GMC PROJECTS INC.

PERSONAL INFORMATION PROTECTION POLICY

At GMC Projects Inc, we are committed to providing our tenants, clients, employees, and vendors with exceptional service. As providing this service may involve the collection, use and disclosure of some personal information about our tenants, clients, employees, and vendors protecting their personal information is one of our highest priorities.

While we have always respected our tenants’, clients’, employees’, and vendors’ privacy and safeguarded their personal information, we have strengthened our commitment to protecting personal information as a result of British Columbia’s Personal Information Protection Act (PIPA).  PIPA, which came into effect on January 1, 2004, sets out the ground rules for how B.C. businesses and not-for-profit organizations may collect, use and disclose personal information.

We will inform our tenants, clients, employees, and vendors of why and how we collect, use and disclose their personal information, obtain their consent where required, and only handle their personal information in a manner that a reasonable person would consider appropriate in the circumstances.

This Personal Information Protection Policy, in compliance with PIPA, outlines the principles and practices we will follow in protecting tenants, clients, employees, and vendors personal information. Our privacy commitment includes ensuring the accuracy, confidentiality, and security of our tenants, clients, employees, and vendors personal information and allowing our tenants, clients, employees, and vendors to request access to, and correction of, their personal information.

Scope of this Policy

This Personal Information Protection Policy applies to GMC Projects Inc and any company that GMC Projects Inc manages. This policy also applies to any service providers collecting, using or disclosing personal information on behalf of GMC Projects Inc.

DEFINITIONS

Personal Information – means information about an identifiable individual. Personal information does not include contact information (described below)

Contact information – means information that would enable an individual to be contacted at a place of business and includes name, position name or title, business telephone number, business address, business email or business fax number.  Contact information is not covered by this policy or PIPA.

Privacy Officer – means the individual designated responsibility for ensuring that GMC Projects Inc complies with this policy and PIPA.

POLICY 1 – COLLECTING PERSONAL INFORMATION

1.1  Unless the purposes for collecting personal information are obvious and the tenant, client, employee, and/or vendor voluntarily provides his or her personal information for those purposes, we will communicate the purposes for which personal information is being collected, either orally or in writing, before or at the time of collection.

1.2  We will only collect tenant, client, employee, and/or vendor information that is necessary to fulfill the following purposes:

·       To verify identity;

·       To verify creditworthiness;

·       To identify tenant, client, employee, and/or vendor preferences;

·       To understand the needs of our tenant, client, employee, and/or vendor;

·       To open and manage an account;

·       To deliver requested products and services;

·       To ensure a high standard of service to our tenant, client, employee, and/or vendor;

·       To meet regulatory requirements;

·       To assess suitability for tenancy;

·       To collect and process rent payments;

POLICY 2 – CONSENT

2.1  We will obtain tenant, client, employee, and/or vendor consent to collect, use or disclose personal information (except where, as noted below, we are authorized to do so without consent).

2.2  Consent can be provided orally, in writing, electronically or it can be implied where the purpose for collecting using or disclosing the personal information would be considered obvious and the tenant, client, employee, and/or vendor voluntarily provides personal information for that purpose.

2.3  Subject to certain exceptions (e.g., the personal information is necessary to provide the service or product, or the withdrawal of consent would frustrate the performance of a legal obligation), tenant, client, employee, and/or vendor can withhold or withdraw their consent for GMC Projects Inc to use their personal information in certain ways.  A tenant’s, client’s, employee’s, and/or vendor’s decision to withhold or withdraw their consent to certain uses of personal information may restrict our ability to provide a particular service or product. If so, we will explain the situation to assist the tenant, client, employee, and/or vendor in making the decision.

2.4  We may collect, use or disclose personal information without the tenant, client, employee, and/or vendor’s knowledge or consent in the following limited circumstances:

·       When the collection, use or disclosure of personal information is permitted or required by law;

·       In an emergency that threatens an individual's life, health, or personal security;

·       When the personal information is available from a public source (e.g., a telephone directory);

·       When we require legal advice from a lawyer;

·       For the purposes of collecting a debt;

·       To protect ourselves from fraud;

·       To investigate an anticipated breach of an agreement or a contravention of law

POLICY 3 – USING AND DISCLOSING PERSONAL INFORMATION

3.1  We will only use or disclose tenant, client, employee, and/or vendor personal information where necessary to fulfill the purposes identified at the time of collection.

