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Privacy Policy

The objective of our Privacy Policy is to ensure the protection of Northwest employees' Personal Information. This includes Personal Information residing within Northwest and Personal Information provided to other third parties in the conduct of commercial activities.

HOW WILL PERSONAL INFORMATION BE COLLECTED?

During your initial meeting upon joining the company, Northwest shall inform you of the purposes for which Personal Information is collected, either at the time or before the information is collected.

OBTAINING CONSENT

You can provide consent to the collection, use and disclosure of your Personal Information expressly or consent may be implied by your actions. If oral express consent is given, Northwest and/or intermediaries will document and/or record the conversation, specifically the name, date, and details of the conversation in either hard or soft copy within the appropriate employee file, administration file or claim file documentation in order that it may be easily located and accessed should this be necessary.

When your Personal Information is sensitive, Northwest shall obtain your express written consent before using it.

DISCLOSURE WITHIN NORTHWEST

Northwest may internally share your personal information for the purposes identified in this policy with its affiliates or other related companies outside of Canada. Only such companies with legitimate business reasons will have access to your Personal Information and must ensure that Personal Information in their possession is securely held.

DISCLOSURE TO THIRD PARTIES

We may disclose your Personal Information to: third parties, which include brokers, agents, private investigators, lawyers and adjusters. Third parties may also be subject to applicable privacy legislation. Only those companies or individuals who are authorized, based on their need to carry out work for Northwest, can have Personal Information disclosed to them.

Furthermore, should Northwest and/or any of its member companies become involved in any business transaction including purchase, sale, merger, amalgamation or financing arrangement, pertaining to any of its business assets, your Personal Information may need to be shared with applicable third parties to complete such a transaction.

WITHDRAWING YOUR CONSENT

Subject to certain legal and contractual restrictions and reasonable notice, you may refuse or withdraw consent to the collection, use or disclosure of Personal Information at any time by notifying our Privacy Officer in writing.

RETENTION PERIODS

Northwest shall protect Personal Information by establishing and operating security safeguards appropriate to the sensitivity of the information, which is held, and to prevent any unauthorized activity relative to the information.

The retention periods for Personal Information are consistent with Northwest's Record Retention Policy and Schedule, which in turn meets provincial legislation requirements.

Your Personal Information will only be retained for as long as necessary for Northwest to serve you or as long as may be required for legal purposes. As soon as any of the Personal Information reaches its maximum retention period, it is either destroyed, made anonymous, or archived from operating systems to a secured, limited access site.

Personal Information that still serves an identified purpose may be retained indefinitely provided that it is archived outside of the regular operating environment with more restrictive accessibility.

DESTRUCTION OF INFORMATION

All Personal Information that is no longer required for its original purpose and has been retained for the minimum required term shall be destroyed, erased, made anonymous, or archived to the secure limited access site.

May 21, 2019


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