Privacy Policy

Purpose

Doman Building Materials Ltd. is committed to maintaining and protecting the accuracy, confidentiality and security of personal information of its employees and individuals with whom it conducts business.

Doman will protect the privacy of personal information of employees, of applicants for employment and individuals as well as personal information received by the Company from other sources at all times during and after employment with the Company.

Scope

This policy applies to all Doman employees.

Ten Privacy Principles

As part of its commitment to privacy, Doman has adopted the following ten principles based on Canada’s privacy legislation, the Personal Information Protection and Electronic Documents Act (PIPEDA). This Privacy Policy describes how Doman collects, uses and discloses personal information concerning its employees.

Accountability

Doman is responsible for protecting personal information under its control and has designated individuals who are responsible for ensuring the Company’s compliance with these privacy principles.

Privacy Officer: Doman’s Privacy Officer is the Chief Financial Officer. The Privacy Officer may be contacted at the address set out at the end of this policy statement.

Management: Senior managers, managers and supervisors are responsible for and shall oversee compliance by their staff with Doman’s Privacy Policy to ensure:

• Purposes are defined for collection of personal information.
• Consent is obtained to collect and disclose the information.
• Collection, use and disclosure of personal information is limited.
• Information is accurate, complete and up-to-date.
• Adequate safeguards protect personal information within Doman’s control.
• Retention and destruction timetables are maintained.
• Contracts with third parties that process Doman information shall include privacy protection requirements.

Managers and supervisors are responsible for the collection, processing and safeguarding of personal information under their control. Managers and supervisors shall inform and train employees having access to personal information on Doman privacy policies and procedures.

All employees of Doman are bound under this Privacy Policy to maintain and protect the privacy and confidentiality of personal information and to follow the privacy protection procedures established by Doman when collecting, using, disclosing and safeguarding personal information.

All Doman’s third party providers are bound contractually to maintain the confidentiality of personal information and to not use the personal information for purposes that are not related to the service/product that they have been contracted to provide and that is not consistent with Doman’s privacy policies and practices.

Identifying Purposes

The purposes for which personal information is collected will be identified before or at the time the personal information is collected.

Doman collects, uses and discloses personal information for the purposes of establishing, managing and promoting the employment relationship with its employees, [current, retired or terminated] or with prospective job applicants, and with other individuals.

The purposes are as follows:

• To establish and maintain employment relationships with employees, prospective job applicants and other interested individuals;
• To administer compensation, incentive programs, benefits, pension plans, and health and safety programs;
• To meet legal, statutory and other regulatory requirements;
• To manage our employees in terms of staffing, recruitment and succession planning decisions. This includes managing employee development, performance management evaluations, and enhancing our ability to meet business objectives;
• To administer and/or protect the Company assets such as communication, networks, voicemail and the Internet.

Doman will indicate either orally, electronically or in writing, at or before the time personal information is collected, the purpose for which it is being collected.

Consent

The consent of the individual will be obtained for the collection, use and disclosure of personal information, except in certain circumstances required or permitted by law.

It is Doman’s policy to collect, use and disclose personal information about its employees and other individuals with their knowledge and consent, unless required or allowed by law. Prior to collecting personal information, the Company will identify the purposes for doing so and limit the collection, use and disclosure of personal information to those purposes.

Consent may be obtained in various ways. Doman may obtain express consent or may determine that consent has been implied by the circumstances.

By completing application forms, benefit or pension forms or employment related contracts, employees and individuals are consenting to the collection and use of personal information for the purposes set out in this Privacy Policy and to the disclosure of personal information to the persons identified in this Privacy Policy for the purposes noted in the above section.

In certain circumstances depending upon the personal information required, express consent will be obtained and employees will be advised prior to the collection, use and disclosure of personal information.

Employees and individuals may withhold or withdraw their consent for Doman and designated third parties as long as there are no legal or contractual reasons preventing them from doing so. Depending upon the circumstances, however, withdrawal of consent may affect the ability of Doman to continue to provide employment, compensation, benefits, programs to employees, or products or services to individuals.

Employees and individuals may contact Doman for more information regarding the implications of withdrawing consent.

Generally, the disclosure of employee and individual personal information will be restricted to those who have a need for, and the right to, the information. Personal information will be accessible by Doman employees who need the information in the performance of their duties. Such employees will include, but not be limited to, payroll/benefit administrators, supervisors, managers and human resources staff.

Exceptions

Doman may collect, use or disclose information without an individual’s prior knowledge or consent in certain circumstances as permitted by law or when required by a court of law or by a regulatory organization, or to legal advisors in order to protect the interests of Doman, or in an emergency situation where the life, health or security of an individual is threatened.

Doman may disclose personal information without prior knowledge or consent of the individual in the following situations:

• To a lawyer or other legal representative of Doman
• To a government body or agency in certain circumstances (for example: Canada Revenue Agency, Employment Insurance, provincial employment standards)
• To collect a debt, or comply with a subpoena, warrant or other court order, or as required by a court of law
• In circumstances otherwise permitted by law.

