Shell Lawyers Privacy Statement A) What is Personal Information? B) How do we collect your Personal Information? C) What limits do we put on the collection, use or disclosure of your Personal Information D) To whom do we provide your Personal Information? E) When and how do we obtain your consent? F) How do we use your Personal Information? G) What safeguards have we implemented to protect your Personal Information? H) How do we ensure the privacy of your Personal Information when dealing with third parties?  I)  How long will we utilize, disclose or retain your Personal Information? J) How can you access your Personal Information that we have collected, utilized or disclosed? K) How do you know that the Personal Information we have on you is accurate? L) What if the Personal Information we have on you is inaccurate? M) How fast will we respond to your written requests? N) Are there any costs to you for requesting information on your Personal Information or on our Privacy Policy or Practices? O) How do we know that it is really you requesting your Personal Information? P) How do you contact us regarding access to your Personal Information or making complaints? A) What is Personal Information? Personal Information is generally any information about an identifiable individual. The type of personal information Shell Lawyers collects, uses and discloses, with your consent, permitted and/or required by law, may include your name, age, mailing address, residential phone numbers or email address, personal history (including financial and credit information, personal health information, billing history, personal family and relationship matters, penal or criminal information), personal information related to your employment, work experience (past and present), conduct in the work place, income and other benefits, medical records, and tax records. Back to Top B) How do we collect your Personal Information? Shell Lawyers collects your Personal Information by fair and lawful means, including the Retainer Agreement, general correspondence, faxes, emails and telephone inquiries. We often collect Personal Information from you or from third parties and as agents on behalf of our clients, where we have obtained the requisite consent to do so (for example, upon a client's instructions) or as otherwise required by law. Third parties include, as examples, employers, union representatives, witnesses, service providers, references and other persons that we need to contact to provide services to and for clients, to establish, manage or terminate an employment relationship, or for administrative or management requirements. Back to Top C) What limits do we put on the collection, use or disclosure of your Personal Information? Shell Lawyers only collects the personal information necessary to fulfill the purposes identified to you prior to or at the time of collection, or any other reasonable and legitimate purposes or as required by law. Shell Lawyers does not, as a condition of supplying a service to you, or of establishing, managing or terminating an employment relationship, or as an administrative or management requirement, require consent to the collection, use or disclosure of personal information beyond that reasonably required for such purposes, or to comply with its obligations under applicable law. We do not use or disclose your personal information, except for the purposes for which it was collected, or new purposes to which you have consented, or as required or otherwise permitted by applicable law. Back to Top D) To whom do we provide your Personal Information? Shell Lawyers usually collects and uses your Personal Information for the following purposes: a) The personal information that you supply and we gather and keep in a file known as the "Client File". The personal information contained in this file is collected, used or communicated generally for the following purposes: i) collecting, recording and using the information relevant to the performance of the services rendered to and for you; ii) recording and determining your various services in your relationship with us; iii) administration, billing, accounting and collection in relation to your business and relationship with us; iv) protecting against fraud and error; v) communicating with you generally or to ensure your satisfaction; vi) communicating the information to a sub-contractor (or other agents or intermediaries) in the course of a contract or mandate for the performance of any of the purposes listed above, as well as; (b) to persons in our Firm for services rendered to and for clients, to establish, manage or terminate an employment relationship, and for administrative or management requirements, including building and maintaining the Firm's expertise and experience; (c) to other Professionals Firms, Government Agencies and any other organizations/enterprises, when required for services to and for clients, as well as for compliance and insurance obligations; (d) to third party service providers with whom we have a contractual agreement, which have comparable levels of privacy protection, for processing related to services rendered to and for clients, to establish, manage and terminate such contractual relationships, and for administrative or management requirements (such as, in all cases, for photocopying, printing and faxing, shredding, storage and other document management, payroll, I.T., including software maintenance, consulting services, investigations and searches, independent expert matters, collection, bailiffs and services); (e) such other disclosures of Personal Information to such persons for which you provide your consent; and (f) as otherwise required and permitted by law. When supplementary disclosure is required, we will identify (at the time we collect such information from you and obtain the requisite consent to such disclosure, unless otherwise permitted by law) the other persons/organizations/enterprises and the other purposes to whom and for which disclosure may occur. Back to Top E) When and how do we obtain your consent? Except when otherwise permitted by law, we obtain the requisite consent prior to collecting and, in any case, prior to using or disclosing your Personal Information for any purpose. You may provide your consent to us either orally or in writing. We will obtain your express consent as often as possible. Your consent may also be intrinsic to the circumstances such as in the case where you have already provided Personal Information to us and you maintain your relationship with us or where you provide our representatives with your phone number so that we can contact you at home. Except when otherwise permitted and/or required by law, we will only use the information for the purpose for which it was given. When your consent is required, you can withdraw consent at any time (unless withdrawing the consent would frustrate the performance of legal obligations), and upon providing us with a 30-day notice. However, the withdrawal of your consent may impact on our ability to serve you and to maintain our professional responsibilities. In certain circumstances, as permitted or required by law, we may collect, use or disclose Personal