, which governs their actions, even if they leave or retire from the firm. Employees are required, as a condition of employment, to conform to our policies and procedures for protecting personal information as well as confidential business and financial information. If you have any questions or comments about our firm's policies and procedures regarding your privacy, we ask that you contact our Privacy Officer, Sheila McGuire. More information can be obtained at the federal privacy commissioner's website, www.privcom.gc.ca.