The purpose of this policy is to outline the basic practices and procedures of inVentiv Health Canada ULC, operating as inVentiv Commercial Services Canada relating to the collection, disclosure, use and safeguarding of personal information.

Policy Statement

Philosophy regarding Personal Information

inVentiv Health respects the privacy of personal information in all aspects of our business. We want everyone to know that we are responsible for the privacy of personal information of a variety of individuals throughout the course of the services we provide. In this regard, we have specifically designated a Chief Privacy Officer (“CPO”) who is accountable for compliance with the procedures and principles that will be explained in this Personal Information Policy. This policy is designed to formalize our existing practices regarding the collection, disclosure, use and safeguarding of personal information.

Definitions

In this policy,

“Act” means the Personal Information Protection and Electronic Documents Act,

“collect” means to gather, receive or record personal information about an individual from any source and by any lawful method;

“consent” means the voluntary agreement with the collection, use and disclosure of personal information for authorized purposes. Consent can be either express or implied and can be provided directly by the individual or by an authorized representative. Express consent can be given orally, electronically or in writing, and is your firm authorization. Implied consent is a common sense conclusion that consent has been obtained from an individual’s action or inaction.

“disclose” means to making personal information available to a third party.

“individual” or “individuals” means a prospective temporary applicant, temporary employee, prospective salaried applicant, salaried employee, prospective permanent placement candidate, a permanently placed candidate, a prospective independent contractor, an independent contractor, a prospective subcontractor or a subcontractor as defined in this policy below.

“prospective temporary applicant” means an individual who has contacted or provided information to inVentiv Health with an interest in temporary work with inVentiv Health’s clients but is not an employee with inVentiv Health or any of its clients.

“temporary employee” means an individual who is an employee of inVentiv and who has been placed in a temporary assignment with one of inVentiv Health ’s clients but remains a inVentiv Health employee.

“prospective salaried applicant” means an individual who is in contact with inVentiv Health with a view to obtaining a salaried position with and performing work for inVentiv Health.

“salaried employee” means an individual who has accepted a salaried position with and is an employee who is performing work for inVentiv Health.

“prospective permanent placement candidate” means an individual who is in contact with inVentiv Health with a view to being placed in a permanent position with one of inVentiv Health ’s clients but is not an employee with inVentiv Health or any of its clients.

“permanently placed candidate” means an individual who has been permanently placed as an employee with one of inVentiv Health’s clients and is not an employee of inVentiv Health. .

“prospective independent contractor” means an individual who has applied for an independent contracting position but has not been engaged in that position.

“independent contractor” means an individual who has been engaged in an independent contracting position.

“personal information” means any information about an identifiable individual but does not include:
Your name;
Your job title;
inVentiv Health’s business address; and
inVentiv Heath’s telephone number.

“third party” means an individual or organization outside of inVentiv Health .

“use” means the treatment and handling of personal information by or on behalf of inVentiv Health .

Why Personal Information Is Collected, Used, Disclosed or Retained

As outlined earlier, based on the nature of our business, we regularly collect, use disclose and retain personal information about individuals in order provide individuals with suitable temporary, permanent or contract employment opportunities. In order that all individuals are fully informed, we are outlining the purposes for which inVentiv Health has always collected, used, disclosed and retained personal information.

Thus, the purposes for which inVentiv Health may collect, use, disclose and retain personal information about individuals may include:
Assessing the suitability of individuals for a particular job or task;
Negotiating and making offers of employment or temporary assignment to selected individuals as applicable;
Verifying an individual’s identity;
Verifying and understanding an individual’s skills, qualifications, and preferences;
Contacting an individual’s employment references;

Establishing an individual’s training requirements or career transition measures; In connection with the administration of inVentiv Health ’s employee benefit plans, including but not limited to medical plans, retirement savings plans and payments;

In connection with medical or health matters related to an employee’s job requirements as well as illness(es) or injury(s) of an employee that affects their work, including occupational health and safety complaints;

Supervising, managing and providing remuneration to employees; Recording significant events during the application process and the employment relationship; Monitoring use of inVentiv Health ’s property and equipment, including telephone, facsimile, Internet and e-mail use and access; Maintaining a safe workplace; For any post-employment or post-temporary service provision matters, including providing of references to prospective employers; Complying with the law, regulatory requirements, and court orders; Complying with tax requirements; For due diligence review purposes in connection with any purchase or sale regarding inVentiv Health; and Assessing and developing inVentiv Health’s business and operations to better service its temporary and salaried employees and clients. At or before the time of collecting such information, inVentiv Hea will identify the purposes for which it is being collected. The collection of personal information will be limited to that which is necessary for the purposes identified by inVentiv Health. Information shall be collected by fair and lawful means.

What Kind of Personal Information Does inVentiv Health Collect and From Where Is It Collected?

