The privacy of our employees, customers, and the general public is very important to us.  It is also important to us that you understand the purposes for which we collect personal information and our approach to consent.

Why a privacy policy?

The purpose of our privacy policy is to govern the collection, use and disclosure of personal information by organizations in a manner that balances people’s right of privacy on the one hand, with the needs of organizations to collect, use or disclose personal information for a reasonable purpose.  This was considered necessary in light of the expanding use of the internet and other technologies which allow companies to easily circulate information.

Our privacy practices are consistent with Canada’s federal privacy legislation, the Personal Information Protection and Electronic Documents Act (PIPEDA).  This legislation also fills Canada’s international obligations for privacy legislation as well.

What is personal information?

The definition of “personal information” is quite broad and generally includes any information about an identifiable individual.  It does not include the name, title or business address or telephone number of an employee of an organization.  For example, sharing an employee’s home phone number with a customer is not ok; sharing the office number of a broker representative with a distributor customer is.

Why do we collect personal information?

We collect personal information to manage and develop our business and operations, including personnel and employment matters; and to meet legal and regulatory requirements.

These two general purposes include the following specific purposes for which we collect
personal information about our employees:

1. To manage, develop and retain a highly-skilled, professional, and productive workforce that supports our business success.  For example, we collect personal information about employees to make staffing and employee development decisions, to measure and reward performance, and to assess our ability to meet our business objectives.
2. To administer compensation and benefits programs.  For example, we collect and record personal information to administer automatic payroll deposits, manage our benefits programs and report pay and compensation information as required by the government.
3. To support the personal health and well-being of employees. For example, Sun Rich collects personal information when providing various health services to employees, such as medical assessment, and return to work assistance.  All health-related information collected by Sun Rich in the course of providing theses services is treated as highly confidential.
4. To provide a safe and respectful workplace as required by law and Sun Rich policies. For example, we keep records of safety incidents, hazardous occurrences, accidents and injury reports in order to provide a safe work environment and comply with the law.
5. To protect and manage corporate assets.  For example, we monitor employee use of our networks (e-mail and Internet).
6. To meet legal and regulatory requirements.  For example, we report pay and compensation information as required by the government.

When do we disclose personal information?

There are a variety of circumstances in which we disclose some personal information about employees.

Here are some examples:

1. To administer compensation and benefits programs, we disclose employee information to financial institutions, insurance providers, government departments and agencies such as the Canada Revenue Agency (formerly Revenue Canada).
2. To administer personal health and well-being programs, we disclose personal information to the BC Workers’ Compensation Board, ON Workplace’ Safety Insurance Board or health professionals.
3. When required by law, or contractual obligations, we may disclose employee personal information to HRDC, creditors or the Provincial Human Rights Commissions.

How do we protect personal information?

All personal information is collected in a fair and non-intrusive manner, with your voluntary consent.  Personal information is not accessible to anyone outside the specific function for which it is collected.  Sun Rich respects the privacy of our customers, employees, job applicants, and other visitors to our websites who may choose to provide personal information.  We recognize the need for appropriate precautions and management of personal information that you provide us.  In order to protect your personal information and your right to privacy, Sun Rich:

• will not collect, use or disclose your personal information for any purpose other than those identified above, except with your consent;
• will protect your personal information with appropriate security safeguards;
• will protect the confidentiality of your personal information when dealing with other companies;
• will strive to keep your personal information as accurate and up-to-date as is necessary for the purposes identified above; and
• will respond to any request you may make for access to your personal information.

Employee Consent

The acceptance of employment and benefits by an employee is viewed as consent for Sun Rich to collect, use, and disclose personal information about the employee for the purposes identified above.

The new privacy legislation gives employees the right to withdraw consent, at any time, subject to legal or contractual restrictions and reasonable notice.  This right protects employees from having their personal information collected unnecessarily or for an unreasonable purpose.

Sun Rich views the purposes identified in this statement as reasonable and necessary to manage our business effectively.  Therefore, Sun Rich will continue to collect, use and disclose personal information for these purposes.  However, you may choose to withhold some personal information by not participating in optional programs, such as the Employee Benefit Program.

How do I find out more information?

This privacy policy explains Sun Rich’s practices regarding personal information collected and can be found at http://www.sun-rich.com/about-us/ and internally on Sun Rich’s intranet, “The Wedge.”

You may also seek advice from the following resources:

• BC employees can contact the Office of the Information and Privacy Commissioner for BC at: 1-250-356-1851
• Ontario employees can contact the Office of the Privacy Commissioner of Canada at: 1-800-282-1376

Contact Information

You may contact the Privacy Officer to access, correct or delete your personal information.  If appropriate, the Privacy Officer may contact another employee(s) to assist in completing your request.

If you have any questions or concerns about Sun Rich privacy practices, contact our Privacy Officer, Leanne Johnson, Vice President of Human Resources, at 1-800-661-0087, 4703 or email at leannej@sun-rich.com or at the following address:

Privacy Officer
Sun Rich Fresh Foods Inc.
22151 Fraserwood Way
Richmond, BC  V6W 1J5

Sun Rich is responsible for protecting the confidentiality and security of personal information under its control.  Sun Rich has designated Leanne Johnson, Vice President of Human Resources, as Sun Rich’s Privacy Officer. The Privacy Officer is accountable for the organization’s compliance with these principles.

