Privacy Policy

ClearView’s Commitment to Privacy

ClearView Strategic Partners Inc. (“ClearView”) is committed to controlling the collection, use and disclosure of personal information provided by its clients, end users of the ClearView ethics reporting services (“ClearView Connects™”) and its employees and has adopted this Privacy Code to ensure the accuracy, confidentiality and integrity of such personal information.

Protecting your personal information and respecting your privacy is important to us. As a provider of ethics reporting and advisory services, the collection and use of information, including business contact information and personal information, is fundamental to the day-to-day operations of our business.

Each ClearView employee and third party service provider must abide by our commitment to privacy in the handling of information, including personal information. ClearView is also concerned about the personal information of its employees and representatives.

It is of the utmost importance that we earn the trust of our clients and the trust of all the end users of our services. To earn that trust, we abide by Ten Principles of Privacy as identified below.

Applicability of ClearView’s Privacy Code

ClearView’s Privacy Code informs you of our commitment to, and policy on, privacy. It provides you with information about the steps that we take to ensure that your privacy and the confidentiality of your personal information are protected.

In this Code, “we”, “us” and “our” means ClearView Strategic Partners Inc. (ClearView), which includes the “ClearView Connects™”, “Pulse Surveys” and “general advisory and communications consulting” service offerings. “You” and “your” means a current or former client, prospective client and all end users of ClearView Connects™. An end user is someone who has been granted access by a client to ClearView Connects™ and is able to make a report using ClearView Connects™ (an “End User”).

Our websites may contain links to other websites that are provided and maintained exclusively by third parties. Websites provided and maintained by third parties are not subject to this Privacy Code. Please review the privacy policies on those websites to determine their information handling practices.

What is Personal Information?

Personal information is any piece of information, either factual or subjective, about an identifiable individual.

The Ten Principles of Privacy

Our Privacy Code consists of the following ten key principles:

Accountability

At ClearView, we take our commitment to securing your privacy very seriously. Each employee and representative of ClearView is responsible for the personal information under his or her control. Our employees are informed about the importance of privacy and receive information periodically to update them about our Privacy Code and related policies.

In addition to establishing this Privacy Code, we have appointed a member of our Senior Management Team, Mr. Phil Enright, President & CEO, as ClearView’s Privacy Officer. Mr. Enright is responsible for analyzing all personal information handling practices at ClearView, and ensuring that our privacy policy is up-to-date and in force at all times.

Identifying Purposes

Whenever we collect information about you, we will explain the purpose and how we intend to use the personal information we collect. We will generally do this at the time that we collect personal information, if not before. We will limit the information we collect to what we need for the purpose that we have identified and we will not use your information for any other purpose without first obtaining your consent.

We may ask you for information in order to establish a relationship and serve you. We obtain most of our information about you directly from you. The information we ask for will depend on which service(s) you require from ClearView. For example, we may ask you for information in order to:

• evaluate your needs;
• determine which products or services will meet those needs; and
• administer our service offerings properly.

As an End User of ClearView Connects™ , you may be asked, or you may choose, to provide your name, telephone number and/or email address, or any other personal information in the report you submit. If you do provide such personal information, you consent to it being forwarded to the relevant client organization who is responsible for the lawful handling of such personal information. As an End User of ClearView Connects™, the choice to provide personal information when submitting a report is yours.

Consent

We seek and confirm your consent to collect, use and disclose your personal information at the time of collection or in advance. We will make an effort to use clear, understandable language when we obtain your consent in order to make sure that you understand the nature, purposes and consequences of the collection, use or disclosure of your personal information.

Consent may be expressed in writing or implied, and in some cases, you may provide it verbally, electronically or through your authorized representative, such as your lawyer. Before deciding what form of consent is appropriate, we will consider the requirements of applicable law, the type of personal information we need, the reason for its collection, use or disclosure and the type of client contact that is involved.

Limiting Collection

Information is not collected by or on behalf of ClearView without a specific, limited requirement. We collect information by fair and lawful means.

As an End User, should you access the ClearView Connects™ by telephone, we, or a service provider acting on our behalf, will not see your name on a “call display” feature.

Limiting Use, Disclosure and Retention

The information we request from you is used or disclosed for the purposes, as defined. We will seek your consent before using or disclosing this information for purposes beyond the scope of your original consent unless required or permitted by law.

Under no circumstances do we sell client lists or other personal information to third parties for marketing purposes. ClearView’s policy is to use information only to forward communications necessary or appropriate to the fulfillment of our obligations as a service provider.

There are some unavoidable types of disclosure of your personal information which may occur occasionally as part of ClearView fulfilling its routine obligations and/or conducting its business in the ordinary course. This includes disclosure to, for example, partners, consultants and suppliers to ClearView (also known collectively as “service providers”). Third parties are only provided with the information necessary to perform services on our behalf, such as technology, banking, financial, auditing, accounting, legal and insurance services. In addition, they are required to protect the information in a manner that is consistent with this Privacy Code.