Limiting Collection

The collection of personal information shall be limited to that which is necessary for the purposes identified and will be collected by fair and lawful means.

When collecting personal information, Doman will usually collect it directly from the individuals about whom the personal information pertains in the form of completed applications or forms, or through other means of correspondence such as the telephone, mail or email.

Personal information may be collected from other sources with prior consent from the individual, for example, from prior employers, personal references or from other third parties having the right to disclose the information.

Limiting Use, Disclosure and Retention

Personal information shall only be used or disclosed for the purposes for which it was collected, unless the individual has otherwise consented or when required or permitted by the law. Personal information will be retained for as long as necessary to satisfy the purposes for which it was collected, or as required or permitted by law.

Personal information will be retained in the Company records for as long as it is reasonably needed to fulfill the identified purposes, or as required or permitted by law. Personal information will be destroyed in a safe and secure manner once it is no longer required.

Doman discloses employee personal information to third parties as required to process payroll and compensation, benefits and pension, to employees and agents and other related employment services, or as required by applicable law, or as otherwise set out in this policy.

Accuracy

Any personal information that is collected, used or disclosed will be kept as accurate, complete and as up-to-date as is necessary for the purposes for which it is used.

Doman will make every reasonable effort to ensure that any personal information is accurate, complete and as up-to-date as required for the identified purposes. Doman will rely on employees and individuals to provide accurate information and to advise the Company of any changes.

Employees and individuals aware of any inaccuracy or changes in their personal information are to contact the Human Resources Department, depending on the nature of the information.

Safeguards

Personal information shall be protected by security safeguards that are appropriate to the sensitivity level of the information received.

Doman is committed to protecting the personal information of its employees [including prospective, current, retired, or terminated] and individuals, and has implemented the necessary security safeguards that are appropriate to the sensitivity of the information to protect it from unauthorized access, disclosure, use or copying.

This means that the personal information is protected:

• Physically by building security measures, secure locked file cabinets
• Organizationally by Doman policies, procedures, staff training and limited access levels
• Technologically by appropriate use of electronic means, including passwords, anti-virus software, use of firewalls

All employees, agents or third party service providers are required to follow the Privacy Policy and practices to protect and safeguard personal information and may not use the information for any unauthorized purpose.

If Doman receives a request to release personal information, the Company will do so only upon satisfactory identification and proof of entitlement of the organization or individual making the request or as required or permitted by law, or upon written authorization of employees, past or present.

Openness

Doman will provide information to individuals about its privacy policies and practices relating to the management of personal information.

Employees and other individuals can obtain more information about Doman privacy policies and procedures by contacting the Privacy Officer in writing. The Privacy Policy is available in the Doman’s Policies, Processes and Procedures manual, in the Doman Employee Handbook and on the Company website.

Individual Access

Upon written request to Doman’s Privacy Officer, an individual will be informed of the existence, use and disclosure of their personal information and shall be given access to it as required and permitted by law. Individuals are entitled to challenge the accuracy and completeness of that personal information and request to have it amended, if appropriate.

Employees and individuals have the right to access and verify personal information maintained in the Company files and to request that any factually inaccurate personal information be corrected, subject to exemptions in the applicable legislation. Depending upon the circumstances, Doman may not always be able to give access to all information, and if this is the case, Doman will provide the individual with reasons in writing for denying access.

Doman shall provide individuals a reasonable opportunity to review and challenge the accuracy and completeness of personal information. A statement of disagreement will be attached to records where a requested amendment cannot be made.

Employees can request access to their employee file by contacting the Human Resources Department.

Challenging Compliance

An individual shall be able to address a challenge concerning compliance with the above principles to the designated individual accountable for Doman’s compliance.

It is Doman’s policy to respond to all inquiries, requests for access to personal information and concerns within 30 days of receiving them unless otherwise allowed or required by law. Inquiries are to be in writing and directed to the attention of the Privacy Officer. If the Privacy Officer is unable to respond to the inquiry within 30 days, individuals will be notified in advance of the end of the 30 day period of when to expect to receive a response.

All privacy complaints must be directed in writing to the attention of the Privacy Officer. It is Doman’s policy to respond to complaints within 30 days of receiving them. If the Privacy Officer is unable to respond to the inquiry within 30 days, individuals will be notified in advance of the end of the 30 day period of when to expect to receive a response.

Contact Details

The Privacy Officer can be reached, in writing, at the following address:

Doman Building Materials Ltd.
1600-1100 Melville Street
P.O. Box 39
Vancouver, BC V6E 4A6
Fax: 604.436.6674
Attention: Privacy Officer

Please be advised that all inquiries and complaints must be IN WRITING to the attention of the Privacy Officer. Telephone calls WILL NOT be accepted. Please be sure to include your name, address, phone number and information relating to the nature of your inquiry or complaint.