Policy on the Collection, Use and Disclosure of Personal Information

Our Commitment
P. W. Transportation Ltd. (“PWT”) is dedicated to protecting privacy and safeguarding personal information. This Policy Statement has been prepared to affirm our commitment to maintaining the privacy of our employees, customers, vendors and others, and to provide information on our practices concerning the collection, use and disclosure of personal information.

Our Ten Privacy Principles
As part of PWT’s continued commitment to maintaining the accuracy, confidentiality and security of personal information, we have established Ten Privacy Principles which have been built upon the values set by the Canadian Standards Association’s Model Code for the Protection of Personal Information and Canada’s Personal Information Protection and Electronic Documents Act (“PIPEDA”).

1. Accountability
   PWT is responsible for maintaining and protecting personal information under its control and shall designate an individual or individuals who are accountable for compliance with these principles.
    
2. Identifying Purposes
   The purposes for which personal information is collected shall be identified before or at the time the information is collected.
    
3. Consent
   The knowledge and consent of the individual are required for the collection, use or disclosure of personalinformation, except where the law provides an exemption.
    
4. Limiting Collection
   The personal information PWT collects shall be limited to only that which is necessary for the purposes identified. Personal information shall be collected by fair and lawful means.
    
5. Limiting Use, Disclosure and Retention
   Personal information may only be used or disclosed for the purpose for which it was collected unless the individual has otherwise consented, or when it is required or permitted by law. Personal information shall be retained for the period of time required to fulfill the purpose for which it was collected.
    
6. Accuracy
   Personal information shall be as accurate, complete and current as is necessary for the identified purposes for which it is to be used.
    
7. Safeguarding Information
   Personal information will be protected by security safeguards appropriate to the sensitivity of the information.
    
8. Openness
   PWT will provide information to individuals about our policies and procedures relating to the management of their personal information.
    
9. Individual’s Access
   Upon request, an individual will be informed of the existence, use and disclosure of their personal information and shall be given access to it. Individuals are entitled to challenge the accuracy and completeness of that personal information and request that it be amended, if appropriate.
    
10. Handling Enquiries or Complaints
    Any questions or enquiries concerning compliance with our privacy policies and procedures may be addressed to our Privacy Officer.

What Is Personal Information
Under PIPEDA, personal information is defined as information about an identifiable individual except for certain business contact information. This definition is extremely broad and includes information such as, but not limited to:

1. residential information (home address, phone number and email)
2. age, income, marital status, dependents, religion and ethnic origin
3. social insurance number, drivers license number, credit card number and bank account information
4. employment application forms, resumes, reference letters and transcripts
5. credit and criminal information obtained through security checks
6. employee information such as compensation, evaluations and assessments, management opinions ofemployees and disciplinary action
7. employee assistance program and training program information
8. benefits information
9. other employee information including:
   a. driving records
   b. purchasing records
   c. dental and health records; medical history
   d. drug or alcohol testing
   e. service and performance awards
   f. DNA and fingerprint samples
10. office devices which record entry and exit times and video surveillance
11. photographs
12. internet activity and other computer monitoring
13. leisure activities or hobbies
14. personal preferences of the individual
15. customer information (credit card numbers, residential addresses, phone numbers and email)

Personal information does not include any business contact information that is displayed on a business card such as name, business mailing and email address, phone number and business title.

What Information Is Collected and Why We Collect It
Collecting personal information about you is necessary for PWT to provide business services.
Employees

For our employees, we gather and use personal information for payroll and benefit administration, to comply with legal and regulatory requirements, for recruitment and training purposes, and for employee’s performance and evaluation reviews. The type of employee information we collect includes, but is not limited to:

1. payroll information (name, address, birthdate, SIN, rate of pay, banking information, tax information)
2. benefits information (dependent status, marital status, address, SIN, rate of pay)
3. employment applications and references
4. driver’s license records
5. alcohol and drug testing records
6. body measurements for uniform purposes
7. performance reviews and evaluations
8. service and performance awards
9. incident and accident records
10. attendance records

While the personal information we collect primarily comes directly from our employees, it may also be provided by other third parties, with the employee’s consent (such as employment references, motor vehicle and driver licensing authorities, alcohol and drug testing companies).
Customers
For our customers, we gather and use personal information, provided directly from our customers, for billing purposes, service requirements and marketing. The type of customer information we may collect includes, but is not limited to:

Personal Customers

1. name
2. mailing address
3. email address
4. telephone number
5. credit card information
6. travel preferences
7. customer sales history

Business Customers

1. business name
2. business address
3. business telephone number
4. business contact name, phone number and email address
5. method of payment (may include credit card numbers)
6. service preferences (special equipment or driver)
7. customer sales history
8. credit and payment history

Personal information may also be used for other purposes, subject to obtaining prior consent for such use.

Consent
We collect and use personal information of our employees and customers with their consent. Their consent may be expressed or implied. Expressed consent could be in writing (e.g. a signed consent, email or application form), or verbally in person or over the telephone. We may determine that consent has been implied by the circumstances (e.g. employment application received in the mail from an individual containing personal information).
There are also legal exceptions where we will not require consent or explain the purposes for the collection, use or disclosure of personal information. For example, this exception would apply if there is an emergency that threatens the life, health or security of an individual, or if we must comply with a court order.

Consent to collect, use and disclose personal information may be withdrawn at any time, subject to legal restrictions.

Sharing Personal Information
PWT does not sell customer lists or personal information to others. We are obliged to keep personal information confidential except when authorized by our employees or customers to disclose information, or when required or permitted by law.

In the course of PWT’s daily operations, access to personal, sensitive and confidential information is restricted to authorized employees who have a legitimate business purpose and reason for accessing it. Access is allowed on a “need to know” basis only. All PWT employees are required to abide by the privacy standards we have established.

Unauthorized access to and/or disclosure of personal information by a PWT employee is strictly prohibited. All employees are expected to maintain the confidentiality of personal information at all times and failing to do so will result in appropriate disciplinary measures, which may include dismissal.

How We Safeguard Personal Information
At PWT, we employ physical (locked storage cabinets and rooms), electronic (passwords, encryption, firewalls) and procedural safeguards to maintain systems security and protect all personal information against unauthorized access, disclosure, inappropriate alteration or misuse. All safety and security measures are appropriate to the sensitivity level of the information collected.

All PWT employees are governed by strict standards and policies to ensure that personal information is secure and treated with the utmost care and respect.

Contact Information
Please contact our Privacy Officer to obtain any further information relative to our privacy policies and procedures or if you have any unresolved enquiries or concerns. Our Privacy Officer can be contacted at:

Sandy Lombardo
P. W. TRANSPORTATION LTD.
6999 Ordan Drive
Mississauga, ON
L5T 1K6
(905) 564-6333