Privacy Policy

At IDC Communications, respecting privacy is an important part of our commitment to our customers and employees. That is why we have developed the IDC Communications Privacy Code. The IDC Communications Privacy Code is a statement of principles and guidelines regarding the minimum requirements for the protection of personal information provided by IDC Communications to its customers and employees. The objective of the IDC Communications Privacy Code is to promote responsible and transparent personal information management practices in a manner consistent with the provisions of the Personal Information Protection and Electronic Documents Act (Canada).

Scope and Application

The ten principles that form the basis of the IDC Communications Privacy Code are interrelated and IDC Communications shall adhere to the ten principles. Each principle must be read in conjunction with the accompanying commentary. As permitted by the Personal Information Protection and Electronic Documents Act (Canada), the commentary in the privacy code has been drafted to reflect personal information issues specific to IDC Communications.

The scope and application of the IDC Communications Privacy Code covers the personal information collected, used, or disclosed by IDC Communications during commercial activities, as well as the management of personal information in any form, whether oral, electronic, or written.

Definitions

Collection: The act of gathering, acquiring, recording, or obtaining personal information from any source, including third parties, by any means.

Consent: Voluntary agreement for the collection, use and disclosure of personal information for defined purposes. Consent can be either express or implied and can be provided directly by the individual or by an authorized representative. Express consent can be given orally, electronically or in writing, but is always unequivocal and does not require any inference on the part of IDC Communications. Implied consent is consent that can reasonably be inferred from an individual’s action or inaction.

Customer: An individual who purchases or otherwise acquires or uses of IDC Communications products or services or otherwise provides personal information while doing business

Disclosure: Making personal information available to a third party.

Employee: An employee of IDC Communications.

Personal information: Information about an identifiable individual, but does not include the name, title, business address or telephone number of an employee of an organization.

Third party: An individual or organization outside of IDC Communications.

Use: The treatment, handling, and management of personal information by and within IDC Communications or by a third party with our knowledge and approval.

The IDC Communications Privacy Code in Detail

Principle 1 - Accountability

IDC Communications is responsible for personal information under its control and shall designate one or more people who are accountable for compliance with the following principles.

1.1 – Responsibility for compliance with the provisions of the IDC Communications Privacy Code rests with the Privacy Officer who can be reached at (204) 258-2600 or via e-mail to [email protected]. Other individuals within IDC Communications may be delegated to act on behalf of the Privacy Officer or to take responsibility for the day-to-day collection and/or processing of personal information.

1.2 – IDC Communications shall make known, upon request, the title of the person or persons designated to oversee compliance of the Privacy Code.

1.3 – IDC Communications is responsible for personal information in its possession or control and shall use contractual or other means to provide a comparable level of protection while information is being processed or used by a third party.

1.4 – IDC Communications shall implement policies and procedures to give effect to the Privacy Code, including:

(a) Implementing procedures to protect personal information and to oversee compliance with Privacy Code.

(b) Implementing procedures to receive and respond to complaints or inquiries.

(d) Developing information materials to explain IDC Communications’ policies and procedures.

Principle 2 - Identifying Purposes for Collection of Personal Information

IDC Communications shall identify the purposes for which personal information is collected at or before the time the information is collected.

2.1 – IDC Communications collects personal information and/or general business information only for the following purposes:

(a) Personal information (Name, Phone number and Postal code) is required for warranty or exchange purposes. Any sales without personal information will be non-refundable and non-exchangeable.

(b) Mobile Device Data for the purpose of backing up and restoring data to new and/or repaired devices.

(c) IDC Communications requires all employees to update their personal information on their payroll processing site prior to the issue of the employees first pay cheque (payworks.ca). All the requested personal information is required by Payworks to process the employee’s payroll. This information is also required by Revenue Canada when processing T4’s for all employees. Some of this information would be considered “sensitive”.

2.2 – IDC Communications shall specify orally, electronically or in writing the identified purposes to the customer or employee at or before the time personal information is collected. Upon request, the persons collecting personal information shall explain these identified purposes or refer the individual to a designated person within IDC Communications who can explain the purposes.

2.3 – When personal information that has been collected is to be used or disclosed for a purpose not previously identified, the new purpose shall be identified prior to use. Unless the new purpose is permitted or required by law, the consent of the customer or employee will be acquired before the information will be used or disclosed for the new purpose.

Principle 3 - Obtaining Consent for Collection, Use or Disclosure of Personal Information

The knowledge and consent of a customer or employee are required for the collection, use, or disclosure of personal information, except where inappropriate. In certain circumstances personal information can be collected, used, or disclosed without the knowledge and consent of the individual.

3.1 – In obtaining consent, IDC Communications shall make reasonable efforts to ensure that a customer or employee is advised of the identified purposes for which personal information will be used or disclosed. IDC Communications shall state the identified purposes in a manner that can be reasonably understood by the customer or employee.

3.2 – Generally, IDC Communications shall seek consent to use and disclose personal information at the same time as it collects the information. However, IDC Communications may seek consent to use and/or disclose personal information after it has been collected, but before it is used and/or disclosed for a new purpose.