The personal information collected by inVentiv Health about you as an individual, as applicable, may include, but is not limited to:

Your name, your job title, your invent Health business address and your inVentiv Health telephone number;

Your home address, home telephone number, education, training, work experience, employment history and references;

Your length of service, promotions, transfers, salary, benefits, perquisites, and other related information;

Information necessary for the administration of payroll, group insurance plans and benefit plans such as the individual’s social insurance number;

Your employment or temporary staffing records, including performance evaluations, severe allergies or medical conditions which relate to your ability to perform the bona fide duties of your position;

Information required for security purposes and any information required by law; inVentiv Health may gather personal information about you from a number of sources including:

From you, including from resumes, educational records, references, applications or forms completed by you for employment or temporary staffing arrangements, interviews, face-to-face discussions, telephone communications, e-mail and other correspondence;

From your agents, brokers, intermediaries, and representatives, as well as from government and other entities.

Consent

The knowledge and consent of an individual is required for the collection, use, or disclosure of personal information, except where otherwise not required under the Act. As an individual, when you applied for or accepted employment or a temporary staffing assignment, you were understood to have provided inVentiv Health with your implied consent to inVentiv Health 's collection, use, disclosure and retention of your personal information for the purposes identified to you under this policy.

In determining the appropriate form of consent, inVentiv Health will take into account the sensitivity of the personal information and the reasonable expectations of individuals.

Where your personal information is transferred to a third party for payroll, benefit administration, or other purposes, inVentiv Health uses contractual arrangements to provide a comparable level of protection of your personal information.

We accept any of the following as your consent for inVentiv Health’s existing use and future collection, use and disclosure of your personal information for the purposes identified above:

Your receipt of this Personal Information Policy, unless you advise inVentiv Health, either orally or in writing, that you do not agree with the terms stated in this Policy, and that you wish to opt out of all or portions of it;

Your implied consent such as your unrestricted release of information to inVentiv Health either directly, or through its authorized representatives;

Your express written or oral consent; or

Your consent as provided by your authorized representative, such as a legal guardian or power of attorney.

Use, Disclosure and Retention of Personal Information

Your records are retained to document personal, confidential and business-related information about you and your relationship with inVentiv Health.

inVentiv Health will use or disclose your personal information only for the purposes for which it is collected, except with the consent of the individual or as required or permitted by law.

inVentiv Health shall retain personal information only as long as required to satisfy the purposes identified above, to comply with any obligations specified in the Act, or other statutes, to meet any potential obligations, and to protect the interests of inVentiv Health and its clients.

inVentiv Health shall make reasonable arrangements for the disposition of records containing personal information in consultation with senior management when such information is no longer required.

Accuracy and Protection of Personal Information

inVentiv Health will attempt to keep personal information as accurate, complete and up-to-date as is necessary for the purposes for which it is used.

In addition, whether in electronic or paper-based format, inVentiv Health maintains strict security systems to safeguard your personal information as is appropriate in respect of the sensitivity of that information.

Access to Personal Information

Upon request, inVentiv Health will make specific information about its policies and practices relating to the management of personal information readily available to individuals.

You may access your personal information that inVentiv Health has in its possession, subject to any statutory exceptions or restrictions. To obtain access to your personal information, please make a written request to inVentiv Health’s CPO stating as specifically as possible which personal information you are requesting access to. The CPO will respond to a written request for access in a timely manner in accordance with the provisions of the Act.

Depending on the personal information requested, copies of your personal information not subject to any restrictions may be provided to you upon payment of an administrative fee.

You shall be able to challenge the accuracy and completeness of the information disclosed and have it amended as appropriate. Alternatively, you may require that a statement of disagreement be attached to the information reflecting any correction that was requested but not made. For more information on the procedures for doing so, please contact the CPO as noted below.

Formal Resolution

Formal Resolution Process

Filing A Complaint:
If you believe that inVentiv Health, its agents, and/or its employees have improperly or without authorization collected, used, disclosed or retained personal information about you contrary to this policy you must make a written complaint to the inVentiv Health’s CPO.

Your written complaint is to set out in as much detail as possible regarding your concerns and should contain the following information:

The conduct that you perceive as contrary to this policy.

The dates of, times and locations where such conduct occurred, including whether there was a single occurrence, numerous incidents and whether such conduct is ongoing.

A list of any witnesses, if any, to such behavior.

The name of the person(s) who engaged in such conduct.

Any actions that you have taken to address such conduct as well as any response to your actions.

Investigation:
Once a formal written complaint is made, inVentiv Health will address your concerns. All written complaints will be investigated, as appropriate, in a timely manner.

The respondent will be given an opportunity to respond to your complaint.

Conclusion of Investigation:
Upon completion of the investigation, you, as the complainant, will be advised of the results of the investigation.

If it is determined that your complaint is valid, appropriate measures shall be taken by inVentiv Health and you will be advised of such action.

Under this policy, every inVentiv Health employee has the right to pursue a complaint under this policy without actual or threatened reprisal or retaliation. If you are not satisfied with the response from the CPO, you may have recourse to the Federal Privacy Commissioner, the Information and Privacy Commissioner of Ontario, or the Quebec Information Access Commission, as applicable.

Inconsistency or Conflict

If there are any inconsistencies or conflicts between this inVentiv Health Personal Information Policy and that of any other document that you received from inVentiv Health, including the employee handbook, then the terms of this policy prevail.

Chief Privacy Officer

For more information, to request access to or amend to your personal information, or to discuss a complaint, please contact the CPO at:

Dureen Tseu – Director of Operations Tel: 416-390-2323; e-mail: dtseu@inVentiv Healthi; Cell: 416-318-8352.