Introduction

This Privacy Policy explains Brunswick Steel’s personal information gathering and handling practices. It applies to the personal information of customers and suppliers which is held at Brunswick Steel.

Brunswick Steel values the privacy of its customers’ and suppliers’ personal information and will comply with the principles of the Personal Information Protection and Electronic Documents Act (PIPEDA) and any other personal information and data protection laws, which may be applicable.

If you have any questions regarding this Privacy Policy, please contact:

Christine Dockter
Privacy Officer

Brunswick Steel
125 Bismarck Street
Box 6 Group 525 RR5
Winnipeg, MB R2C 2Z2

Ph: (204) 224-1472
Fax: (204) 222-3479
Email: cdockter@brunswicksteel.com

What is Personal Information?

PIPEDA defines personal information as "information about an identifiable individual" that includes any factual or subjective information, recorded or not, in any form. Under PIPEDA personal information does not include the business name and address, positions/titles of individuals, business telephone/fax numbers and e-mail addresses of any employee, i.e. information on a business card.

Purpose of Collection and Use

Brunswick Steel collects and uses personal information in the ordinary course of business. Personal information will be collected only with the individual’s consent and only to fulfill the purposes identified. If the personal information collected by Brunswick Steel will be used for a new purpose, it will also be documented and consent of the individual will be obtained before information can be used for that purpose.

Consent

Brunswick Steel will not disclose an individual’s personal information to anyone or any organization without the individual’s explicit written permission, except when required by law to do so. Brunswick Steel will not, as a condition of the supply of a product or service, require an individual to consent to the collection, use or disclosure of information beyond that required to fulfill the explicitly specified and legitimate purposes. Consent will not be obtained through deception. An individual may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice. Brunswick Steel will inform the individual of the implications of such withdrawal.

Security

Brunswick Steel takes appropriate steps to ensure the security of personally identifiable information in its custody and limits access. Highly sensitive information is stored in locked cabinets and offices with access limited to those persons who legitimately require the information. Use of passwords, appropriate levels of security and encryption govern electronic files.

Accuracy

Brunswick Steel is dedicated to ensuring that personal information is as accurate, complete and up-to-date as is necessary for the purposes for which it is to be used. As long as an individual is a customer or supplier of Brunswick Steel we will periodically verify that our records are accurate.

Right of Access

Upon request, Brunswick Steel will inform an individual whether or not the company holds personal information about the individual. An individual may access their personal information or request a correction of personal information upon written request. Brunswick Steel will provide access within 10 working days of receipt of the request. Individuals may challenge the accuracy and completeness of their personal information and request it be amended as appropriate. Access requests should be made in writing to the Privacy Officer. Under no circumstance shall the official file be removed from the office by the individual, and access to the file shall be given only in the presence of a Manager or the Privacy Officer.

Document Retention

Government regulations and applicable laws require Brunswick Steel to retain certain information for a certain period of time, typically seven years. At the time that an account is closed we will maintain all other information collected, for a period of one year. At the end of the one-year period, all personal information will be destroyed except for the information required to be kept by law.

Challenging Compliance

If you wish to enquire or complain about the Brunswick Steel personal information management practices a written enquiry or complaint should be sent to the attention of the Privacy Officer at the address on page one of this policy. The Privacy Officer will investigate all claims and respond to all written enquiries. If a complaint is found to be justified, Brunswick Steel will take all reasonable steps to amend the applicable privacy policies or procedures.