3.3 – IDC Communications may require customers to consent to the collection, use and/or disclosure of personal information as a condition of the supply of a product or service only if such collection, use and/or disclosure is required to fulfill the explicitly specified, and legitimate identified purposes.

3.4 – In determining the appropriate form of consent, IDC Communications shall consider the sensitivity of the personal information and the reasonable expectations of its customers and employees.

3.5 – The purchase or use of products and services by a customer, or the acceptance of employment or benefits by an employee, may constitute implied consent for IDC Communications to collect, use and disclose personal information for the identified purposes.

3.6 – A customer or employee may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice. Customers and employees may contact IDC Communications for more information regarding the implications of withdrawing their consent.

3.7 – IDC Communications may collect or use personal information without knowledge or consent if it is clearly in the interests of the individual and consent cannot be obtained in a timely way, such as when the individual is seriously ill or mentally incapacitated.

3.8 – IDC Communications may collect, use, or disclose personal information without knowledge or consent if seeking the consent of the individual might defeat the purpose of collecting, using, or disclosing the information, such as in the investigation of a breach of an agreement or a contravention of a law.

3.9 – IDC Communications may collect, use, or disclose personal information without knowledge or consent in the case of an emergency where the life, health or security of an individual is threatened.

3.10 – IDC Communications may use or disclose personal information without knowledge or consent to a lawyer representing IDC Communications, to collect a debt, to comply with a subpoena, warrant or other court order, or as may be otherwise required or authorized by law.

Principle 4 - Limiting Collection of Personal Information

IDC Communications shall limit the collection of personal information to that which is necessary for the purposes identified. All information shall be collected by fair and lawful means.

4.1 – IDC Communications collects personal information primarily from its customers or employees.

4.2 – IDC Communications may also collect personal information from other sources including previous employers or personal references, or other third parties who represent that they have the right to disclose the information.

Principle 5 - Limiting Use, Disclosure, and Retention of Personal Information

IDC Communications shall not use or disclose personal information for purposes other than those for which it was collected, except with the consent of the individual or as required or permitted by law. IDC Communications shall retain personal information only if necessary for the fulfillment of those purposes.

5.1 – IDC Communications may disclose a customer’s personal information to:

(a) Bell MTS

5.2 – IDC Communications may disclose personal information about its employees to:

(a) Payworks

(b) References, but only with the consent of the employee

5.3 – Only IDC Communications’ employees with a business need-to-know, or whose duties reasonably so require, are granted access to personal information about customers and employees.

5.4 – IDC Communications shall keep personal information only if it remains necessary or relevant for the identified purposes or as required by law. Depending on the circumstances, where personal information has been used to decide about a customer or employee, IDC Communications shall retain, for a period that is reasonably sufficient to allow for access by the customer or employee, either the actual information or the rationale for making the decision.

5.5 – IDC Communications will remove all copies of mobile device data from store terminals at the end of each business day.

5.6 – IDC Communications shall maintain reasonable and systematic controls, schedules and practices for information and records retention and destruction which apply to personal information that is no longer necessary or relevant for the identified purposes or required by law to be retained. Such information shall be destroyed, erased, or made anonymous.

5.7 – When personal information is no longer required, this information will be destroyed with appropriate security measures.

5.8 – Specific personal information will be kept indefinitely to adhere to the lifetime warranty that is available on these repairs.

Principle 6 - Accuracy of Personal Information

Personal information shall be as accurate, complete, and up to date as is necessary for the purposes for which it is to be used.

6.1 – IDC Communications will make reasonable efforts to keep the personal information that is used on an ongoing basis – including information that is disclosed to third parties – accurate and up to date, unless limits to the requirement for accuracy are clearly set out.

6.2 – IDC Communications will generally rely on individual customers to provide updated information, such as changes to customer addresses and other contact information.

6.3 – IDC Communications shall update personal information about its’ customers and employees as necessary to fulfill the identified purposes or upon notification by the individual.

6.4 – IDC Communications shall disclose personal information to these individuals upon request, and after their identity has been verified. The information will be provided within a reasonable timeframe, and at a reasonable cost, if any. If this information will not be provided to the individual, that individual will be informed as to the reasons why the information cannot be disclosed.

Principle 7 - Security Safeguards

IDC Communications shall protect personal information with security safeguards appropriate to the sensitivity of the information.

7.1 – IDC Communications shall protect personal information against such risks as loss or theft, unauthorized access, disclosure, copying, use, modification, or destruction, through appropriate security measures, regardless of the format in which it is held.

7.2 – IDC Communications shall protect personal information disclosed to third parties by contractual agreements stipulating the confidentiality of the information and the purposes for which it is to be used.

7.3 – All of IDC Communications’ employees with access to personal information shall be required to respect the confidentiality of that information.

Principle 8 - Openness Concerning Policies and Procedures

IDC Communications should make readily available to customers and employees’ specific information about its policies and procedures relating to the management of personal information.