3.2  We will not use or disclose tenant, client, employee, and/or vendor personal information for any additional purpose unless we obtain consent to do so.

3.3  We will not sell tenant, client, employee, and/or vendor lists or personal information to other parties unless we have consent to do so.

POLICY 4 – RETAINING PERSONAL INFORMATION

4.1  If we use tenant, client, employee, and/or vendor personal information to make a decision that directly affects the tenant, client, employee, and/or vendor we will retain that personal information for at least one year so that the tenant, client, employee, and/or vendor has a reasonable opportunity to request access to it.

4.2  Subject to policy 4.1, we will retain tenant, client, employee, and/or vendor personal information only as long as necessary to fulfill the identified purposes or a legal or business purpose.

POLICY 5 – ENSURING ACCURACY OF PERSONAL INFORMATION

5.1  We will make reasonable efforts to ensure that tenant, client, employee, and/or vendor personal information is accurate and complete where it may be used to make a decision about the tenant, client, employee, and/or vendor or disclosed to another organization.

5.2  Tenants, clients, employees, and/or vendors may request correction to their personal information in order to ensure its accuracy and completeness.  A request to correct personal information must be made in writing and provide sufficient detail to identify the personal information and the correction being sought.

5.3  If the personal information is demonstrated to be inaccurate or incomplete, we will correct the information as required.

POLICY 6 – SECURING PERSONAL INFORMATION

6.1  We are committed to ensuring the security of tenant, client, employee, and/or vendor personal information in order to protect it from unauthorized access, collection, use, disclosure, copying, modification or disposal or similar risks.

6.2  The following security measures will be followed to ensure that tenant, client, employee, and/or vendor personal information is appropriately protected:

·       Use locked filing cabinets;

·       physically secure offices where personal information is held;

·       use of user IDs, passwords, encryption, firewalls;

·       restrict employee access to personal information as appropriate (i.e., only those that need to know will have access;

·       contractually require any service providers to provide comparable security measures.

6.3  We will use appropriate security measures when destroying tenant, client, employee, and/or vendor personal information such as shredding documents and deleting electronically stored information.

6.4  We will continually review and update our security policies and controls as technology changes to ensure ongoing personal information security.

POLICY 7 – PROVIDING TENANT, CLIENT, EMPLOYEE, AND/OR VENDOR ACCESS TO PERSONAL INFORMATION

7.1 Tenants, clients, employees, and/or vendors have a right to access their personal information, subject to limited exceptions.

7.2  A request to access personal information must be made in writing and provide sufficient detail to identify the personal information being sought.

7.3  Upon request, we will also tell our tenant, client, employee, and/or vendor how we use their personal information and to whom it has been disclosed if applicable.

7.4  We will make the requested information available within 30 business days, or provide written notice of an extension where additional time is required to fulfill the request.

7.5  A minimal fee may be charged for providing access to personal information.  Where a fee may apply, we will inform the tenant, client, employee, and/or vendor of the cost and request further direction from the tenant, client, employee, and/or vendor whether or not we should proceed with the request.

7.6  If a request is refused in full or in part, we will notify the tenant, client, employee, and/or vendor in writing, providing the reasons for refusal and the recourse available to the tenant, client, employee, and/or vendor.

POLICY 8 – QUESTIONS AND COMPLAINTS:  THE ROLE OF THE PRIVACY OFFICER OR DESIGNATED INDIVIDUAL

8.1  The CFO is GMC Projects designated Privacy Officer and is responsible for ensuring GMC Project Inc’s compliance with this policy and the Personal Information Protection Act.

8.2  Tenant’s, client’s, employee’s, and/or vendor’s should direct any complaints, concerns or questions regarding GMC Projects Inc’s compliance in writing to the Privacy Officer. If the Privacy Officer is unable to resolve the concern, the tenant, client, employee, and/or vendor may also write to the Information and Privacy Commissioner of British Columbia.

Contact information for GMC Projects Inc’s Privacy Officer:

Valerie Sauve, CFO
vsauve@gmcprojects.com