Sturgeon Refinery

Privacy of Personal Information Policy

North West Redwater Partnership (NWR) is committed to maintaining the accuracy, confidentiality and security of individuals’ personal information.  This Privacy of Personal Information Policy applies to the personal information of all individuals, unless the personal information is related to an individual who seeks to be, is or was employed by NWR.  Such information is dealt with in the NWR Privacy of Personal Information for Employees Policy.

Scope

This Privacy of Personal Information Policy covers those activities that are subject to the provisions of Canada’s federal and provincial privacy laws (as applicable).   If an individual is unsure if or how this Privacy of Personal Information Policy applies to her/him, she/he should contact our Privacy Officer for more information.

Personal Information

For the purposes of this Privacy of Personal Information Policy, personal information is any information about an identifiable individual, other than the person’s business title or business contact information when used or disclosed for the purpose of business communications.

Collection

NWR collects and maintains different types of personal information in respect of the individuals with whom we
interact, including:

  • contact and identification information, such as name, address, telephone number and e-mail address;
  • product and service related information concerning the products and services that we provide to, or receive from, the individual;
  • credit and financial information such as direct deposit and banking information;
  • business relationship information, including information related to agreements, preferences, advisors and decision-makers, feedback and information requested by, or provided to, an individual.

We may also collect market-related information, which may include personal information, concerning market trends and activities impacting our business.  This information may include contract terms, financial information and other information for the purpose of market analysis and strategic planning.  We may also collect information related to our media, investor and public relations activities and information related to our interactions with financial and other analysts and advisors.

NWR’s Run & Maintain operations include activities related to the processing and storage of crude oil and the treatment and upgrading of same; as such, NWR may also collect personal information from individuals participating in and/or impacted by those activities, including information related to obtaining permits and licenses, emergency planning and environmental stewardship.

As a general rule, NWR collects personal information directly from an individual.  In most circumstances where the personal information that we collect is held by a third party, we will obtain permission before we seek out this information from such source (such permission may be given directly by the individual, or implied from her/his actions).

From time to time, we may utilize the services of third parties in our business. We may also receive personal information collected by those third parties in the course of the performance of their services for us or otherwise.  Where this is the case, we will take reasonable steps to ensure that such third parties have represented to us that they have the right to disclose an individual’s personal information to us.

Where permitted or required by applicable law or regulatory requirements, we may collect information about an individual without her/his knowledge or consent.

Purpose

NWR collects personal information to enable us to manage, maintain, and develop our business and operations, including:

  • to establish, maintain and manage our relationship with individuals so that we may provide them with, or receive from them, the products and services that have been requested;
  • to be able to review the products and services that we provide to individuals so that we may understand requirements for our products and services and so that we may work to improve our products and services;
  • to be able to review the products and services that we obtain so that we may work with individuals and so that they may understand our requirements for such products and services;
  • to be able to comply with requests (for example, if an individual prefers to be contacted at a business or residential telephone number and she/he advises us of that preference, we will use this information to contact the individual at that number);
  • to enable us to undertake our environmental, health and safety activities, including incident planning, response and investigation:
    • to protect us against error, fraud, theft and damage to our goods and property;
    • to enable us to comply with applicable law or regulatory process (for example, we may collect personal information to satisfy the obligations imposed on us by our various regulators); and
    • any other reasonable purpose to which an individual consent.

Monitoring of our Plant and Equipment

In the course of conducting our business, we may monitor our facilities, plant and equipment. For example, some NWR locations are equipped with surveillance cameras. These cameras are generally in high-risk areas or plant sites. Where in use, surveillance cameras are there for the protection of employees and third parties, and to protect against theft, vandalism and damage to NWR goods and property. Generally, recorded images are routinely destroyed and not shared with third parties unless there is suspicion of a crime, in which case they may be turned over to the police or other appropriate government agency or authority.

This is not meant to suggest that all individuals visiting our facilities will in fact be monitored or their actions subject to surveillance.  It is meant to bring to an individual’s attention that such monitoring may occur and may result in the collection of personal information.

Use and Disclosure

We may use or disclose an individual’s personal information:

  • for the purposes described in this Privacy of Personal Information Policy; or
  • for any additional purposes for which we have obtained an individual’s consent to the use or disclosure of personal information.

We may use and disclose personal information without an individual’s knowledge or consent where we are permitted or required by applicable law or regulatory requirements to do so.

We may share personal information with our Team Members, contractors, consultants and other parties who require such information to assist us with managing our relationship with an individual, including third parties whose services we use to conduct our business.

In addition, personal information may be disclosed or transferred to another party during the course of, or completion of, a change in ownership of or the grant of a security interest in, all or a part of NWR or its affiliates through, for example, an asset or share sale, or some other form of business combination, merger or joint venture, provided that such party is bound by appropriate agreements or obligations and required to use or disclose personal information in a manner consistent with the use and disclosure provisions of this Privacy of Personal Information Policy unless an individual consents otherwise.

