In the course of its commercial activities and, in particular, providing services to its clients, HRA ("HRA") collects personal information about its clients, its employees and others. This information may be used for contact purposes, for general human resources purposes and, more broadly, to communicate with our clients and others respecting consulting affairs relevant to them and, more specifically, the services that we provide.

When we are retained to act on behalf of a client, we use, retain and disclose personal information on behalf of, and as instructed by, that client in connection with our advice. Our use, retention and disclosure of such information is governed by our duty of confidentiality to our client.

HRA recognizes the importance of protecting the personal information that it holds respecting its clients, employees and others. This policy outlines the framework of HRA's policies and procedures regarding its collection, use, retention and disclosure of personal information in respect of its clients and others and supplements, where applicable, our professional obligations of confidentiality.

Our privacy principles only apply to personal information about identifiable individuals.

Why Does HRA Collect Personal Information?

HRA collects personal information to provide consulting services and products to its clients. In addition, we may produce newsletters, papers and hold seminars concerning consulting developments, which we provide as a service to our clients and others in the business community.

How do we Use your Information?

HRA may use your personal information for the following purposes:

• to provide consulting services
  
• for billing, record-keeping and other client contact and service matters
  
• to assess new clients' eligibility for credit
  
• for audit and record-keeping purposes
  
• for account collection purposes
  
• to manage and develop its business and operations
  
• to learn about the needs of current and potential clients, to develop or offer services and products
• tailored to those needs and to communicate with those clients regarding current and future products and services
  
• to follow up on client comments and suggestions

Subscription Program

When you participate in our subscription program and provide us with your contact information in order to receive information in hard copy or electronic format, your information will be collected for the purpose of providing you with the specific information you requested. In addition, we may send you other information on consulting developments, upcoming seminars and general information in which you expressed an interest or that we believe will be relevant to you or your business. We do not sell, or share your subscription contact information with other parties, except as may be required by law.

Disclosure of your Personal Information

HRA will only disclose your personal information for purposes related to its providing of services to you, or with your express consent, or if required or authorized by law. For example, we may disclose your information:

• when the consulting services we are providing to you require us to give your information to third parties
  
• where it is necessary to establish or collect fees
  
• if we engage subject matter experts
  
• if we retain other consultants, on your behalf
  
• if a court issues a subpoena

Consent

We may obtain your consent to our collection, use and disclosure of your information either expressly, for stated purposes (such as in a retainer letter or by completing one of our client publications request forms), or impliedly when the purposes are not stated expressly but are indicated by the relevant circumstances or follow logically from other expressly stated purposes (such as providing our regular publications and updates in areas in which we have provided advice previously). You may withdraw or amend any consent previously given by contacting our Privacy Officer, subject to any legal or contractual restrictions and upon reasonable notice to us. For example, if you tell us that you no longer wish to receive our publications or information about our services, we will comply with your request.

Your consent to our collection of certain personal information may be required in order for us to provide consulting services. However, we will not require, as a condition of providing a service, that personal information not related to providing such service be collected.

Updating your Information

Since we use your personal information to provide consulting services to you, it is important that the information be accurate and up-to-date.

If any of your information changes, please inform us so that we can make any necessary changes.

Is my Personal Information Secure?

HRA uses appropriate security measures to protect against loss, theft, unauthorized access, disclosure, use or modification of personal information. Such measures will vary depending on the sensitivity, amount, format, nature and storage of the personal information and will involve, as applicable, physical, organizational and electronic security measures, including premises security, restricted file access to personal information, technological safeguards including security software and firewalls to prevent unauthorized computer access, and password and security policies.

HRA requires that third party service providers to whom personal information may be transferred provide a level of security for such personal information that meets standards established by HRA.

In communicating with us, you should be aware that e-mail is not a fully secure medium.

Access to your Personal Information

We will respond promptly to any request for access to your personal information. There will be no cost for reasonable requests to such access, unless you request copies of records or your request involves significant retrieval costs. We will advise you of the cost, if any, prior to the retrieval of such records or information.

In certain circumstances, we may be unable to provide access to some or all of the personal information that we hold about you. Such circumstances include those in which the personal information cannot be separated from the records of others, cannot be disclosed for reasons of personal security or commercial confidentiality or is protected by professional standards relating to confidentiality.

Correcting Errors

If we hold information about you and you advise us that it is not accurate, complete and up-todate, we will take appropriate steps to correct it.

Changes to our Privacy Policy

As part of our regular review of all of our policies and procedures, we may change our privacy policy from time to time.

Website

Our website may contain links to other sites, which are not governed by our privacy policy. On our website, as with most other commercial websites, we may monitor traffic patterns, site usage and related site information in order to optimize our web service. We may provide aggregated information to third parties, but these statistics do not include any identifiable personal information.

Questions, Concerns, Requests for Access

If you have any questions or concerns, wish to access your personal information or wish to change your preferences regarding our use of your information, please contact us: