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Privacy Policy

Overview

Kriska Transportation Group Limited (KTG) is committed to respecting the privacy of individuals. We will collect, use and disclose personal information in compliance with the Personal Information Protection and Electronic Documents Act (PIPEDA).

KTG will manage personal information collected from employees, customers, business partners and other individuals in a responsible and business-like manner. We will control the collection and accuracy of personal information, ensure up-to-date inventory of personal information and protect the information collected from unauthorized use or disclosure.

Identifying Purposes KTG collects personal information for the following purposes: To provide an appropriate supply of well-trained employees and contractors for all of its critical functions To comply with all safety and regulatory obligations To recruit and train professionals for all areas of the business To deliver service to its customers For management, labour relations and human resources purposes, including compliance with all regulatory authorities, fact finding boards, investigation of operating irregularities, employee discipline, employee fitness for work, administration of pay, benefits and other related matters To manage equipment, properties and facilities To ensure environmental compliance To perform risk management

For all other purposes necessary to ensure safe, efficient and cost-effective movement of goods within Canada and the United States KTG identifies the purposes for which it collects personal information at or before the time of collection from an individual and collects only that information necessary for the purposes identified. This information is normally collected through the completion of forms or other documents. Collection of information may also be orally or by implied consent.

Consent

Knowledge and consent of the individual is required for the collection, use and disclosure of personal information except where inappropriate and in cases of implied consent for statutorily required purposes. PIPEDA sets out specific conditions under which KTG may collect, use or disclose personal information without the knowledge or consent of the individual.

Consent must be informed. KTG will make reasonable efforts to ensure that individuals are advised of the purposes for which their information is being collected and used. KTG will endeavor to state the purposes for collection in such a manner as to ensure that the individual can reasonably understand the nature, purpose and consequences of the collection, use or disclosure of personal information to which they are consenting.

KTG will not require an individual to consent to the collection, use or disclosure of information beyond that required to fulfill explicitly specified and legitimate purposes. In determining the form of consent, KTG will take into account the sensitivity of the information and the reasonable expectations of the individual.

Depending upon the circumstances and the type of information to be collected, KTG may request consent in a number of ways. KTG will generally seek express consent when the information is considered to be of a sensitive nature and less sensitive information may be collected by implied consent.

Individuals may give consent in a number of ways including:

  • An application form that is used to seek consent, collect information and inform the individual of the use that will be made of that information. By completing and signing the form, the individual gives consent to the collection and the specified uses
  • Oral consent may be given when information is collected over the telephone

An individual may withdraw consent at any time subject to legal and contractual restrictions and with reasonable notice. KTG will inform the individual of the implications of such a withdrawal.

Limiting Collection

The collection of personal information will be limited by KTG to that which is necessary for the purposes it has identified (or such other purposes as required or permitted by applicable law). Information will be collected by lawful and fair means. KTG will not collect personal information in a misleading manner or indiscriminately. KTG will specify the type of information collected as part of its information handling policies and practices.

Limiting Use, Disclosure and Retention

Personal information will not be disclosed or used without the consent of the individual or as required or permitted by applicable law. Personal information will only be held for as long as necessary to fulfill the identified purposes and to comply with various legislative, regulatory and auditing requirements (e.g. Income Tax Act, MOT/DOT regulations, etc.). Personal information that has been used to make a decision about an individual will normally be held for a one year period to allow an individual access following a decision making process.

Personal information will be destroyed or erased after it is no longer required to fulfill identified purposes. KTG has guidelines that govern the destruction of personal information.

Accuracy and Security of Personal Information

Personal information collected will be kept as accurate, complete and up to date as is necessary for the purposes for which it is used. We will not routinely update your personal information, unless such a process is necessary. We expect you, from time to time, to supply us with written updates to your personal information, when required.

  • Safeguards may vary depending on the sensitivity of the information being held.
  • Methods for securing personal information include the following:
  • Physical measures (locked filing cabinets, restricted access to offices)
  • Limiting access on a “need-to-know” basis
  • The use of passwords and/or encryption on files

KTG will ensure that its employees are aware of the importance of maintaining the protection of personal information and will use care in disposing of or destroying personal information collected in order to prevent unauthorized access to the information.

Individual Access

An individual will be informed upon request of the existence, use and disclosure of his/her personal information and will be given access to that information subject to the exclusions set out in the PIPEDA. An individual has the right to correct, or have corrected all erroneous personal information and may have the accuracy and completeness of the information amended as appropriate.

Should an individual seek access of his/her personal information, the individual must address a written request in this regard to the Privacy Officer at indicated below. KTG will respond to an individual’s request for information within a reasonable time and at a minimal cost to the individual. If there is a cost to the individual for access, KTG will provide an estimate and the individual must advise KTG whether he/she is or is not withdrawing the request. KTG will provide the information to the individual in such form as to be readily understandable and will include any explanations of abbreviations or codes. If access to any or all of the information sought cannot be given because of legal, security reasons or other reasons recognized by law, the individual will be so advised.

KTG will amend information when an individual successfully demonstrates the inaccuracy or incompleteness of personal information. The information may require correction, deletion or addition of information.

Accountability

KTG is responsible for the personal information under its control and has designated the Human Resources Manager as its Privacy Officer. The Privacy Officer is accountable for KTG’s compliance with PIPEDA. Any questions or comments regarding this privacy policy or its administration should be forwarded to the Human Resources Manager.

Procedures have been put in place to receive and respond to inquiries or complaints from our employees and independent operators relating to handling personal information. KTG will investigate all complaints and, if the complaint is justified will take appropriate measures including amending its policies and practices if necessary.

Personal information and privacy inquiries should be directed as follows:

In writing:

Privacy Officer
Kriska Transportation Group Limited
P.O. Box 879
Prescott, ON
K0E 1T0

By e-mail: hmewhinney@kriska.com