Privacy

Personal Information Protection Policy

Our Commitment to Privacy

Conroy Ross Partners and Conroy Ross Partners Limited (hereinafter referred to collectively as “CRP”) respects the privacy and confidentiality of your Personal Information used in our business processes, and adheres to the standards and expectations of the privacy legislation in British Columbia, Alberta, Saskatchewan, Ontario and Quebec. CRP also adheres to the requirements of Canada’s Anti-Spam Legislation when contacting you through commercial electronic message (“CEM”). CRP has a privacy policy that explains how CRP collects, uses, discloses, and protects your Personal Information.

This policy also applies to any person(s) providing services on our behalf.

What is Personal Information?

Personal Information is information that may be used to identify you as an individual. This includes: your name, home address, home telephone numbers, age, sex, marital or family status, financial information, educational history, and identification numbers.

As defined under PIPA, Personal Information does not include your business contact information when you are being contacted as a representative of an organization. This information includes: your name, position name or title, business address, business telephone number and business e-mail address.

Consent

If you choose to use our services and/or submit your Personal Information to CRP, then you are providing your consent for CRP to retain your Personal Information, and use it in the conduct of our business activities. This includes both Search and Consulting services.  For purposes of this policy, “Search” refers to Executive and Professional Search, and Interim Management Solutions. For example, if you submit your resume through our website to apply for a search we are conducting for a client, you are providing your consent for us to use your Personal Information in the context of our Search businesses.

You may withdraw your consent to the use and disclosure of your Personal Information at any time, unless it is necessary for us to use your Personal Information to fulfill our legal obligations.  Please contact our Privacy Director if you would like to withdraw your consent.

Collection and Use of Your Personal Information

CRP collects Personal Information for our Search and Consulting business lines, and as an employer described below:

Consulting
CRP may collect Personal Information if it is reasonably necessary for a project.

Search
CRP will collect your Personal Information when you are applying for a search that we are conducting for a client.  This information may be acquired from resumes, cover letters, telephone conversations, interviews, security or criminal checks, and/or academic verifications.

Employment with CRP:
CRP may collect your Personal Information if you are applying for employment within our company.  If hired, more Personal Information will be required for payroll, compensation and benefits, office security and emergency services.

In all cases noted above, after collecting your Personal Information, it may be used by CRP to communicate with you from time to time for reasons such as ensuring the information that we have about you is correct, to communicate with you about opportunities for employment, to provide you with information about CRP and its services, and/or to communicate with you about other appropriate business matters.

Disclosing Personal Information

CRP does not sell Personal Information in any circumstance.

CRP may disclose your Personal Information in the normal course of providing our business services in the following ways:

Consulting
If we disclose any Personal Information about you, it will only be used for project purposes, and with your prior consent.

Search
CRP may disclose your resume or any Personal Information about you to our clients, for the purpose of providing you with a recruiting opportunity, only with your prior consent. This information will only be used to evaluate your suitability for the role, or potentially other opportunities as well.

Employment with CRP:
When you accept employment with CRP, your Personal Information will be disclosed to: third-party insurers, government authorities (including Canada Customs and Revenue Agency and Alberta Health Care), our provider for employee benefits, our payroll administrator, our banks, consultants who advise our company regarding employee benefits and other compensation information or issues, staff responsible for hiring and/or performance management, and to legal counsel if ever required.  Certain Personal Information will be provided to our office building managers for office security and parking security purposes.  Personal Information may also be used for emergency contact information.

In addition, in certain circumstances, CRP may disclose your Personal Information to comply with applicable laws, respond to inquiries or requests from government authorities, or if compelled by legal process.

Protecting Your Personal Information

In the normal course of providing Search and Consulting services, CRP utilizes both its own technology and third-party IT providers.

Where CRP utilizes our own technology, your Personal Information is stored in secure databases on locked servers.  We use technological safeguards such as data encryption for security of information being transferred back and forth between our Calgary, Edmonton and Regina offices, firewall protection and virus protection software, and strong password protection to ensure security, and prevent unauthorized computer access.

Where CRP utilizes third-party IT providers, your Personal Information may be transferred and/or stored on technology not owned by CRP, and that may be located in the Canada, United States or other country.  CRP reviews all-third party IT providers for their security practices, privacy policies and general business reputation. Contractual and other means are used to ensure that the level of protection provided is comparable to the high level of security that CRP provides when we utilize our own technology. You should be aware that where your Personal Information is transferred and/or stored on technology outside of Canada, your information may be accessible to law enforcement and national security authorities of those jurisdictions in certain circumstances.

All CRP employees sign a confidentiality agreement and are educated with respect to handling your Personal Information in a confidential manner.

We protect Personal Information in a manner appropriate to the sensitivity of the information.  We make every reasonable effort to prevent any loss, misuse, disclosure or modification of Personal Information, as well as any unauthorized access to Personal Information.

Retention of Personal Information

CRP retains your Personal Information as described below:

Consulting
CRP will retain your Personal Information only as long as it is required to complete our projects.

Search
We will retain your Personal Information in our confidential database in order to contact you again to discuss future opportunities, unless you specifically request otherwise.

Employment with CRP:
We will retain your Personal Information throughout your employment and for at least seven years after your employment with CRP ends, as required by Canada Customs and Revenue Agency.

Removal/Disposal of Personal Information

We use appropriate security measures, such as professional waste management for the destruction of any hard copy information, to dispose of any Personal Information.  If the information is electronic, then the information is permanently deleted from our server.

Access and Accuracy of Your Personal Information

You may make a request to access your Personal Information by writing to our Privacy Director and providing sufficient information in your request to allow us to identify the information you are seeking.  We will respond to your request within 45 calendar days and a reasonable fee to provide information may apply.  If we need more time, we will provide an explanation and time-frame.  If we refuse your request in whole or in part, we will provide you the reasons for the refusal.  For example, we may not be able to provide information about you from our records if it contains references to other persons or cannot be disclosed for legal reasons.

Please inform our Privacy Director if we need to make any changes to your Personal Information so that it is as accurate as possible.  When necessary the corrections will be made as soon as reasonably possible and we will notify anyone we may have misinformed.

Questions and Complaints

If you have a question or concern about your Personal Information, or want to request access to your Personal Information, please contact:

Diane Wheatley
Privacy Director
Conroy Ross Partners
780-432-5490 ext. 431
dwheatley@conroyross.com

A reasonable fee may be charged to cover the administrative costs of addressing your request.  We will advise you of any fees that may apply before beginning to process your request.  If we are unable to respond to your request for any reason, we will provide you with a written explanation.

Other resources:

Office of the Privacy Commissioner of Canada
Toll-free: 1-800-282-1376
112 Kent Street
Place de Ville
Tower B, 3rd Floor
Ottawa, Ontario
K1A 1H3
www.priv.gc.ca

Access and Privacy Service Alberta
Tel: 1-780-422-2657
Email: foiphelpdesk@gov.ab.ca
3rd Floor, Commerce Place
10155 – 102 Street NW
Edmonton, Alberta
Canada T5J 4L4
www.foip.alberta.ca

Office of the Information and Privacy Commissioner of Saskatchewan 
Tel:  (306) 787-8350
Email:  webmaster@oipc.sk.ca
503 — 1801 Hamilton Street
Regina, Saskatchewan
S4P 4B4
www.oipc.sk.ca

To remove or change your information, please send a request to the email address below.

Diane Wheatley
Conroy Ross Partners
780-432-5490 ext. 431
dwheatley@conroyross.com

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