Protecting your privacy is important to Brainhunter Systems Ltd, its Directors, Officers and Management (collectively, “BRAINHUNTER ”). This Policy explains how BRAINHUNTER collects, uses and discloses personal information provided by its consultants, sub-contractors and employees. This policy attests to this concern and corroborates our commitment to protect such information.

This policy was established in accordance with the Personal Information Protection and Electronic Documents Act (federal “PIPEDA”).

The policy applies to personal information in all its forms – verbal, electronic, written or other – that an organization collects, uses, and discloses in the course of business activities. The term “personal information” refers to any information about an identifiable individual or any information that allows an individual to be identified. In general, personal information does not include business contact information, such as your name, title or position, business address, business telephone or fax number in your capacity as an employee of an organization. During your relationship with BRAINHUNTER, you may be asked to provide certain personal information concerning you. Examples of such information include your date of birth, home address, financial and credit information, billing and account information and other information relating to the provision of consulting and staffing services by BRAINHUNTER.

Information of a public nature is not subject thereto.

Any personal information you provide to BRAINHUNTER will be treated with care and, subject to this Policy and applicable law, will not be used or disclosed in a way to which you have not consented. By submitting your personal information to BRAINHUNTER, you signify your consent to the collection, use and disclosure of your personal information in accordance with this Policy. If you do not consent to the collection, use and disclosure of your personal information in accordance with this Policy, please do not provide any personal information to BRAINHUNTER. Of course, certain services can only be offered to you if you provide BRAINHUNTER with your personal information. If you choose not to provide BRAINHUNTER with the required information, we would not be able to offer you those services.

This policy and the related procedures shall be periodically reviewed to ascertain their conformity and effectiveness.

Principles governing the protection of personal information


BRAINHUNTER is responsible for the personal information it handles and shall designate a person responsible for ensuring compliance with the principles set forth below.

It is incumbent on the company’s senior management to control the compliance of this policy with the appropriate regulatory provisions and to appoint a person responsible for that undertaking. BRAINHUNTER shall disclose the title of the designated person on request. The role of the person responsible covers the following:

  • ensuring that the company complies with the legislation respecting the handling and protection of personal information;
  • ensuring that the company has implemented the measures required to protect the confidentiality of the personal information held;
  • receiving requests for information, access to the file and complaints, and processing them in a diligent and satisfactory manner;
  • ensuring that all personnel is sensitized to the protection of personal information, including training and the transmission of information about BRAINHUNTER’s policies and procedures;

Other BRAINHUNTER employees may be delegated to act on behalf of the designated person and to look after the daily gathering and processing of personal information. Furthermore, the protection of personal and confidential information is incumbent on all employees at BRAINHUNTER. To that effect, every employee shall sign a confidentiality agreement as part of their employment. Temporary employees, consultants and subcontractors shall also sign a confidentiality agreement.

Identifying purposes

The purpose for which personal information is gathered shall be determined prior to or at the time of the gathering thereof. BRAINHUNTER collects, uses, and discloses personal information for the purposes identified prior to or at the time of collection, or as otherwise permitted or required by applicable law, including for the following purposes: to provide employment, consulting and other staffing related services;

  • to comply with federal and provincial tax requirements, remittance obligations, or other government or regulatory requirements;
  • administrative, management and business purposes, such as to process invoices, administer accounts, process and remit payments, fulfill contractual obligations, and audit our business operations;
  • to develop our knowledge management systems and databases;
  • to distribute BRAINHUNTER publications, invitations to seminars and events and other communications which BRAINHUNTER believes may be of interest to consultants, subcontractors and employees;
  • to contact and communicate with consultants and other individuals for the purpose of conducting market research, and evaluating service and satisfaction;
  • for any other purpose for which we have your consent.


A person shall be informed of and consent to any gathering, use or communication of personal information about him or her, unless it is not appropriate to do so. To the extent possible, we will obtain consent to collect, use and disclose personal information about an individual directly from such individual. However, if you provide personal information concerning another individual to BRAINHUNTER, you represent that, prior to submitting such information, you have obtained the necessary consent or authority to permit BRAINHUNTER to collect, use and disclose such personal information for the purposes set out in this Policy, or the collection, use and disclosure is permitted by applicable law. BRAINHUNTER will not collect, use or disclose personal information without the consent of the individual(s) concerned unless we are permitted or required to do so by applicable law. We generally do not obtain the consent of the individual(s) concerned in the following circumstances:

  • if legal, medical or security reasons make it impossible or impractical to seek consent; and
  • whenever information is collected for the detection and prevention of fraud or for law enforcement, and when seeking the consent of the individual may defeat the purpose of collecting the information.

Limiting collection, use and disclosure

BRAINHUNTER shall only gather the personal information needed for a specific purpose and proceed in an honest and lawful manner.

We strive to limit the amount of personal information we collect to that necessary and appropriate for the identified purposes. We will not use or disclose your personal information for purposes other than those for which it was collected, except with your consent or as permitted or required by applicable law.

If BRAINHUNTER is involved in a merger or other reorganization, BRAINHUNTER may disclose your personal information to the resulting organization.

BRAINHUNTER does not sell or exchange for consideration any personal information it holds.

BRAINHUNTER shall not communicate confidential information to any external parties except those needed to conduct its business, as identified above. Some, examples of third parties to whom BRAINHUNTER discloses confidential information to fulfill its mandate include; payroll and benefit providers, government tax authorities, financial institutions and regulatory entities.


BRAINHUNTER shall not preserve any personal information it holds beyond the period prescribed for preservation requirements, no matter what medium is used.

The preservation period shall not exceed the longer of the following:

  • the period needed for the authorized purposes, or
  • the period prescribed by legal or other tax requirements.

The preservation period shall take into account the requests for access that a person might invoke subsequent to decisions made about him or her. However, it shall be limited to the strict interval of time needed for the personal information to fulfill the role for which it is intended.


Personal information shall be as accurate, complete and up-to-date as required for the purpose for which it is used. BRAINHUNTER shall update this information when needed for a set purpose, or on notification to this effect by the person concerned if any information is erroneous or no longer valid.