EMPLOYEE PRIVACY POLICY

Royal Legacy
_____________________________________ (the “Company”) is committed to protecting the

privacy of its employees. As part of this commitment, we have prepared this Policy, which

explains how the Company collects, uses, discloses and otherwise manages the personal

information of its employees.

I. Scope of the Policy

This Policy applies to all Company employees and any contractor who provides any service to

the Company and who, in the course of fulfilling his or her contractual duties to the Company,

engages in collecting, using or disclosing personal information on behalf of the Company.

II. Definition of Personal Information

Personal information means information about an identifiable individual, such as a person`s

name, date of birth, home address, home phone number, social insurance number, family status

or income. Personal information does not include business contact information or work

product information (i.e., information that is prepared or collected by an employee as part of

that employee`s work responsibilities, but does not include personal information).

III. Purposes for Collecting and Using Personal Information

The Company collects, uses and discloses employee personal information for purposes of

establishing, maintaining, managing or terminating the employment relationship. By way of

example, the Company may require employee personal information for the following purposes,

among others:

 to determine suitability for employment or promotion;

 to review and evaluate performance;
 to monitor attendance and use of company resources and property;
 to determine eligibility for salary increases, bonuses and other incentive-based
compensation;

April 2017 1
 to administer benefit programs;
 to investigate suspected misconduct or non-performance of duties;
 to determine physical and/or mental fitness for work; and
 to comply with statutory requirements (e.g. Income Tax Act, workers’ compensation and
labour and employment standards) and the agencies and governmental bodies
administering those statutes.

The personal information required to administer the employment relationship varies with each

individual employee. Examples of the types of personal information that the Company may

require about employees include:

 Name  Workplace accidents

 Age/date of birth  Promotion/demotion
 Social insurance number  Service, including breaks in service
 Home address  Vacation and leaves of absence
 Gender  Payroll and salary
 Marital and family status  Bonus
 Emergency contact information  Medical information including
 Previous work history and information supporting medical
references leaves of absence, and information
 Educational background respecting fitness for work and
 Information regarding job-related physical limitation
skills
 Performance evaluations
 Attendance
 Discipline

The Company will not collect, use or disclose employee personal information except for a

legitimate purpose in the employment relationship. Further, the Company will not gather

more personal information than is necessary to meet its purpose.

IV. Disclosure of Personal Information

The Company will not disclose an employee’s personal information to any third party without

the employee’s consent, except as permitted or required by law, or as otherwise required to

April 2017 2
administer the employment relationship (e.g. a payroll or benefit plan administrator/processor).

In the case of a transfer of personal information to affiliates or third party

administrators/processors, the Company will ensure that such affiliates/and or third parties

have contractually agreed to safeguard the personal information and to use the information

only for the purpose for which it has been provided.

Please note that in the event that a third party to whom the Company discloses employee

personal information is located outside Canada, local laws may otherwise allow that

information to be accessed by third parties without the consent of the employee concerned.

There are circumstances in which an employee’s consent is not required before personal

information can be collected, used or disclosed. For example, it is permissible for an employer

to collect, use or disclose employee personal information without consent if it is reasonable for

the purposes of establishing, managing or terminating the employment relationship with the

individual. Likewise, an employer may collect personal information without consent for the

purpose of investigating a breach of an agreement or a contravention of a law. It is also

permissible for an employer to disclose personal information without consent in response to a

search warrant or other legally valid enquiry or order, or where required to do so by law. Your

personal information may also be disclosed where necessary in connection with a sale of assets,

merger or other corporate restructuring.

V. Retention of Personal Information

The Company will retain employee personal information only as long as necessary to fulfil the

purposes for which it was collected, or as required by law. Some personal information may

have continuing relevance while other information may become dated and meaningless with

the passage of time. Employment standards and income tax legislation require an employer to

maintain certain records for a specified period of time.

April 2017 3
The Company retains information that has been considered in any decision that directly affects

an employee for at least one year after the decision is made. For example, the Company may

keep information that has been relied in the decision to discipline, terminate or deny an

employment opportunity or benefit for one year or more after the decision is made. Otherwise,

the Company aims to keep its files current and will make reasonable efforts to remove from the

personnel files information that is no longer relevant for the purposes for which it was collected.

When such information is removed from the employee file, it will be destroyed in a manner that

will ensure that the information is no longer identifiable.

VI. Accuracy of Personal Information

The Company requires accurate, complete and up-to-date records of its employees’ personal

information in order to make employment-related decisions effectively. If you are aware that

your personal information needs to be updated or corrected, please let us know.

VII. Security of Personal Information

The Company safeguards the security of personal information in its custody and control by

means that are reasonable, having regard to the sensitivity of the information, the purpose for

which it is to be used, the quantity and distribution of the information, and the medium on

which it is stored. Your personal information will only be accessed by employees and third

party administrators on a ``need-to-know basis``. Further, the Company will use reasonably

secure methods whenever it destroys personal information.

VIII. Individual Access to Personal Information

Andre Zahrebelny
An employee may submit a written request to ________________________ to access, correct or

update his or her personal information, and obtain an explanation of the Company’s use and

disclosure of the personal information. The Company will respond to the request within thirty

(30) days.

April 2017 4
If access to any or all of the information cannot be given because of cost, legal or security

reasons recognized by applicable privacy legislation, the employee will be advised.

Upon reviewing his or her personal information, the employee may request the Company to

modify or remove any inaccurate or unnecessary personal information on file. If the Company

does not agree that the modification or removal is necessary or warranted, the employee may

provide a written statement of his or her concerns, which will be included in the employee’s

personnel file.

IX. Complaint Procedure

We are committed to maintaining the privacy of employee personal information in the course of

administering our duties as an employer. If you have any questions or concerns about this

Employee Privacy Policy or about how we or any third party treat your personal information,

you may contact Andre Zahrebelny

_______________________ with your questions or concerns. We will

investigate any complaints and endeavor to resolve employee concerns.

Employees may have a right to file a complaint with a provincial privacy commissioner’s office

in those jurisdictions with applicable privacy legislation if the employee is not satisfied that the

employer is acting in compliance with the legislative requirements. In any event, no employee

will be penalized or disciplined for asserting a right under this policy.

Rashi

April 2017 5