McCoy Corporation

Personal Information Protection Policy

At McCoy, we are committed to providing our customers with exceptional service. As providing this service involves the collection, use and disclosure of some personal information about our customers, protecting their personal information is one of our highest priorities. This policy applies to all McCoy divisions and subsidiaries, including The Real McCoy Service Centres, Scona Trailer Manufacturing, Peerless Limited, Farr Canada, Rebel Metal Fabricators Ltd. and Prairie Truck Ltd..

McCoy complies with all relevant provincial legislation, namely the Personal Information Protection Act ("PIPA") of Alberta. Where applicable, the Corporation also complies with PIPA’s counterpart in British Columbia, and the Personal Information Protection and Electronic Documents Act (S.C. 2000, c. 5) (“PIPEDA”) and have applied the ten key privacy principles as expressed in PIPEDA. These principles address the ways in which organizations such as McCoy collects, uses and disclose personal information, and also address the rights of individuals to have access to their personal information and to have it corrected if necessary.

McCoy will inform our customers 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 customers’ personal information. Our privacy commitment includes ensuring the accuracy, confidentiality, and security of our customers’ personal information and allowing our customers to request access to, and correction of, their personal information.

Scope of this Policy

This Personal Information Protection Policy applies to McCoy and any divisions and subsidiaries it may have from time to time.

This Policy also applies to any service providers collecting, using or disclosing personal information on behalf of McCoy its divisions and subsidiaries.

Definitions

"Personal Information" –means any information about an identifiable individual such as name, age, home address and phone number, social insurance number, marital status, income, or credit history. Personal information does not include contact information (described below) when that contact information is used for contacting an individual in their capacity as an employee of an organization.

"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 McCoy complies with this Policy and PIPA.

"Assistant Privacy Officer" – means the individual designated responsibility for the practical application of this Policy and PIPA.

Collecting Personal Information

Unless the purposes for collecting personal information are obvious and the customer voluntarily provides his or her personal information for those purposes, McCoy will communicate the purposes for which personal information is being collected, either orally or in writing, before or at the time of collection.

The Corporation will only collect customer information that is necessary to fulfill the following purposes:

verify identity;

verify creditworthiness;

report to and obtain reports from credit bureaus;

identify customer preferences;

understand the financial, banking, insurance needs of our customers;

open and manage an account;

deliver requested products and services

ensure a high standard of service to our customers;

retain a contractor or agent who will perform services for us on an outsource or contract basis.

Consent

McCoy will obtain the customer’s consent to collect, use or disclose personal information (except where, as noted below, McCoy are authorized to do so without consent).

Consent can be provided orally, in writing, through an authorized representative or it can be implied where the purpose for collecting using or disclosing the personal information would be considered obvious and the customer voluntarily provides personal information for that purpose. McCoy typically obtain a customer’s consent through their signature on a credit application form.

Consent may also be implied where a customer is given notice and a reasonable opportunity to opt-out of the customers personal information being used for mail-outs or the marketing of new services or products, and the customer does not opt-out.

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), customers can withhold or withdraw their consent for McCoy to use their personal information in certain ways. A customer’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 customer in making the decision.

The Corporation may collect, use or disclose personal information without the customer’s, knowledge or consent in the following limited circumstances:

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;

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

When the collection, use or disclosure of personal information is otherwise permitted or required by law.

Using and Disclosing Personal Information

McCoy will only use or disclose customer personal information where necessary to fulfill the purposes identified at the time of collection or as indicated in Collecting Personal Information (above).

McCoy will not use or disclose customer personal information for any additional purpose unless McCoy obtain consent to do so.

McCoy will not sell customer lists or personal information to other parties.

Retaining Personal Information

If the Corporation uses customer personal information to make a decision that directly affects the customer, McCoy will retain that personal information for at least one year so that the customer has a reasonable opportunity to request access to it.

Subject to the preceding paragraph, McCoy will retain customer personal information only as long as is reasonable to fulfill the identified purposes or a legal or business purpose.

Ensuring Accuracy of Personal Information

McCoy will make reasonable efforts to ensure that customer personal information is accurate and complete where it may be used to make a decision about the customer or disclosed to another organization.

Customers 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. A request to correct personal information should be forwarded to the Assistant Privacy Officer.

If the personal information is demonstrated to be inaccurate or incomplete, McCoy will correct the information as required and send the corrected information to any organization to which we disclosed the personal information in the previous year. If the correction is not made, we will note the customer’s correction request in the file.

Securing Personal Information

McCoy is are committed to ensuring the security of customer personal information in order to protect it from unauthorized access, collection, use, disclosure, copying, modification or disposal or similar risks.

The following security measures will be followed to ensure that customer personal information is appropriately protected:

use of locked filing cabinets

physically securing offices where personal information is held

use of user IDs, passwords, firewalls

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

contractually or otherwise requiring any service providers to provide comparable security measures.

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

Upon request, McCoy will also tell customers how we use their personal information and to whom it has been disclosed if applicable.

Questions and Complaints

The Role of the Privacy Officer or designated individual is:

The Assistant Privacy Officer is responsible for the practical application of this Policy. The Privacy Officer is responsible for ensuring McCoy ’s compliance with this Policy and the Personal Information Protection Act.

Customers should direct any complaints, concerns or questions regarding McCoy ’s compliance in writing to the Assistant Privacy Officer. If the Assistant Privacy Officer is unable to resolve the concern, the customer may also write to the Information and Privacy Commissioner of Alberta.

Contact information for McCoy Corporation:

Privacy Officer – Peggy Robertson
Vice President, Corporate Affairs, Corporate Secretary
Suite 600, 5241 Calgary Trail NW,
Edmonton, Alberta
T6H 5G8