Peak of the Market Privacy Policy

  1. Introduction: This document defines Peak of the Market’s (Peak’s) Privacy Policy and sets out guidelines and procedures to be followed by Peak and its employees to protect the privacy of “personal information” in Peak’s possession. Personal information means any information about an identifiable individual except the name, title or business address or business telephone number of an employee.

    The Privacy Policy is based on the requirements of the Personal Information Protection and Electronic Documents Act (Canada) (“PIPEDA”). The Privacy Policy applies to all aspects of personal information handling by Peak.

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  2. General Policy Statement: Peak does not generally collect personal information but may, in certain instances, collect personal information to allow it to more effectively carry on its business. Such information could include:

    1. Names and addresses of individual growers, employees and individual customers;

    2. Credit information about individual growers or individual customers;

    3. Information voluntarily submitted by web-site visitors.

    All personal information shall be handled in accordance with PIPEDA and Peak shall comply with the principles set out in PIPEDA.

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  3. Privacy Officer: Peak shall, at all times, have a designated privacy compliance officer (the “Privacy Officer”) responsible for privacy compliance by Peak. His or her name shall be made available to the public upon request. The responsibilities of the Privacy Officer shall include:

    1. Establishing and updating, as necessary, personal information protection policies and procedures.
    2. Ensuring, by way of contractual means or otherwise, that protection is provided by other organizations to which personal information is disclosed.
    3. Ensuring that Peak’s employees are informed of Peak’s Privacy Policy and procedures and the importance of protecting and maintaining the confidentiality of personal information.
    4. Addressing privacy inquiries, complaints and access requests.

    In addition to the Privacy Officer, other individuals within Peak may be designated as being responsible for the day-to-day collection and processing of personal information.

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  4. Peak and its employees shall comply with the following policies regarding the collection, use and disclosure of personal information:

    1. Only personal information reasonably necessary to allow Peak to carry on its business shall be collected by Peak and its employees.

    2. No personal information shall be collected, used or disclosed without first obtaining the consent of the individual to the collection, use and/or disclosure of that information. ( In certain circumstances, with the permission of the Privacy Officer, consent may be implied, particularly where the information is not sensitive in the circumstances and where it can be reasonably assumed that the individual would expect the information to be collected, used and/or disclosed in the particular fashion).

    3. Peak shall document and disclose the purposes for which personal information is being collected at or before the time of collection. Disclosure of the purposes may be done orally or in writing but shall be stated in such a manner that the individual can reasonably understand how the information will be used or disclosed. Where information is collected in writing (for example, on an application form), disclosure of the purposes for which information is being collected should, if practical, be made in writing.

    4. Once personal information is collected, it shall be used and disclosed only for the purposes consented to by the individual, unless the individual consents to use or disclosure for another purpose.

    5. An individual may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice.

    6. Personal information shall not be routinely updated unless it is necessary for the purposes for which it was collected or if revisions are required by the individual it relates to.

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  5. Accuracy of Personal Information: Peak and its employees shall take reasonable steps 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. To ensure the quality and integrity of the personal information collected:

    1. Insofar as possible, personal information should be collected directly from the individual to whom it relates.

    2. Information received from public sources or third parties should, where practical, be confirmed with the individual to whom it relates.

    3. Where information is disclosed by Peak, appropriate disclaimers regarding accuracy should be provided.

    4. Employees of Peak shall notify the Privacy Officer of any change to their personal information.

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  6. Protecting Personal Information: Personal information shall be protected in a manner commensurate with its sensitivity and reasonable steps shall be taken to prevent it from being stolen, lost, accessed, copied, used or modified without permission.

    Personal information collected by Peak shall be disclosed internally only to those persons who need to know the information in order for Peak to fulfill the purposes for which such information was collected.

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  7. Retention and Destruction: Peak and its employees shall follow the following policies with respect to retention and destruction of personal information:

    1. Peak shall keep personal information as long as it remains necessary or relevant for the purposes identified or as required by law. Peak shall destroy, erase or make anonymous any personal information no longer needed for its identified purposes or legal requirements.

    2. Personal information that has been used to make a decision about an individual shall be retained long enough to allow the individual access to the information after the decision has been made.

    3. The review and destruction of personal information shall be supervised by the Privacy Officer.

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  8. Access to Personal Information: Any requests for personal information held by Peak of the Market or inquiries about Peak’s practices in dealing with personal information, shall be referred directly to the Privacy Officer and the Privacy Officer shall be responsible for responding to such requests. Any such request or inquiry may be addressed to:

    Peak of the Market Privacy Officer
    1200 King Edward Street
    Winnipeg, Manitoba R3H 0R5

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  9. Challenging Compliance: Any complaint regarding Peak’s handling of personal information or Compliance with PIPEDA shall be made in writing to the Privacy Officer. The Privacy Officer shall investigate the complaint and attempt to resolve the complaint to the individual’s satisfaction.