Sun Rich will:

• Be responsible, by contractual or other means, for all personal information under its control, including personal information that is not in its custody. This includes personal information transferred to another organization for processing.
• Develop and implement policies and practices for the handling of personal information and make this information available to the public on request.
• Develop and implement a complaint process to handle complaints about our personal information practices and make this information available to the public on request.

We collect personal information to manage and develop our business and operations, including personnel and employment matters; and to meet legal and regulatory requirements. These two general purposes include the following specific purposes for which we collect personal information about our employees:

1. To manage, develop and retain a highly-skilled, professional, and productive workforce that supports our business success.  For example, we collect personal information about employees to make staffing and employee development decisions, to measure and reward performance, and to assess our ability to meet our business objectives.
2. To administer compensation and benefits programs.  For example, we collect and record personal information to administer automatic payroll deposits, manage our benefits programs and report pay and compensation information as required by the government.
3. To support the personal health and well-being of employees. For example, Sun Rich collects personal information when providing various health services to employees, such as medical assessment, and return to work assistance.  All health-related information collected by Sun Rich in the course of providing these services is treated as highly confidential.
4. To provide a safe and respectful workplace as required by law and Sun Rich policies. For example, we keep records of safety incidents, hazardous occurrences, accidents and injury reports in order to provide a safe work environment and comply with the law.
5. To protect and manage corporate assets.  For example, we monitor employee use of our networks (e-mail and Internet).
6. To meet legal and regulatory requirements.  For example, we report pay and compensation information as required by the government.

Sun Rich will:

• Ensure that the collection of personal information is necessary to fulfill the purpose(s) identified.
• Ensure that the purpose(s) is limited to what a reasonable person would consider appropriate in the circumstances.
• Inform the individual from whom the information is collected, either verbally or in writing, before or at the time of collection why the personal information is needed and how it will be used.
• On request by the individual, provide the name or title and contact information of a person within the organization who is able to answer questions about the collection of personal information.
• When using an individual's personal information that has already been collected for a new purpose not previously identified, inform the individual of the new purpose and obtain consent prior to its use.

Sun Rich will explain the reason for and obtain your consent before using your Personal Information for any other purpose other than listed above.  We will only collect, use and disclose your personal information with your consent, except where otherwise required or permitted by law.

The acceptance of employment and benefits by an employee is viewed as consent for Sun Rich to collect, use, and disclose personal information about the employee for the purposes identified above.

Employees have the right to withdraw consent, at any time, subject to legal or contractual restrictions and reasonable notice.  This right protects employees from having their personal information collected unnecessarily or for an unreasonable purpose.  You may choose to withhold some personal information by not participating in optional programs, such as the Employee Benefit Program.

Sun Rich will limit the collection of your personal information to only those details that are necessary for the purposes identified.  Sun Rich will collect personal information directly from the individual it is about unless the Act or the individual authorizes the collection of personal information from another source.

Sun Rich will only use your personal information for the purposed for which it was collected, unless you have consented otherwise, or when it is required or permitted by law.  Your personal information will only be retained for the time necessary to fulfill the purposes for which it was collected, and to meet any legal or regulatory requirements.

Sun Rich will keep your personal information as accurate, complete and up-to-date as possible to fulfill the purposed for which it was collected.  You can assist us in ensuring your records are current by providing us with any changes to your personal information, such as an address change.

Sun Rich will protect your personal information with appropriate security safeguards and will protect the confidentiality of your personal information when dealing with other companies or organizations.

Sun Rich will make available to you information about our policies and practices regarding the management of personal information.  If you would like more information or to access your personal information or to make a complaint about our personal information practices, please contact our Privacy Officer, Leanne Johnson.

Sun Rich will upon request,

1. Provide employees access to:

• their personal information,
• an explanation of how their personal information is and has been used, and
• a list of any individuals or organization to whom their personal information has been disclosed.

2. Correct personal information:

• Sun Rich will correct personal information that it verifies is inaccurate or incomplete,
• If a correction is made, will send a copy of the corrected personal information to each organization to which the incorrect or incomplete information was disclosed in the past year,
• If no correction is made in response to an individual’s request, make a note to indicated that a correction was requested but none was made.

Sun Rich employees may contact our Privacy Officer, Leanne Johnson, Vice President Human Resources, with any questions, concerns, or suggestions with respect to our privacy principles and practices.  Leanne can be reached at 1-800-661-0087, 4703 or leannej@sun-rich.com

All complaints will be investigated and appropriate measures to correct information handling practices and policies will be taken.

You may also seek advice from the Offices of the Privacy Commissioners:

• BC employees can contact the Office of the Information and Privacy Commissioner for BC at: 1-250-356-1851
• Ontario employees can contact the Office of the Privacy Commissioner of Canada at: 1-800-282-1376

Sun Rich will not collect customer personal information unless the customer contacts Sun Rich directly. In order to adequately address a customer’s concern or questions, their personal information may be shared with other employees for the expressed purpose of addressing the concern or question.

