Personal Information Protection Policy

PERSONAL INFORMATION PROTECTION POLICY*
Private Sector Privacy Legislation

*In the event that portions contained herein this policy do not meet standards prescribed and/or mandated by the Law Society of British Columbia in relation to the Solicitor- Client relationship, the Law Society of British Columbia Code of Conduct and Rules will supersede this policy.

W&C retains the right to refuse provision of any and all personal information that has been incorporated into the work product of the lawyer as this is privileged and proprietary information. W&C will provide in substance any collected information from any person upon request by that person of their information.

At White & Company Family Law, we are committed to providing those who provide us information with exceptional service. As providing this service involves the collection, use and disclosure of some personal information about those that provide us information, protecting their personal information is one of our highest priorities.

While we have always respected the privacy of those who provide us information, and champion the safeguarding of their personal information, we have strengthened our commitment to protecting personal information as a result of British Columbia’s Personal Information Protection Act (PIPA). PIPA, which came into effect on January 1, 2004, and sets out the ground rules for how B.C. businesses and not-for-profit organizations may collect, use and disclose personal information, regardless of whether those who provide us with information covert fully to clientele.

We will handle the information of those who provide us with information in a manner that a reasonable person would consider appropriate in the circumstances.

This Personal Information Protection Policy, in compliance with PIPA, outlines the principles and practices we will follow in protecting those who provide us with information. Our privacy commitment includes ensuring the accuracy, confidentiality, and security of those who provide us with information, regardless of whether it is provided by a non-client or someone who is not yet a client.

Scope of this Policy
This Personal Information Protection Policy applies to White & Company Family Law.

Definitions

Personal Information –means information about an identifiable individual [E.g., including name, age, home address and phone number, social insurance number, marital status, religion, income, credit history, banking information, medical information, education, employment information]. Personal information does not include contact information (described below).
Person providing information –includes all clients, non-clients, prospective clients, and those who have not yet perfected their retainers as prospective clients.
Contact information – means information that would enable an individual to be contacted at a place of business and includes name, position name or title, business telephone number, business address, business email or business fax number. Contact information is not covered by this policy or PIPA.
SMS (Short Message Service) – standard technology used to send text messages between mobile phones.
Privacy Officer – means the individual designated responsibility for ensuring that White & Company Family Law complies with this policy and PIPA.

Policy 1 – Collecting Personal Information
1.1 Unless the purposes for collecting personal information are obvious and the person providing information voluntarily provides their personal information
for those purposes, we will communicate the purposes for which personal information is being collected, either orally or in writing, before or at the time
of collection.
2.1 We will only collect information from those who provide information that is necessary to fulfill the following purposes, but not limited to the following
purposes in all circumstances:

To verify identity.
To understand the legal needs of those who provide us with information and determine whether it is possible to provide them with the requested services.
To conduct a conflict check
To ensure a high standard of service to those who provide us with information.
To meet regulatory requirements including the Law Society of British Columbia.
To comply with all duties of confidentiality to clients who engage the Solicitor-Client relationship fully resulting in a perfected retainer.

Policy 2 – Consent
2.1 We will obtain the consent of those who provide with information to collect, use or disclose personal information (except where, as noted below,
we are authorized to do so without consent) either passively, or actively or both.
2.2 Consent can be provided orally, in writing, electronically, through an authorized representative or it can be implied where the purpose for collecting
using or disclosing the personal information would be considered obvious and the those who provide information voluntarily provides personal

information for that purpose.
2.3 Subject to certain exceptions (e.g., the personal information is necessary to provide the service or product, or the withdrawal of consent would
frustrate the performance of a legal obligation), those who provide information can withhold or withdraw their consent for White & Company Law to
use their personal information in certain ways. Those who provide information’s decision to withhold or withdraw their consent to certain uses of personal information may restrict our ability to provide a particular service or product. If so, we will explain the situation to assist those who provide
us information in making the decision.

*For clients: only in the circumstances explicitly outlined in the Law Society and permitted in the Solicitor-Client relationship which endures beyond termination once perfected.

Policy 3 – Using and Disclosing Personal Information
3.1 We will not use or disclose the personal information of those who provide us with information for any purpose.
3.2 We will not sell personal information of any individual who provides us with information

Policy 4 – Retaining Personal Information
4.1 Subject to policy 4.1, we will retain client personal information only as long as necessary to fulfill the identified purposes or a legal or business purpose
such as requirements outlined by the Law Society of British Columbia.

Policy 5 – Ensuring Accuracy of Personal Information
5.1 We will make reasonable efforts to ensure that the personal information of those who provide us with information is accurate and complete where it
may be used to make a decision about those who provide us information.
5.2 Clients are the only persons who may request correction to their personal information in order to ensure its accuracy and completeness. A request to
correct personal information by a non-client may be made in writing and must provide sufficient detail to identify the personal information and the
correction being sought which may be corrected by the company.

