Privacy Code

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 and end users of ClearView's ethics reporting services ("ClearView Connects™") 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.

Each ClearView employee, representative and third party service provider must abide by our commitment to privacy in the handling of information, including personal information.

It is of the utmost importance that we earn the trust of our clients and 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 is our policy on privacy and it informs you of our commitment to 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.

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.

IF YOU ARE AN END USER 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™.

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. Please refer to the applicable privacy and other policies of the relevant organization for further information.
• If you include personal information about another person in the report you submit, you consent to it being forwarded to the relevant client organization who is responsible for the lawful handling of such personal information. Please refer to the applicable privacy and other policies of the relevant organization for further information.
• If you choose to submit your email address to ClearView in order to receive email notifications when your report has been updated, ClearView will:
  • Securely store your email address and will not pass it on to the client organization.
  • Only use your email address to notify you of activity relating to your report.
  • Delete your email address when the report is closed, you turn off the email notifications, or you haven't logged into clearviewconnects.com for 90 days. You will be notified when we delete your email address.
• If you choose to submit your email address to ClearView in order to receive email notifications when your report has been updated:
  • You can turn email notifications on and off at any time by logging into clearview.connects.com and changing your email notification settings.
  • Email notifications will only remind you to log into clearviewconnects.com and will not contain any report information.

If you are not an End-User of ClearView Connects™, and you believe that a client organization has received your personal information through a report that has been submitted, please contact the relevant client organization directly as they are responsible for the lawful handling of such personal information.

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 and representatives 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 for 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 ("Identified Purposes"). 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.

If you make an inquiry through our website, send us an e-mail message or otherwise that includes personal information, we will use that information to respond to your inquiry.

If you are a client or prospective client, we may ask you for information in order to establish a relationship and serve you. The information we ask for will depend on which services you require from ClearView. For example, we may ask you for information in order to:

• Evaluate your needs;
• Determine which services will meet those needs; and
• Administer our service offerings properly.

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. Before deciding what form of consent is appropriate, we will consider the requirements of applicable law, the type of personal information we need and the reason for its collection, use or disclosure.

Limiting Collection

We only collect personal information that we determine we need for the identified purposes. We collect information by fair and lawful means.

Limiting Use, Disclosure and Retention

The information we request from you is used or disclosed for the identified purposes. 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 personal information to third parties for marketing purposes. ClearView's policy is to use information only to fulfill our obligations to provide services.

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, consultants and suppliers to ClearView (also known collectively as "service providers"). Service providers 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 identified and as permitted by applicable law. Once your personal information is no longer required, it will be destroyed or made anonymous.

Accuracy

If you are a client or prospective client, 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 you to disclose all material information and to inform us of any relevant changes.

We encourage you 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, mail, e-mail, or our websites), 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. 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™. 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.

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 our website, at https://www.clearviewconnects.com/documents/PrivacyPolicy.

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

Providing Individual Access and Breach Notification

If you are a client or prospective client:

• 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 for responding such a request 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, 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:

• the personal information was collected in ClearView Connects™, and we have agreed with a client or end user that we will not disclose such information or pursuant to our service terms the relevant client organization is responsible for the lawful handling of such personal information or as provided for in this Code;
• 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 an 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 you in a timely manner in the event of a disclosure of personal information in breach of our policies and agreements. ClearView requires its employees, representatives 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
CANADA

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 information handling practices. In particular, changes to applicable 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.

ClearView Connects™ is a registered trademark of ClearView Strategic Partners Inc.

Last updated August 1, 2020