In this policy “Personal Information” means any information about an identifiable individual or information that allows an individual to be identified.

At Penney & Brown Law we are committed to protecting the privacy of our clients, staff and those with whom we have professional relationships. The privacy and security of the personal information we collect, use and disclose through the provision of legal services and the operation of our law firm is of the upmost importance to us.

This policy sets out how we collect, disclose and use personal information and how to contact us if you have questions or issues.

We collect and use personal information as permitted by law and follow the Personal Information Protection and Electronic Documents Act “PIPEDA”, which regulates the way private organizations collect, use, keep, secure and disclose personal information in Canada.

We also follow The Rules of Professional Conduct that govern us as members of the Law Society of Newfoundland and Labrador and set out privacy obligations between lawyer and client. This policy has been developed with those obligations in mind.

If you don’t consent to the collection, disclosure, and use of your information in accordance with this Privacy Policy do not provide Penney & Brown Law with any personal information.

In order to deliver thorough and professional legal services and operate a law firm we need to access to personal information. Generally speaking we collect personal information to:

• Confirm identity,
• Consider the existence of conflicts of interest and act appropriately,
• Access all relevant facts and information related to the client retainer and provide legal services,
• Bill and collect for services,
• Comply with legal and professional obligations.

This information will necessarily include personal information about our clients and about individuals other than our clients such as staff members.

Where practical, we try to collect personal information directly from the person to whom the information pertains. When necessary, we will collect personal information from other sources. For example at times we collect information from medical professionals, public registries, financial institutions, government departments/agencies, law enforcement and the courts.

By retaining this firm for legal advice or representation, an individual consents to our necessary collection, use or disclosure of the individual’s personal information to properly advise and represent the individual client.

It is our normal practice to collect, use and disclose personal information only with consent from the individual. Consent may be given in person, in writing or by phone or electronic communications. We may determine that consent is implied when an individual contacts us.

In some cases we are permitted by law to collect information without an individual’s express or implied consent. If such situation occurs we will substantiate our legal authority to collect, use and/or disclose personal information.

At Penney & Brown law we carefully store and protect personal information using office procedures, physical storage, and technology. Be advised that Penney & Brown Law uses cloud based services for storage of personal client information.

Generally speaking, Penney & Brown Law only discloses personal information to third parties:

• to meet client needs in the conduct of providing legal services,
• with the client’s consent and in keeping with the client’s instructions,
• with other professionals (i.e. doctors) with the express consent of the client,
• as required by the Law Society of Newfoundland and Labrador and our liability insurers,
• to collect on accounts payable, and/or
• where required by law, such as in litigation where information must be disclosed in accordance with the Rules or Court or where we believe that a minor child is in need of protection and a report must made to the appropriate authority in accordance with child protection legislation.

If you have any questions or concerns regarding this policy or how we manage your personal information, or if you wish to request access to, or correction of your personal information under our care and control, please contact our Privacy Officer below.

Privacy Officer:

Jill Brown, Partner

37 West St. Corner Brook, NL

A2H 2Y6

709 634-9885

jbrown@penneybrown.com

We rely on our clients to provide us with accurate and up to date contact information. If your personal information changes while we are doing work for you please let us know.

If you are dissatisfied with our handling of your personal information, we invite you to contact our Privacy Officer in writing, setting out the reasons for your concern. If, after our Privacy Officer has reviewed and responded to your concern, you remain dissatisfied, you may wish to contact the federal Office of the Privacy Commissioner at: Office of the Privacy Commissioner of Canada, 30 Victoria Street Gatineau, QC, K1A 1H3, Toll-free: 1-800-282-1376, Phone: (819) 994-5444.