Personal information means information about an identifiable individual, except business title and business contact information when used or disclosed for business communications, and includes information about prospective, present or former employees and external parties such as landowners and other individuals.
It is Sunshine's policy to comply with the privacy legislation within each jurisdiction in which it operates. Sometimes the privacy legislation and / or an individual's right to privacy are different from one jurisdiction to another. This Policy covers only those activities that are subject to the provisions of Canada's federal and provincial privacy laws, as applicable.
Sunshine will endeavour to obtain express, deemed or implied consent of individuals, except where otherwise permitted by law, to collect, use and disclose personal information for reasonable business purposes. To the extent that your consent is required, Sunshine will assume, unless you advise otherwise, that you have consented to Sunshine collecting, using and disclosing your personal information for the purposes stated in this policy (including any other purposes stated or reasonably implied at the time such personal information was provided to Sunshine).
You may withdraw or limit your consent to our collection, use or disclosure of your personal information at any time, subject to any legal or contractual restriction and reasonable notice. Please note that the withdrawal of your consent may change the way in which Sunshine is able to interact with you.
Internal Stakeholder Information
"Personal employee information" is personal information collected, used or disclosed for the purposes of establishing, managing or terminating an employment relationship. Sunshine can collect, use and disclose this information without consent but will only collect, use and disclose the personal information that is necessary for the purpose of administering the employment relationship.
External Stakeholder Information
In general, the personal information about external parties is collected, used and disclosed for the purposes of:
- Providing information about Sunshine and its operation to external parties
- Managing and administering contracts with external parties
- Managing Sunshine's relationship with and providing for the safety of external parties
- Meeting any legal or regulatory requirement or obligation
- Facilitating participation in Sunshine events
- Other reasonable purposes consistent with Sunshine's business objectives.
For example, Sunshine may collect personal information about individuals including landowners, leaseholders, residents and royalty holders for purposes such as:
- Administration - to execute agreements, facilitate payments and file land registry requirements
- Safety - Emergency Response Plans
- Legal compliance - as required by law or regulation (for example EUB, environmental and Government regulations)
- Development - to manage and foster relationships necessary to conduct business
- External stakeholder considerations that are reasonably necessary and / or required.
Protection of Information
Sunshine will endeavour to ensure that personal information is protected by reasonable security safeguards that are appropriate to the sensitivity level of the information and that personal information is only retained for the period of time as outlined in any retention and disposal guidelines established by Sunshine from time to time, or as required for statutory or other legal purposes. Some of the security safeguards implemented by Sunshine include:
- Limiting the collection, use and disclosure of personal information to that reasonably required to carry on our business.
- Ensuring that areas and documents are only accessible by authorized personnel on a need-to-know basis.
- Protecting the confidential nature of personal information when dealing with other organizations and requiring them to meet the same standard as we do in handling personal information.
Access to Information
Upon written request, and subject to legal requirements, individuals will be granted the reasonable right of access to and review of their personal information within 30 days of the request being made. Summary information is available on request. More detailed requests, which require archive or other retrieval costs, may be subject to normal fees and disbursement costs. Sunshine will seek to identify these costs to you at the time of your request.
In order to ensure compliance with this Policy and privacy legislation, Sunshine has appointed the VP Corporate Operations as the Privacy Officer for the Company. The Privacy Officer is responsible for ensuring compliance with the law and this policy and responding to any questions or concerns. You may address any questions or concerns about our compliance with this policy or concerning your personal information by contacting Sunshine's Privacy Officer.
Sunshine Oilsands Ltd.
Privacy Officer: Michele Langer
Sunshine's Commitment to Privacy Principles
- Accountability - Sunshine is responsible for personal information under its control and has designated a Privacy Officer who is accountable for Sunshine's compliance with the privacy principles.
- Identifying Purposes - Sunshine shall identify the purposes for which personal information is collected at or before the time of collection.
- Obtaining Consent - The knowledge and consent of an individual are required for the collection, use, or disclosure of personal information, except where inappropriate.
- Limiting Collection - The collection of personal information shall be limited to that which is necessary for the purposes identified by Sunshine. Personal information shall be collected by fair and lawful means.
- Limiting Use, Disclosure and Retention - Sunshine shall 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. Sunshine shall retain personal information only for as long as necessary to achieve fulfillment of the identified purposes.
- Keeping Personal Information Accurate - Sunshine shall keep personal information as accurate, complete, and up-to-date as is necessary for the purposes for which it is to be used.
- Safeguarding Personal Information - Sunshine shall protect personal information by security safeguards appropriate to the sensitivity of the information.
- Openness Concerning our Privacy Practices - Sunshine ensures that specific information about its policies and practices relating to the management of personal information is made readily available to individuals with whom it interacts.