PRIVACY COMMITMENT

Watson Advisors Inc. (“Watson Board Advisors” or “Watson”) respects the privacy of individuals in all aspects of our business. Protecting your privacy is important to us and we are committed to protecting your personal information when providing services to our clients. We recognize that ensuring the accuracy, confidentiality and security of your personal information is our professional and legal obligation. Your personal information is collected, used and disclosed by Watson in accordance with this Privacy Policy.

This Privacy Statement is designed to meet the standards prescribed by the applicable privacy laws in the jurisdictions in which we operate, including the Personal Information Protection and Electronic Documents Act and the regulations thereunder (“PIPEDA”) in Canada as well as applicable Canadian provincial privacy legislation such as the Personal Information Protection Act in British Columbia.

WHAT IS PERSONAL INFORMATION?

Personal information means identifiable information about an individual but does not include business contact information such as the name, position or title, business telephone, business address, business email or business fax numbers of an individual.

Information about an identifiable individual includes age, gender, income, marital status, health status, financial situation, current employment and compensation package, previous employment history and compensation package, board appointments, company affiliations, other resume information, information obtained through reference and background checks, interview notes about you, evaluations about you, feedback forms, educational records, reference letters, testing results and identification numbers (such as a social insurance number, driver’s license, etc.).

WHY WE ASK FOR YOUR PERSONAL INFORMATION

Watson provides advisory consulting and recruitment. We collect, use, and store a variety of personal information to provide such services.

1. General

For all clients, we will collect and use information about your organization and individuals within your organization for the purposes of providing services or fulfilling our obligations to you and furthering our business relationship with you. We may collect personal contact information for directors and members of the executive management team.

We may also use the data for other business purposes, including benchmarking. We may use the personal data collected to contact you in relation to any of our services that we believe may be of interest to you. We may contact you from time to time to share thought leadership that we have published which we believe could be of interest to you. You may opt out of receiving these communications at any time.

2. Executive or Director Search

If you are a client that has retained Watson to recruit candidates for your organization, we will ask you for information so that we can conduct a candidate search based on your business needs, expectations, organizational culture and other relevant issues. We will discuss these needs and other relevant issues with potential candidates.

If you are a potential candidate for one of our executive or director search assignments, we may collect personal information that includes: personal contact information (e-mail address, address, telephone number), career history, education history, social activities, compensation details, professional experience, information relating to references, languages, photographs, individual capabilities, qualifications, preferences, personality, character traits, executive competencies, offer letters, identification data (civil/marital status, gender, nationality), and contact history. This data may be obtained directly from you, through publicly available sources, your professional networking profile, news reports, and/or third parties such as our clients, sources/referees, and our authorized background check providers.

If you are an individual who provides a personal reference for one of our candidates, we will ask you to answer specific questions to validate the information that we have about our candidate and to explore their skills and experience relative to the role in question, in order to assist our clients in their selection process. We may also collect and process your contact details, certain professional and employment details (such as title, occupation, qualifications and employment history) and your connection to the candidate.

3. Advisory Consulting Services

If you participate in an advisory consulting project, we will ask you to answer specific questions regarding your performance and/or the performance of others as either an executive team member or as a board member. We use the information you provide to analyze your responses and deliver insights to you, and/or the person or body being evaluated. We collect information to identify strengths and weaknesses, challenges and opportunities, competencies and gaps, or areas for improvement, training and development.  When it is part of our engagement, we will also provide your organization with an aggregated analysis of multiple assessments.

We also use the information you provide us in aggregated and de-identified ways to improve our products and services, conduct research and analysis such as identify trends and patterns in leaders and organizations, as well as to promote our services and develop and share thought leadership.

4. Establishing an employment, contractual, or partnership relationship

We collect from former employers and other third parties, and from publicly available sources, personal information about prospective or current employees, contractors and partners that is reasonably required to establish, manage or terminate an employment, contractual, or partnership relationship.

HOW WE COLLECT PERSONAL INFORMATION ABOUT YOU

Much of the information we collect comes directly from you. If you are a recruitment candidate, we may obtain personal information about you from third parties and publicly available websites to help us assess your eligibility and suitability as a candidate for positions for which are recruiting on behalf of our clients. If you are part of an organization for whom we are facilitating assessments, we may obtain personal information from others within or external to your organization.

We will not process your personal information in a way that is incompatible with what is outlined in this Privacy Policy and we will use our best efforts to ensure that data is accurate, complete, current and reliable for its intended use.

