Privacy Policy Standard for Highline Mushrooms
Date of publication: 20-Jan-26
PURPOSE:
Highline Produce Limited (Highline) will only collect, use or disclose information for the purpose of facilitating Highline Mushrooms’ business operation and the administration of an Associate’s benefits. The collection of information will be limited and privacy maintained in accordance with applicable federal and provincial privacy legislation, including the Personal Information Protection and Electronic Documents Act (PIPEDA), Alberta’s Personal Information Protection Act (PIPA), and British Columbia’s Personal Information Protection Act (PIPA).
SCOPE:
Applies to all associates employed by Highline Produce Limited and subsidiary companies.
PROCEDURE / INSTRUCTIONS:
The Right of Privacy - Highline recognizes that privacy is a fundamental right and integral to maintaining trust and integrity in relationships with Associates, customers, and suppliers. This Policy is based on the Ten Fair Information Principles under PIPEDA and equivalent provincial privacy laws.
DEFINITIONS:
Accountability- Highline is responsible for personal information under its control. This accountability is the under the jurisdiction of the Human Resources Department who ensure compliance at all sites.
Identifying the purpose- Highline shall identify, at or before the collection, the purpose of which any personal information is collected.
Obtain Consent- Highline will obtain informed consent from Associates for the collection, use or disclosure of their personal information, except where otherwise permitted by law.
Limit Collection- Personal information collected will be limited to what is necessary for the identified purposes.
Limit use, disclosure and retention- Personal information will not be used or disclosed for purposes other than those for which it was collected, except with the consent of the Associate or as required by law. Personal information shall be retained only as long as necessary for the fulfillment of those purposes and in accordance with any statutory requirements.
Accuracy- Personal information shall be accurate, complete and current as is necessary for the purposes for which it is used, taking into account the interests of the individual.
Safeguards- Personal information shall be protected by security safeguards appropriate for the degree of sensitivity and format of information. Safeguards include administrative, physical, and technical controls.
Openness- Highline shall make readily available to customers, clients and Associates specific information about its policies and practices relating to the management of personal information.
Individual access- Upon request, an associate shall be informed of the existence, use and disclosure of his/her personal information and shall be given access to that information. Associates may challenge the accuracy and completeness of the information and have it corrected where appropriate.
Provide recourse- An Associate shall be able to address a challenge concerning compliance with this Policy or the Fair Information Principles to the designated individual(s). Highline shall investigate all complaints and respond in writing within 30 days. Where unresolved, Associates may contact the Office of the Privacy Commissioner of Canada or the provincial Privacy Commissioner (Alberta or British Columbia).
PRIVACY BREACH PROTOCOL
In the event of a privacy breach, Highline will:
Contain the breach and assess risk of harm.
Notify affected individuals and, where required, the Office of the Privacy Commissioner or relevant provincial authority.
Document the incident and corrective actions taken.
DATA RETENTION AND DESTRUCTION
Highline will retain personal information for the duration required to fulfill its purpose and meet legal obligations (e.g., CRA seven-year retention, ESA three-year applicant retention). After that period, information will be securely destroyed or anonymized.
RESPONSIBILITIES:
Highline recognizes its obligation to act with the utmost good faith when utilizing personal information supplied by customers, suppliers, employees, and potential employees.
Senior Management, Human Resources, Accounting, Administration, Supervisors and Managers share responsibility for protecting the privacy of our associates and business operations in accordance with this policy.
The Human Resource Managers, the Corporate Human Resources Manager and the Vice President of Human Resources are are responsible for ensuring compliance with this policy and investigating complaints at all sites.
