At Bison Credit Solutions, we embrace the new federal Personal Information Protection and Electronic Documents Act (PIPEDA) and acknowledge the importance of national standards that are designed to protect the personal information that we collect.

The Code of Privacy for Bison Credit Solutions follows and complies with the CSA Model Code of Personal Information Privacy. It is as follows:

1. ACCOUNTABILITY

Bison Credit Solutions will be responsible for all personal information held under our control. We have designated a Chief Privacy Officer, whose responsibility it is to ensure our organization remains privacy compliant through strict adherence with the policies and procedures as indicated in PIPEDA. The Chief Privacy Officer for Bison Credit Solutions is Jim Van Esch, Operations Manager. Any enquiries respecting privacy compliance or information management should be directed to his attention. Upon receiving an enquiry, Mr. Van Esch will respond within thirty (30) days. Mr. Van Esch can be contacted at:

Bison Credit Solutions
3402 8th St SE
Calgary, Alberta
T2G 5S7

Telephone: (403) 263 7620
Facsimile: (403) 263 7623
Toll Free: (877) 686 8522

Bison Credit Solutions has made a commitment to:

• • Protect personal information under our control.

• • Allow individuals to request information; seek amendments to their personal information; and file complaints against Bison Credit Solutions with our Chief Privacy Officer.

• • Provide continuous training on information management to our staff.

• • Develop information to explain to the public and our clients, those policies and procedures that make Bison Credit Solutions privacy compliant.

2. IDENTIFY PURPOSES

Bison Credit Solutions will identify the purpose for which we collect personal information on affected individuals at the time of collection. All assignments received from our clients will be vetted to ensure their requests for information are compliant with PIPEDA.

3. CONSENT

By our clients listing accounts for collection with our agency, this implies that we are acting on their behalf; thereby enabling us to collect any necessary pertinent information in reference to the file. We may obtain express consent for the collection, use or disclosure of personal information, or may act accordingly when we determine that consent has been implied by the circumstances. Express consent is specific authorization given by the affected individual to Bison Credit Solutions, either orally or in writing. Implied consent is when Bison Credit Solutions has not received a specific consent but the circumstances allow us to collect, use, or disclose personal information.

4. LIMITING COLLECTION

Bison Credit Solutions will limit its collection of personal information to that which is necessary for the purposes we have identified. We will only collect personal information for specific, legitimate purposes and will not collect personal information indiscriminately. Bison Credit Solutions will only collect information by fair and lawful means – not by misleading or deceiving individuals about the purpose for which the information is being collected. Our policies and procedures relating to the limitations on collection of personal information will be regularly communicated to our employees who deal with collection, use and disclosure of personal information.

5. LIMITING USE, DISCLOSURE, AND RETENTION

Bison Credit Solutions will limit the use, disclosure of personal information to those purposes for which it is initially collected, as permitted by law. Upon the date mandated by law, all records collected will be destroyed, erased, or made anonymous.

6. ACCURACY

Bison Credit Solutions will make every effort to ensure that the personal information collected for an intended purpose is accurate, complete, and up-to-date. Our goal is to minimize the possibility that inappropriate or inaccurate information may be used to make a decision about any individual whose personal information we process.

7. SAFEGUARDS

Bison Credit Solutions will safeguard all personal information under our control in a manner that is appropriate to the sensitivity of the information. We will take all the physical security measures necessary including alarming and properly locking our facilities and/or locking all personal information in secure filing cabinets. All Bison Credit Solutions employees will be properly trained in the policies that pertain to these safeguards. Members of the public will not be allowed access to our facilities unless identified, logged in, and escorted by properly trained staff. Personal information under the control of Bison Credit Solutions may be electronically stored. We maintain our own servers on-site that are protected through the application of the latest technical measures as well as physical access restriction. Bison Credit Solutions has a strict policy respecting the management and distribution of personal information, whether by electronic means or otherwise, and we ensure that all staff are trained in these procedures. The distribution of personal information will be on a need-to-know basis. We will take precautions in the disposal or destruction of personal information to prevent unauthorized parties from gaining access to personal information. These measures include:

• • Ensuring that no one may retrieve personal information after disposal.

• • Shredding documents before recycling the chaff,

• • • Deleting electronically stored

  information,

• Destroying hard drives, memory sticks, disks, etc. when they are no longer of use and are decommissioned.

8. OPENNESS

Bison Credit Solutions will make information respecting our policies and procedures which govern our information management readily available to individuals requesting same. All employees of Bison Credit Solutions will make available to the public easily understandable information about our company, our privacy policies, and our Code of Privacy. This information is available in hard copy by contacting Bison Credit Solutions at (403) 263 7620 or can be accessed through our website at www.bisoncredit.com.

9. INDIVIDUAL ACCESS

Upon request, an individual will be informed of the existence, use and disclosure of his/her personal information that is under our control. They may be given access to and be permitted to challenge the accuracy and the completeness of that information. There are lawful exceptions that will prevent us from providing such access, which include, but are not limited to the following:

• • Personal information about another person might be revealed,

• • Commercially confidential information might be revealed,

• • Someone’s life or security might be compromised.

• • The information was collected without consent for the purposes related to an investigation of a contravention of a law or a breach of an agreement or other lawful exemption.

• • The information was generated during the course of a formal dispute resolution process,

• • The information is protected by the Solicitor/Client privilege,

• When restricted from providing this disclosure under other Federal or Provincial legislation.

10. CHALLENGING COMPLIANCE

An individual may address a challenge concerning compliance with the aforementioned policies and procedures to our Chief Privacy Officer whose details are listed in Section 1 (Accountability).