This policy is to establish standards with respect to how e-mail and the Internet can be used at Sun Rich, and what type of material can be downloaded and transmitted.  It also outlines the disciplinary measures that will be taken if this policy is violated.

Electronic mail or e-mail refers to a system that allows creating, editing, sending, receiving, forwarding, printing, filing, and deleting electronic messages within Sun Rich and/or the Internet.

Internet refers to the public, global network of public and private computers and networks that provides worldwide access to computer, information databases, computer file transfer mechanisms, electronic mail and on-line discussion groups.

For the purposed of this document, use of e-mail, the Internet refers to access through Sun Rich technology systems.

Personal information means recorded information about an identifiable individual.

This policy applies to all employees of Sun Rich.

1. Use of e-mail and the Internet should be predominantly for business-related purposes.
2. Employees are required to ensure that their personal interests in using e-mail and the Internet do not conflict with or appear to conflict with their duties and Sun Rich policies and procedures.  Therefore personal usage should be restricted to non-work hours.
3. The following are unacceptable uses of e-mail and the Internet:
   
   • view, duplicate, store or transmit nudity or pornographic materials
   • transmit or post threatening, abusive or obscene material
   • operate a personal business
   • defamation
   • destroying or altering data
   • disclosing data – especially electronic information or records containing personal information
   • encryption exports:  exporting encryption software, putting it on the Internet without an export permit
   • fraud – misusing passwords, encryption keys, computer service accounts, eg., obtaining money, goods or services through false representation made on a computer system
   • gambling
   • hacking and trafficking:  making, possessing or distributing computer programs that are designed to assist in obtaining unlawful access to computer systems
   • harassment and threats – harassing other persons electronically
   • hatred:  willfully promoting hatred against an identifiable group
   • intellectual property:  breaching intellectual property rights
   • interfering with computer systems:  damaging or interfering with others’ lawful use of data and computers, eg., spreading viruses with intent to cause harm
   • misrepresentation:  fraudulent or negligent misrepresentation
   • privacy invasion:  intercepting private communications and unlawfully obtaining access to personal information.
4. You agree to comply with all reasonable rules and restrictions that Sun Rich may impose on the use of computers, e mail and Internet access.  In particular you acknowledge that:

• Sun Rich Right of Access:  Information stored or transmitted on Sun Rich's computers systems, including E-mail, is not private to you.  All information stored or transmitted on Sun Rich's systems is, and remains at all times, the property of Sun Rich.  Sun Rich reserves the right, at all times, and without prior notice to you, to access any information, data, file, or E-mail message on any of Sun Rich's information systems.  As a result, you have no expectation of privacy with respect to this information.
• Monitoring of Computer Use:  The use of Sun Rich's computer systems may be monitored.  You must understand that information created, stored, or transmitted by Sun Rich's computer systems, including information you might consider personal, is available for review by authorized Sun Rich representatives for any purpose.  Please note that even when an E-mail message or other computer file is erased, it may be possible to recreate the message or file.
• Passwords:  It is your responsibility to keep your password(s) secret. You may not share your passwords(s) with anyone, and you are responsible for all activity performed with your personal user ID or password.
• Protecting Sun Rich Information: You are responsible for protecting Sun Rich's information and must follow company guidelines for the appropriate use, storage, transmittal, and destruction of company information.  This includes information stored on, or transmitted by, the company's computer systems.  Sun Rich's trade secrets, work product including any software files and confidential information should never be transmitted or forwarded to outside individuals or companies not authorized to receive that information and should not be sent or forwarded to other employees inside the company who do not need to know the information.  IF YOU ARE UNCERTAIN WHETHER YOU ARE AUTHORIZED TO SEND OR FORWARD SUCH INFORMATION, YOU SHOULD CHECK WITH YOUR SUPERVISOR.
• Copying or Downloading of Software: Only software for which all applicable license fees have been paid may be installed on Sun Rich's computers and networks.  You are encouraged to have the software loaded by the I.T. Department or other designated personnel.  You may not copy software without the written permission of the owner.   Please be aware that using non-standard software, not reviewed at a project level by your department, can compromise the efficiency and integrity of the systems chosen by Sun Rich.  You should only use software deemed acceptable by Sun Rich for its business use.  Sun Rich’s computer systems are not to be used to copy and/or transmit documents, software, or other information protected by copyright laws, without written permission of the copyright owner.

1. Employees are responsible for their own use of e-mail and the Internet.  If an employee is unclear whether certain usage is acceptable or not, the employee should discuss this with their supervisor.
2. When an incident of improper use of e-mail or the Internet occurs, Human Resources will investigate the situation fully.
3. Subject to the investigation and the nature of the incident, violation of this policy may result in disciplinary action up to and including dismissal.

Sun Rich will update this privacy policy occasionally to ensure compliance.  Sun Rich encourages you to review our privacy policy periodically to be informed as to how Sun Rich is protecting your information and to be aware of any changes to our policy.

Policy Effective Date:  January 1, 2004
Updated:  September 26, 2012