8.1 – IDC Communications shall make information about its policies and procedures easy to understand, including:

(a) The title and address of the person or persons accountable for IDC Communications’ compliance with the Privacy Code and to whom inquiries and/or complaints can be forwarded.

(b) The means of gaining access to personal information provided by IDC Communications.

(c) A description of the type of personal information held by IDC Communications, including a general account of its use; and

(d) A description of what personal information is made available to related organizations.

8.2 – IDC Communications shall make available information to help customers and employees exercise control of the collection, use and/or disclosure of their personal information and, where applicable, privacy enhancing services available from IDC Communications.

Principle 9 – Customer and Employee Access to Personal Information

Upon request, IDC Communications shall inform a customer or employee of the existence, use, and disclosure of his or her personal information and shall give the individual access to that information. A customer or employee shall be able to challenge the accuracy and completeness of the information and have it amended as appropriate.

9.1 – Upon request, IDC Communications shall afford its’ customers and employees a reasonable opportunity to review the personal information in the individual’s file. Personal information shall be provided in understandable form within a reasonable time, and at minimal or no cost to the individual.

9.2 – In certain situations, IDC Communications may not be able to provide access to all the personal information that it holds about a customer or employee. For example, IDC Communications may not provide access to information if doing so would likely reveal personal information about a third party or could reasonably be expected to threaten the life or security of another individual. Also, IDC Communications may not provide access to information if disclosure would reveal confidential commercial information, if the information is protected by solicitor-client privilege, if the information was generated during a formal dispute resolution process, or if the information was collected in relation to the investigation of a breach of an agreement or a contravention of the laws of Canada or a province.

9.3 – Upon request, IDC Communications shall provide an account of the use and disclosure of personal information and, where reasonably possible, shall state the source of the information. In providing an account of disclosure, IDC Communications shall provide a list of third parties to which it may have disclosed personal information about the individual when it is not possible to provide an actual list.

9.4 – In order to safeguard personal information, a customer or employee may be required to provide sufficient identification information to permit IDC Communications to account for the existence, use and disclosure of personal information and to authorize access to the individual’s file. Any such information shall be used only for this purpose.

9.5 – IDC Communications shall promptly correct or complete any personal information found to be inaccurate or incomplete. Any unresolved differences as to accuracy or completeness shall be noted in the individual’s file. Where appropriate, IDC Communications shall transmit to third parties having access to the personal information in question any amended information or the existence of any unresolved differences.

9.6 – IDC Communications and employees can obtain information or seek access to their individual files by contacting the IDC Communications Privacy Officer.

Principle 10 - Challenging Compliance

A customer or employee shall be able to address a challenge concerning compliance with the above principles to the designated person or persons accountable for IDC Communications’ compliance with The IDC Communications Privacy Code.

10.1 – IDC Communications shall maintain procedures for addressing and responding to all inquiries or complaints from its customers and employees regarding IDC Communications’ handling of personal information.

10.2 – IDC Communications shall inform its customers and employees about the existence of these procedures as well as the availability of complaint procedures.

10.3 – The person or persons accountable for compliance with the Privacy Code may seek external advice where appropriate before providing a final response to individual complaints.

10.4 – IDC Communications shall investigate all complaints concerning compliance with the Privacy Code. If a complaint is found to be justified, IDC Communications shall take appropriate measures to resolve the complaint including, if necessary, amending its policies and procedures. A customer or employee shall be informed of the outcome of the investigation regarding his or her complaint.

Monitoring and Enforcement

All the employees of IDC Communications are required to abide by the privacy code. IDC Communications will perform both random and scheduled reviews to ensure compliance with the principles of the privacy code. All reviews of the Privacy Code will be documented. If an issue is identified, the Privacy Officer, or delegated individual, will perform continuous monitoring to show improvement or help identify root causes that need to be addressed. If an employee of IDC Communications violates company policy, a system of progressive discipline shall be followed as outlined in the employee policy manual.

How to Contact the IDC Communications Privacy Officer

Where appropriate, individuals may request access and raise concerns or complaints regarding their personal information with IDC Communications.

If an individual files a complaint, IDC Communications will investigate the matter or suspected failure to comply with this notice or IDC Communications Privacy Principles. It is IDC Communications’ practice to respond to the individual within 45 days of receiving the complaint. IDC Communications will take all appropriate action to remedy any such issues. If the matter cannot be settled, IDC Communications agrees to cooperate with the dispute resolution system set forth below. If individuals feel that their complaint was not satisfied, they may file a formal complaint, free of charge, with the Privacy Commissioner of Canada or the Privacy Commissioner in the applicable province Office of the Privacy Commissioner of Canada 30 Victoria Street Gatineau, Quebec K1A 1H3 Phone: 1-800-282- 1376

In Writing: Privacy Officer, IDC Communications Inc., 1385 Niakwa Road East, Winnipeg, MB R2J 3T3

By Phone: 1-800-474-7771

By Fax: 1-800-496-1116

By email: [email protected]