Policy 6 – Securing Personal Information
6.1 We are committed to ensuring the security of the information of those who provide us with information in order to protect it from unauthorized access,
collection, use, disclosure, copying, modification or disposal or similar risks.
6.2 The following security measures will be followed to ensure the information of those who provide us with information is appropriately protected:

the use of locked filing cabinets.
physical securing offices where personal information is held
the use of user IDs, passwords, encryption, and firewalls.
contractually requiring all employees to sign a Confidentiality Agreement, committing them to this Privacy Policy.
keeping all client information and information from those who provide it us out of view of third-party providers who may enter our office.

6.3 We will use appropriate security measures when destroying client’ personal information such as use of secure shredding services.
6.4 We will review and update our security policies and controls as technology changes to ensure ongoing personal information security on a regular
ongoing, basis.
6.5 We will ensure our staff complete IT security training where applicable, such as testing them with phishing campaigns to ensure that we protect
against software infiltration, so they are able to recognize risks when presented with them.

Policy 7 – Providing Those Who Provide Us Information with access to Personal Information
7.1 Those who provide us with information have a right to access their personal information, subject to exceptions.
7.2 A request to access personal information must be made in writing and provide sufficient detail to identify the personal information being sought.
7.3 Upon request, we will also tell those who provide us with information, how we use their personal information and to whom it has been disclosed if
applicable.
7.4 We will make the requested information available within 30 business days or provide written notice of an extension where additional time is required
to fulfill the request.
7.5 A minimal fee may be charged for providing access to personal information. Where a fee may apply, we will inform those who provide us information of
the cost and request further direction from the client on whether or not we should proceed with the request.
7.6 If a request is refused in full or in part, we will notify those who provide information in writing, providing the reasons for refusal and the recourse
available to the individual.

Policy 8 – Opting into SMS Messaging Service

8.1 White and Company Family Law Corporation, respects your privacy. By opting into our SMS messaging service, you agree to the following terms
regarding how we handle your data.

Data Collection: We will collect your name, email address, mailing address, and mobile phone number when you sign up for SMS updates. The information will be collected via the website contact form, email, telephone or in person.
Data Usage: We use your data solely for sending Customer Care messages.
Data Security: We protect your data with secure storage measures to prevent unauthorized access.
Prevention of Unauthorized Data Sharing: We have strict policies and security measures in place to prevent unauthorized sharing or access to your data.
Data Retention: We retain your information if you are subscribed to our SMS service. You may request deletion at any time.
MESSAGE AND DATA RATES MAY APPLY. Your mobile carrier may charge fees for sending or receiving text messages, especially if you do not have an unlimited texting or data plan.
Messages are recurring, and message frequency varies depending on your communication needs.
Contact White and Company Family Law Corporation at (778) 800-8660 or admin@wandcfl.com for HELP or to STOP receiving messages.
Opt-Out: You can opt out of the SMS list at any time by texting, emailing, or replying STOP or UNSUBSCRIBE to admin@wandcfl.com or (778) 800-8660. After unsubscribing, you will receive a final SMS to confirm you have unsubscribed, and we will remove your number from our list within 24 hours.
You can send HELP for additional assistance, and you will receive a text including our Phone number, email and website. We are here to help you.
Non-Sharing Clause: We do not share your data with third parties for marketing purposes. White and Company Family Law Corporation will not sell, rent, or share the collected mobile numbers.

8.2 Data Sharing for Marketing

Your personal and mobile information will not be shared with third parties for marketing purposes under any circumstances.
We do not transfer your personal information to any external organizations under any circumstances. Any information sharing that may be mentioned elsewhere in this policy excludes mobile opt-in data.

8.3 Messaging Terms and Conditions

By providing your phone number you have opted in to receive messages from White and Company Family Law Corporation about family law services from (778) 800-8660. Msg frequency varies. You may receive 1-2 messages per month. Msg & data rates may apply. Text HELP for help. Text STOP to unsubscribe. Mobile opt-in info is never shared with third parties.

Policy 9 – Questions and Complaints: The Role of the Privacy Officer or designated individual
9.1 The Privacy Officer (the Managing Lawyer) is responsible for ensuring White & Company Family Law’s compliance with this policy and the Personal Information Protection Act.
9.2 Those who provide information should direct any complaints, concerns or questions regarding White & Company Family Law’s compliance in writing to
the Privacy Officer. If the Privacy Officer is unable to resolve the concern, those who provide information may also write to the Information and
Privacy Commissioner of British Columbia.

Contact information for the Privacy Officer:
Betti White, Managing Lawyer
495 Van Horne Street, Penticton, British Columbia, V2A 4K7
Email: admin@wandcfl.com | Telephone: (778) 800-8660

PERSONAL INFORMATION PROTECTION POLICY* Private Sector Privacy Legislation

PERSONAL INFORMATION PROTECTION POLICY*
Private Sector Privacy Legislation