You may withdraw your consent at any time by notifying us in writing, subject to legal or contractual restrictions and reasonable notice. Should you wish to do so, please direct your notice to our Privacy Officer, in writing, by emailing sid@watsoninc.ca. We will inform you of the implications of withdrawing your consent. We will not require you to consent to the collection, use, disclosure or protection of information beyond that which is required to fulfill the specified and legitimate purposes for which the information is being collected.

WHEN AND HOW WE OBTAIN YOUR CONSENT

We generally obtain your consent prior to collecting, and in any case, prior to using or disclosing your Personal Information for any purpose. You may provide your express consent to us either orally, electronically or in writing. You may also consent to our collection, use and disclosure of Personal Information by voluntarily providing us with Personal Information through a clear, affirmative action (e.g. by submitting an information request, participating in a survey, etc.). We may also rely on your implied consent to the collection, use and disclosure of your Personal Information where implied consent is permitted under applicable law.

We will not, as a condition of the supply of our professional services or products, require you to consent to the collection, use, disclosure or protection of information beyond that which is required to fulfill the specified and legitimate purposes for which the information is being collected.

WHEN WE RELEASE YOUR PERSONAL INFORMATION

We will release your personal information to parties outside Watson (other than normal-course suppliers we engage to operate our business) only under the following circumstances:

With Your Consent: We will disclose your personal information to our clients with your prior consent.

When Required or Permitted by Law: In certain circumstances, the law may require or permit Watson to disclose your personal information without your knowledge or specific consent. For example, such information may be disclosed if required to comply with a subpoena, warrant, or court order, or if requested by a government institution, which has the lawful authority to obtain the information.

In exceptional circumstances it may be necessary that we disclose your personally identifiable information if we believe, in good faith, that disclosure is otherwise necessary or advisable to protect Watson’s interests. We will seek to ensure that any proposed disclosure is required in the circumstances and then ensure we disclose only the information that is required.

Under no circumstances do we sell personal information to other organizations.

SAFEGUARDING YOUR PERSONAL INFORMATION

To prevent unauthorized access, maintain accuracy of data, and ensure the proper use of information, Watson has implemented appropriate legal, physical, technical and security procedures to protect the confidentiality of, and safeguard, the personal information collected, and prevent against accidental loss, unauthorized access, or unlawful processing. These measures will be reviewed over time and updated to remain aligned with legal and technological developments.

YOUR RIGHT TO ACCESS YOUR INFORMATION

We make every reasonable effort to ensure the accuracy and completeness of personal information which we collect, and which is likely to be used for a decision affecting an individual or if it is likely to be disclosed to another organization.

You have the right to request access to your personal information in our custody and control and for information on how it is being used or disclosed by us. The law permits individuals to request that errors or omissions in their personal information in our custody and control to be corrected. We will respond to all such requests in compliance with applicable privacy legislation.

Please note that we may not be able to provide information about you from our records if it contains references to other persons, is subject to legal privilege, is part of Watson’s proprietary information, or cannot be disclosed for other legal reasons. If you have any questions regarding decisions made, we will tell you the reasons for those decisions.

If we have collected and processed your Personal Information on the basis of your consent, you may withdraw your consent at any time by providing notice to us in writing. Withdrawing your consent will not affect any processing performed prior to your withdrawal nor will it affect processing on the basis of lawful processing grounds other than consent.

RETENTION OF YOUR PERSONAL INFORMATION

Watson will retain your personal information for as long as necessary to fulfill the purpose(s) for which it was collected and to comply with applicable laws and regulations. Your consent to such purposes(s) will remain valid after termination of our relationship with you.

LINKS TO THIRD PARTY WEBSITES

There are several places throughout Watson’s website that may link to other websites that are not Watson websites and do not operate under Watson’s policies. When you link to other websites, Watson’s policies no longer apply. We encourage you to review each site’s Privacy Policy before you disclose any personally identifiable information.

CHANGES TO THE PRIVACY POLICY

Watson reserves the right to modify or amend our Privacy Policy at any time and for any reason. If there are material changes to the Privacy Policy, we will post those changes here. Please check this Privacy Policy from time to time to stay informed.

PRIVACY OFFICER

Watson has appointed its Chief Operating Officer as its privacy officer. If you have any questions about your personal information, please e-mail sid@watsoninc.ca.