Information without your knowledge or consent. These circumstances include (where applicable): Personal Information which is subject to solicitor-client privilege; information on individuals which is publicly available; where collection or use is clearly in the interests of the individual and consent cannot be obtained in a timely way; to investigate a breach of any agreement or a contravention of a law; to comply with a subpoena, warrant, court order or as required or otherwise permitted by law. Back to Top F) How do we use your Personal Information? We collect your Personal Information primarily to provide services to and for clients, to establish, manage or terminate an employment relationship, or for administrative or management requirements, and to enhance our relationship with clients and employees. We do not sell client lists or other Personal Information. We may also use your Personal Information as otherwise permitted by law. Your Personal Information is kept in a file entitled "Client File" and an "Administrative File" for administrative or management purposes, including Personal Information for accounting, billing and collection, conflict of interests, recruitment, information technology ("I.T."), and secretarial service. We also use contact information in order to provide clients and others with publications, information, seminars and other communications that may be of interest including invitations to Shell Lawyers social activities. Back to Top G) What safeguards have we implemented to protect your Personal Information? Shell Lawyers is committed to protecting the security of personal information. We therefore use security safeguards appropriate to the sensitivity of personal information to protect it from loss or theft, as well as unauthorized access, disclosure, copying, use or modification. These safeguards include physical measures, such as restricted access to offices and equipment, organizational measures, such as publishing this policy to all Shell Lawyers' members and personnel with the strict instructions to act in accordance with its principles (for example, limiting access on a "need to know" basis) and technological measures, such as the use of passwords and/or encryption. The following are examples of the categories of personnel that may be considered as having the "need to know" for the Personal Information contained in a File: a) "Client File": the Firm's lawyers, including paralegals, articling students and students at law, as well as their support staff (including secretaries or assistants) for purposes of client work, precedents usage and other services to and for clients, and for compliance and insurance coverage, as well as the administrative staff and contract services from third parties (when necessary for technical and I.T. services, accounting, billing or collection matters or any other services to and for clients or for compliance and insurance obligations). Back to Top H) How do we ensure the privacy of your Personal Information when dealing with third parties? We remain responsible for all personal information communicated to third parties for processing. As such, we ensure that third parties which are engaged to perform services on our behalf and are provided with Personal Information are required to observe the intent of this Privacy Statement by having comparable levels of security protection or, when required, by satisfying our firms requirement (through a confidentiality agreement) that they will not use or disclosure the personal information for any other purpose but that for which the Personal Information was communicated. Back to Top I) How long will we utilize, disclose or retain your Personal Information? We may keep a record of your Personal Information, including correspondence or comments, in the applicable file specific to you. We will utilize, disclose or retain your Personal Information for as long as necessary to fulfill the purposes for which it was collected and as required or otherwise permitted by law. We will establish minimum and maximum retention periods and procedures for maintaining and destroying your Personal Information. We may utilize a third party contract service for the long-term storage of inactive Client Files. Back to Top J) How can you access your Personal Information that we have collected, utilized or disclosed? Subject to the exceptions provided by the applicable law, we will make available to you any specific Personal Information about you that we have collected, utilized or disclosed, upon your written request. We will make such information available to you in a form that is generally understandable, including explaining any abbreviations or codes and using an alternative format, if required. Simply send your request for access to the Privacy Officer listed below. Back to Top K) How do you know that the Personal Information we have on you is accurate? We will use every reasonable effort to ensure that your Personal Information is kept as accurate, complete and up-to-date as possible. We will not routinely update your Personal Information, unless such a process is necessary. In order to help us maintain and ensure that your Privacy Information is accurate and up to date, you must inform us, without delay, of any change in the information you provided to us. Back to Top L) What if the Personal Information we have on you is inaccurate? You can at any time, challenge the accuracy or completeness of the Personal Information we have on you, subject to the exceptions provided by the applicable law. If you successfully demonstrate that the Personal Information we have on you is inaccurate or incomplete, we will amend the Personal Information as required. Where appropriate, we will transmit the amended information to third parties to whom we have communicated your Personal Information. Back to Top M) How fast will we respond to your written requests? We will make every reasonable effort to respond to each of your written requests not later than thirty (30) days after receipt of such requests. When applicable, we will advise you in writing if we cannot meet your requests within this time limit. When applicable, you have the right to make a complaint to the appropriate Privacy Authority in respect of this time limit. Back to Top N) Are there any costs to you for requesting information on your Personal Information or on our Privacy Policy or Practices? Access to your Personal Information contained in a file is free of charge. However, a reasonable charge may be required when you request the transcription, reproduction or transmission of such information. We will notify you, following your request for transcription, reproduction or transmission, of the appropriate amount that will be charged. You will then have the opportunity to withdraw your request. Back to Top O) How do we know that it is really you requesting your Personal Information? We may request that you provide sufficient identification to permit access to the existence, use or disclosure of your Personal Information. Any such information shall be used only for this purpose. P) How do you contact us regarding access to your Personal Information or making complaints? Back to Top