Calloway REIT
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Privacy Policy

The Trust has a practice of protecting the privacy and security of its customers, suppliers and associates' records. We are committed to meeting our obligations under the Canadian privacy laws including the PIPEDA ( Personal Information Protection and Electronic Documents Act ).

The purpose of this policy is to establish and maintain the basis upon which personal information regarding associates, customers, suppliers, vendors of the Trust will be collected, used, disclosed, retained and destroyed.
This policy applies to all associates, customers, suppliers and vendors of the Trust. Personal information includes any factual or subjective information, recorded or not, about an identifiable individual. It does not include information normally found on business cards, such as name, employer, title, business address, and business telephone or fax number, nor information that is publicly available.

The Privacy Officer will have overall responsibility for this policy and is designated to oversee compliance.
The Trust is committed to the privacy rights of its associates/customers/ suppliers/vendors by ensuring that their personal information is collected, used disclosed, retained and destroyed in a manner consistent with PIPEDA.

Purpose of Information Being Collected
Personal information collected and retained will be used for business purposes relating to the associate's hire and employment as well as the operation of the Trust's business. Such business purposes may include but not be limited to:
• Determining suitability for hire, promotion, transfer, retention and assignment;
• Administering compensation, benefit and expense reimbursement programs;
• Measuring and managing business and personal performance productivity;
• Complying with legal obligations, including, but not limited to, employment standards, labour relations, human rights, workers compensation, health and safety, taxation and common law obligations.

Consent
By signing the employment contract, associates provide the necessary and appropriate consent to the collection, retention, disclosure and destruction of personal information that is relevant to business purposes of the Trust.

Limiting Collection
Personal information collected and retained will be limited to that which is necessary for the purposes identified.

Limiting Use, Disclosure and Retention
Personal information collected by the Trust will not be used or disclosed for purposes other than those for which it is collected, except with the consent of the associate or as required by law. Personal information will only be retained for as long as necessary for the fulfillment of those purposes or as required by law.
Further, by signing the employment contract, or other contracts/leases or legal documents, vendors/suppliers/ contractors/vendors and associates provide consent to the Trust's disclosure of such personal information to third parties for legitimate, identified purposes, including but not limited to, compensation and benefits administrators, consultants and advisors and governmental and adjudicative authorities or potential successors to all or part of the business of the Trust.

Accuracy
Personal information collected and retained will be as accurate, complete and up-to-date as is necessary for the purposes for which it is to be used. Upon hire, associates are requested to provide their personal information in an accurate and complete manner. Associates are also requested to submit via email to Human Resources anytime there is a change in personal information that is retained by the Trust.

Safeguards
Personal information collected and retained will be safeguarded by means appropriate to the sensitivity and risk as determined by the Trust.
Furthermore, associates are expected to honour any confidentiality agreements from previous associates or their parties and will not make inappropriate use of any other person's confidential or proprietary information in carrying out their duties for the Trust.

Openness
The Trust will make readily available to associates specific information about policies and procedures relating to the management of personal information that is under its control. Associates are invited to review any and all Trust policies on the Trust's Online Orientation and the intranet for the most up to date versions as changes are made and communicated to all associates.

Individual Access
Upon request, associates may be informed of the existence, use and disclosure of their personal information that is under the Trust's control and may be given access to that information. To do so, associates are requested to contact Human Resources and make an appointment to view their personnel file and any other relevant personal information they believe is being retained. Any corrections or revision to personal information retained by the Trust should be corrected by sending an email to Human Resources.