Privacy Principles

Introduction

Great White North Inc. ("Great White North") is concerned about the protection of personal information that it holds respecting its clients, subscribers and others. The approaches outlined in these privacy principles (the "Privacy Principles") provide the framework for Great White North's policies and procedures regarding its collection, use, retention and disclosure of personal information in all its operations.

The Privacy Principles are based on the principles contained in the federal Personal Information Protection and Electronic Documents Act and the Canadian Standards Association's Model Code for the Protection of Personal Information, which forms part of the Act and are consistent with principles contained in provincial privacy laws, where applicable.

The Privacy Principles apply to personal information that is collected, used or disclosed by Great White North. They do not apply to non-personal information or business information.

The Privacy Principles will be made available to clients, subscribers and other interested persons upon request.

Overview of Privacy Principles

1. Accountability
   Great White North is responsible for personal information under its control and will designate a person or persons who are accountable for its compliance with the Privacy Principles.
2. Identifying Purposes
   Great White North will identify the purposes for which personal information is collected at or before the time the information is collected.
3. Consent
   The knowledge and consent of the individual are required for the collection, use, or disclosure of personal information, except where inappropriate.
4. Limiting Collection Great White North will limit the collection of personal information to that which is necessary for the purposes identified. Great White North will collect personal information by fair and lawful means.
5. Limiting Use, Disclosure, and Retention
   Great White North will not use or disclose personal information for purposes other than those for which it was collected, except with the consent of the individual or as required by law. Great White North will retain personal information only as long as necessary for the fulfilment of the purposes for which it was collected.
6. Accuracy
   Great White North will use reasonable efforts to ensure that personal information is as accurate, complete and up-to-date as is necessary for the purposes for which it is to be used.
7. Safeguards
   Great White North will protect personal information by security safeguards appropriate to the sensitivity of the information.
8. Openness
   Great White North will make readily available to individuals specific information about its policies and practices relating to the management of personal information.
9. Individual Access
   Upon request, Great White North will inform an individual of the existence, use and disclosure of his or her personal information and will give the individual access to that information. An individual will be able to challenge the accuracy and completeness of the information and have it amended as appropriate.
10. Challenging Compliance An individual will be able to address a challenge concerning compliance with the Privacy Principles to the person(s) designated to oversee Great White North 's compliance.

Definitions

In the Privacy Principles, the following definitions apply:

client - a current or potential customer of Great White North

collection - gathering, acquiring or obtaining personal information from any source by any means

consent - voluntary agreement with what is being done or proposed. Consent can be either express or implied. Express consent is given explicitly, either orally or in writing. Express consent is unequivocal and does not require any inference on the part of the organization seeking consent. Implied consent arises where consent may reasonably be inferred from the action or inaction of the individual.

disclosure - making personal information available to a third party

individual - a client, subscriber or other interested person

personal information - any information that is about or can be linked to an identifiable individual, but does not include the name, title, business address or telephone number of an employee of an organization.

subscriber - an individual who has requested newsletters from Great White North

third party - any person or organization other than Great White North

use - refers to the treatment and handling of personal information by Great White North

CUSTOMER SERVICE POLICY: PROVIDING GOODS AND SERVICES TO PEOPLE WITH DISABILITIES (AODA) - ONTARIO ONLY

In accordance with the Ontarians with Disabilities Act (ODA, 2001) and the Accessibility for Ontarians with Disabilities Act (AODA, 2005), GWN has developed a policy to ensure that persons with disabilities have equal access to programs, services and activities. GWN strives at all times to provide its goods and services in a way that respects the dignity and independence of people with disabilities. GWN is also committed to giving people with disabilities the same opportunity to access our goods and services and allowing them to benefit from the same services, in the same place and in a similar way, as GWN's other clients.

This policy applies to all GWN employees, contractors, clients, any person engaged in business with GWN and visitors to GWN property in the province of Ontario.

PROVIDING GOODS AND SERVICES TO PEOPLE WITH DISABILITIES

GWN is committed to excellence in serving all clients including people with disabilities. The company will carry out its functions and responsibilities in the following areas:

• Communication - we will communicate with people with disabilities in ways that take into account their disability and make information available to them in a variety of accessible formats. The company will train staff who communicate with clients on how to interact and communicate with people with various types of disabilities.
• Telephone Services - we are committed to providing fully accessible telephone service to our clients. GWN will train staff to communicate with clients over the telephone in clear and plain language and to speak clearly and slowly. The company will offer to communicate with clients via email if telephone communication is not suitable to their communication needs and/or is not available.
• Assistive Devices - GWN will ensure that staff are trained and familiar with various assistive devices that may be used by clients with disabilities while accessing our goods or services:
• Persons with disabilities are welcome to use their assistive devices.
• Persons with disabilities are welcome to use service animals.
• Billing - GWN is committed to providing accessible invoices to all of its clients. If an invoice is required in another format, please contact your account manager or let us know at info@gwnpromo.com.

USE OF SERVICE ANIMALS AND SUPPORT PERSONS

We welcome people with disabilities who are accompanied by a service animal on GWN premises that are open to the public and other third parties. GWN will also ensure that all staff dealing with the public are properly trained in how to interact with people with disabilities who are accompanied by a service animal.

We also welcome people with disabilities who are accompanied by a support person. Any person with a disability who is accompanied by a support person will be allowed to enter GWN's premises with his or her support person. At no time will a person with a disability who is accompanied by a support person be prevented from having access to his or her support person while at our office.

NOTICE OF TEMPORARY DISRUPTION

Clients will be provided with notice in the event of a planned or unexpected disruption in the facilities or services usually used by people with disabilities. This notice will include information about the reason for the disruption, its anticipated duration, and a description of alternative facilities or services, if available. The notice will be placed at all public entrances to our premises.

TRAINING FOR STAFF

The company will ensure that all its employees and contractors to whom this policy applies, receive training required by the Accessibility Standards for Customer Service. In addition, training will be provided to all staff as part of orientation training for new employees, and on a continuing basis, as required.

The amount and format of training will depend on the level of the employee's interaction with clients. A record of training will be kept by GWN's management.

Training will include:

• the objectives of the Accessibility for Ontarians with Disabilities Act, 2005 and the requirements of the client service standard;
• how to interact and communicate with people with various types of disabilities;
• what to do if a person with a disability is having difficulty accessing a service or resource; and
• how to use the equipment or devices available throughout our building that may help to provide services to persons with disabilities.

Applicable staff will be trained on policies, practices and procedures that affect the way goods and services are provided to people with disabilities. Staff will also be trained on an ongoing basis when changes are made to these policies, practices and procedures.

FEEDBACK PROCESS

We want to meet and surpass client expectations while serving clients with disabilities. Comments on GWN's services regarding the way we provide goods and services to people with disabilities can be provided by sending an email to the Office Manager at info@gwnpromo.com. A response can be expected within five (5) business days.

MODIFICATIONS TO THIS OR OTHER POLICIES

No changes will be made to this policy before considering the impact on people with disabilities. Any policy of GWN that does not respect and promote the dignity and independence of people with disabilities will be modified or removed.