Further, personal information may be disclosed:

  • as permitted or required by applicable law or regulatory requirements;
  • to comply with valid legal processes such as search warrants, subpoenas or court orders;
  • as part of NWR’s regular reporting activities to its affiliates;
  • to protect the rights and property of NWR;
  • during emergency situations or where necessary to protect the safety of a person or group;
  • where the personal information is publicly available; or
  • with an individual’s consent.

Notification and Consent

We collect, use or disclose personal information where we have individuals’ consent to do so.  Depending on the sensitivity of the personal information, consent may be implied, deemed (using an opt-out mechanism) or express.  Express consent can be given orally, electronically or in writing.  Implied consent is consent that can reasonably be inferred from action or inaction.

Typically, we will seek consent at the time that we collect personal information.  In certain circumstances, consent may be obtained after collection but prior to our use or disclosure of personal information.  If we plan to use or disclose personal information for a purpose not previously identified (either in this Privacy of Personal Information Policy or separately), we will endeavour to advise the individual of that purpose before the use or disclosure.

As we have described above, we may collect, use or disclose personal information without an individual’s knowledge or consent where we are permitted or required to do so by applicable law or regulatory requirements.

An individual may change or withdraw consent at any time, subject to legal or contractual obligations and reasonable notice, by contacting our Privacy Officer using the contact information below.  All communications with respect to withdrawal or variation of consent should be in writing and addressed to our Privacy Officer.

We assume that, unless an individual advises us otherwise, she/he has consented to the collection, use and disclosure of personal information as explained in this Privacy of Personal Information Policy.

Storage and Protection

NWR endeavors to maintain physical, technical and procedural safeguards that are appropriate to the sensitivity of the personal information in question.  These safeguards are designed to prevent an individual’s personal information from loss and unauthorized access, copying, use, modification or disclosure.

The security of personal information is important to us: an individual should advise our Privacy Officer immediately of any incident involving the loss of or unauthorized access to or disclosure of personal information that is in our custody or control.

Updates

It is important that the information contained in our records is both accurate and current.  If an individual’s personal information changes during the course of NWR’s relationship with the individual, the individual should keep us informed of such changes.

In some circumstances NWR may not agree with the request to change the personal information and will instead append an alternative text to the record in question.

Access

If an individual would like to review her/his personal information, she/he should contact our Privacy Officer. Any such communication must be in writing.

When requesting access to personal information, an individual should note that we may request specific information from her/him to enable us to confirm her/his identity and right to access, as well as to search for and provide the personal information. We may charge a fee to access personal information; however, we will advise an individual of any fee in advance.  If an individual requires assistance in preparing her/his request, she/he should contact our Privacy Officer.

An individual’s right to access the personal information that we hold is not absolute.  There are instances where applicable law or regulatory requirements allow or require us to refuse to provide some or all of the personal information.  In addition, the personal information may have been destroyed, erased or made anonymous in accordance with our record retention obligations and practices.  In the event that we cannot provide an individual with access to her/his personal information, we will endeavour to inform the individual of the reasons why (subject to any legal or regulatory restrictions).

Inquiries

If an individual has any questions about this Privacy of Personal Information Policy or concerns about how we manage personal information, she/he should contact our Privacy Officer by telephone, in writing or by e-mail.  We will endeavour to answer questions and advise of any steps taken to address the issues raised.  If the individual is dissatisfied with our response, she/he may be entitled to make a written submission to the Privacy Commissioner.

Privacy Officer

We have appointed the Director – Human Resources as Privacy Officer to oversee compliance with this Privacy of Personal Information Policy. Contact information is as follows:

  • NWR Sturgeon Refinery, Director, Human Resources, Central Administrative Building (CAB)
  • PO Box 930, 56212 RR 220, Gibbons, Alberta T0A 1N0, (587) 469-6059

Revisions

NWR may make changes to this Privacy of Personal Information Policy to reflect changes in its legal or regulatory obligations or in the manner in which we deal with personal information.  We will post any revised version of this Privacy of Personal Information Policy on our website and also on our internal N: Drive, under Policies, Procedures & Controls.

Interpretation

Any interpretation associated with this Privacy of Personal Information Policy will be made by our Privacy Officer.  This Privacy of Personal Information Policy includes examples but is not intended to be restricted in its application to such examples, therefore where the word ‘including’ is used, it shall mean ‘including without limitation’.

This Privacy of Personal Information Policy does not create or confer upon any individual any rights, or impose upon NWR any rights or obligations outside of, or in addition to, any rights or obligations imposed by Canada’s federal and provincial privacy laws, as applicable. Should there be, in a specific case, any inconsistency between this Privacy of Personal Information Policy and Canada’s federal and provincial privacy laws, as applicable, this Privacy of Personal Information Policy shall be interpreted, in respect of that case, to give effect to, and comply with, such privacy laws.