| This policy describes the principles on which Weston and its subsidiaries and divisions will protect the privacy of personal information. Loblaw Companies Limited has implemented its own privacy policy, which is substantially the same as this policy. The policy is based on the Canadian Standards Association Model Code for the Protection of Personal Information. While this document sets out the principles on which Weston’s privacy practices are based, privacy laws will vary from province to province and those laws may also govern Weston’s privacy practices in such province. This policy is part of Weston’s commitment to ensure that all personal information of individuals in its possession is protected and used in accordance with the law. Privacy laws across Canada are evolving, and therefore this policy is subject to change. 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, medical and financial information. With respect to customers, such information is collected primarily in connection with products provided by Weston. Employees may be asked to provide such information to Weston in connection with matters relating to their employment. In all cases, Weston is committed to protecting the privacy of individuals and the integrity of their personal information. 1. Accountability Weston is responsible for personal information under its control, including any personal information disclosed to third parties for handling or administrative purposes. Weston has designated a Privacy Officer who is accountable for Weston’s compliance with this Policy and with privacy legislation. 1.1 While ultimate accountability for Weston’s compliance with the Policy rests with the Privacy Officer and Senior Management of Weston, day-to-day compliance with the Policy is delegated to individuals throughout Weston’s business. 1.2 With respect to personal information that has been transferred to a third party for processing, Weston will use contractual or other means, and may include the examination of such third party’s practices with respect to personal information, to safeguard personal information while it is being processed by a third party. 1.3 Weston has implemented internal guidelines and practices to give effect to this Policy, including:
1.4 Weston has implemented practices to effectively monitor compliance with this policy across its business, including the appointment of a Privacy Officer and regional privacy coordinators and regular privacy compliance reviews. 2. Identifying the Purposes for which Personal Information is Collected The purposes for which personal information is collected will be identified by Weston at or before the time the information is collected, unless such purposes are obvious. 2.1 Weston will ensure that the purposes for which personal information is collected and the way in which the information may be used are clear to the individual. In some cases, the purpose will be clear from the context of the interaction, in other circumstances, a written or verbal explanation may be required. For example, employees are required to give certain personal information that is essential to the employer-employee relationship, such as SIN and banking information for payroll deposits. 3. Consent Weston 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, such as where immediate health of a person is at risk, or in connection with the breach of an agreement or a law. 3.1 Weston will obtain consent, either express or implied, for the use or disclosure of personal information at the time of the collection of the information. In certain circumstances, consent with respect to use or disclosure will be sought after the information has been collected but before use, particularly if Weston wants to use the information for a purpose not previously identified to the individual. 3.2 Weston is committed to obtaining meaningful consent to the collection, use and disclosure of personal information. To achieve this aim, the purposes for which the information will be used, if not obvious, will be explained in such a manner that the individual can reasonably understand how the information will be used or disclosed. 3.3 Weston will not, as a condition of the supply of a product or service, unreasonably require an individual to consent to the collection, use, or disclosure of information beyond what is required in the circumstances. 3.4 The way
in which Weston seeks consent may vary, depending on the circumstances
and the type of information collected. In determining the type
of consent that may be required, Weston will consider the nature
of the information, the use to which the information will be
put, applicable laws and the type of interaction in which the
information is provided. 3.6 An individual, subject to legal or contractual limitations, may withdraw his or her consent at any time on sufficient notice to Weston. Withdrawal of consent may result in Weston 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. 4. Limits on the Collection of Personal Information by Weston The collection of personal information by Weston will be limited to that which is necessary for the purposes identified by Weston. At all times, Weston will collect personal information by fair and lawful means. It is possible that Weston may, with the consent of an individual, collect and use information about that individual from a third party. For instance, credit references may be checked in appropriate circumstances. 5. Limits on the Use,
Disclosure and Retention of Personal Information by Weston 6. Accuracy of Personal Information held by Weston Weston will make reasonable
efforts to ensure that personal information of individuals is
as accurate, complete, and up-to-date as is necessary for the
purposes for which it is to be used. 6.2 Weston will make reasonable efforts to obtain information from individuals in order to update information on hand if required to fulfill the purposes for which the information was collected. Once informed by a person that personal information held by Weston about them is inaccurate, Weston will update the information as soon as possible. 7. Safeguarding Personal Information Weston will protect personal
information by the use of security safeguards appropriate to
the sensitivity of the information. 7.2 The nature of the safeguards used by Weston will vary depending on the sensitivity of the information that has been collected, the amount, distribution, and format of the information, and the method of storage of the information. More sensitive information will be safeguarded by a higher level of protection. 7.3 The methods of protection used by Weston will include:
7.4 Weston will ensure that its employees who are in contact with personal information are trained in the appropriate protection of personal information and that they are aware of the importance of maintaining the confidentiality of personal information. Employees are required to abide by this Policy. 7.5 If personal
information is disclosed to third parties for the purpose of
processing or another administrative purpose, Weston will make
reasonable efforts to ensure that the third party uses safeguards
to protect personal information which are comparable to those
used by Weston. Weston will make available to
individuals information about its policies and practices relating
to the management of personal information. Weston is open about
the policy it has to ensure the protection of personal information.
9. Individual Access to Personal Information Upon the receipt by Weston of a written request, an individual will be informed, within a reasonable time following such request, of the existence, use, and disclosure of his or her personal information and will be given access to that information. In certain limited circumstances, as permitted by law, certain information, such as that collected and held in the context of an investigation of the breach of a law or a contract, will not be disclosed to the individual. Weston has established procedures for an individual to follow in order to access their personal information. 9.1 Subject
to applicable laws, upon receipt of a written request from an
individual, Weston will inform him or her whether or not Weston
holds personal information about the individual and make reasonable
efforts to indicate the source of the information. In addition,
Weston will, upon written request, provide a summary of the
use that has been made or is being made of this information.
9.4 Weston
may charge a reasonable fee to cover its cost of providing the
information, provided that Weston will inform the individual
of the approximate cost of providing the information prior to
doing so and will afford the individual the opportunity to withdraw
his or her request. 10. Complaints and Questions |
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