We will retain your information only for the time it is required for the purposes we describe and as permitted by applicable law. Once your personal information is no longer required, it will be destroyed or made anonymous.

Accuracy

We will make reasonable efforts to keep your information accurate and up-to-date, based upon additional information provided by you and to the extent updated information is relevant to the purpose for which it was originally collected. While we will do our best to ensure that the information that we retain is accurate, we rely on individuals to disclose all material information and to inform us of any relevant changes.

We encourage our clients to review and confirm the accuracy of information provided . If you find any errors in this information, we urge you to contact us as soon as possible (by phone, fax, mail, e-mail, or Internet), and we will make the appropriate corrections as soon as possible.

Safeguards: Protecting Your Information

We will protect your information with appropriate safeguards and security measures, such as ClearView’s computer usage and security policies and our information protection policies. Internal audits of our procedures and security measures are conducted regularly to ensure that they are being properly administered and that they remain effective and appropriate.

ClearView maintains personal information in a combination of paper and electronic media. With respect to our business generally, recent paper records concerning client information are stored in files kept onsite at our Toronto head office and in our Burlington, Ontario office.

Access to client information, including personal information, will be authorized only for ClearView’s employees, representatives and service providers who require access in the performance of their duties, to any person granted access by the individual through the consent process and to those otherwise authorized by law.

When providing information to service providers acting on our behalf, we will require such organizations or individuals to abide by our Privacy Code or to have their own code which gives generally equivalent protection. We will give them only the information necessary to perform the services for which they are engaged, and will require that they not store, analyze or use that information for purposes other than to carry out those services.

ClearView’s computer systems, including portions of our websites, are password-secured and constructed in such a way that only authorized individuals can access secure systems and databases, including ClearView Connects™.

If you send us an e-mail message that includes personal information (such as your name included in the “address”), we will use that information to respond to your inquiry. Please remember that e-mail is not necessarily secure against interception. If your communication contains sensitive information (including financial information), you should not send it electronically unless the e-mail is encrypted or your browser indicates that the access to our website is secure.

Openness: Keeping You Informed

ClearView has prepared this plain-language Privacy Code to keep you informed. It is made available to the public, in paper form from the address set out below and in electronic form, on http://clearviewpartners.com/privacy-policy/.

If you have any additional questions or concerns about privacy, we invite you to contact us by phone, fax, mail, e-mail, or our websites, and we will address your concerns to the best of our ability.

Providing Individual Access and Breach Notification

We will give you access to the information that we retain about you within a reasonable time, with a written request, satisfactory identification and proof of entitlement. You also have the right to know:

• how we collected your personal information;
• how we are using it; and
• to whom it may have been disclosed, except where such disclosure was to a governmental body or service provider to ClearView for routine purposes.

We may charge you a nominal fee and if so, we will give you notice in advance of processing your request.

If you find any errors in this information, we urge you to contact us as soon as possible (by phone, fax, mail, e-mail, or our websites), and we will make the appropriate corrections immediately, based on the receipt of satisfactory evidence.

In some cases we may not provide access to personal information within our possession or control. This may occur when:

• providing access would be likely to reveal personal information about a third party or could pose a threat to the security of the third party, and the information cannot be segregated;
• disclosure would reveal confidential commercial information of ClearView;
• it would be too costly, in our determination, to retrieve it;
• the personal information is protected by solicitor-client privilege; or
• the information has been collected during the investigation of a legal matter or cannot be disclosed for other legal reasons, such as a non-disclosure agreement.

If we deny your individual request for access to your personal information, we will advise you in writing of the reason for the refusal and you may then challenge our decision.

It is ClearView’s policy to inform clients in a timely manner in the event of a disclosure of personal information in breach of our policies and agreements. ClearView requires its employees and others to alert ClearView to potential unauthorized disclosures.

Providing Recourse: Respecting and Responding to Your Privacy Concerns

ClearView encourages you to contact us with any questions or concerns you might have about our information protection practices or this Privacy Code. We will investigate and respond to your concerns about any aspect of our handling of your information.

In most cases, an issue is resolved simply by telling us about it and discussing it. You can reach ClearView Client Services by phone at 416-481-1900 (1-866-655-7528 toll free), by e-mail at
clientservice@clearviewpartners.com or by mail at:

ClearView Strategic Partners
Client Services
372 Bay Street, Suite 1902,
Toronto, ON M5H 2W9

If, after contacting ClearView Client Services, you feel that your concerns have not been addressed satisfactorily, please contact the ClearView Chief Privacy Officer at 1-416-481-9167, privacy@clearViewpartners.com or by mail at the above address.

Please be sure to include your name, address, preferred method of communication, the nature of your complaint, and relevant details, including your past communications with us.

Conclusion

We may amend our Privacy Code to reflect changes to our privacy and and information handling practices. In particular, changes to Canadian privacy laws, may cause us to add, modify or remove portions of this Privacy Code. The date of the most recent update will be indicated, below.

June, 2017.