Gowlings understands the importance of protecting the privacy of clients, staff, professionals and other individuals and has implemented a policy concerning Personal Information. Gowlings places a high priority on effectively dealing with any privacy complaints and this document addresses how Gowlings will meet its obligations under our privacy policy and the law with respect to the subject of privacy.

All privacy complaints will be treated seriously, dealt with promptly and handled in a confidential manner.

A "privacy complaint" relates to any concern or dispute that you have with our privacy practices as they relate to your Personal Information. This could include matters such as how Personal Information is collected, stored, used or disclosed or how long it is kept. A privacy complaint may also concern how access is provided.

If you have provided us with Personal Information you have a right to make a complaint and have it investigated and dealt with under our privacy policy.

What do I do if I have a privacy complaint?

If you have a privacy complaint, we encourage you to first discuss it and try to resolve it with your primary contact at Gowlings. However, if your privacy complaint is not resolved, the matter will then be referred to Gowlings' Chief Privacy Officer.

Alternatively, you may contact Gowlings' Chief Privacy Officer by sending a message to chiefprivacyofficer@gowlings.com. You may complain orally or in writing or use the form provided.

All complaints will be logged in a complaints register. If you submit your complaint to your primary contact, he or she is required to send a copy of the complaint to the Firm's Chief Privacy Officer. This is done to record the request in the Firm's Complaint Register.

The Procedure Gowlings Will Follow After Receiving a Privacy Complaint

Our objective with privacy complaints is to achieve an effective resolution of your complaint within a reasonable timeframe of 30 days, or as soon thereafter as practicable.

Once you make a complaint to your Gowlings contact (who may be the Chief Privacy Officer), the matter may be resolved in a number of ways:

1. Further information and investigation: Your Gowlings contact may request further information from you. You should be prepared to give as many details as possible including details of any relevant dates and documentation. This will enable your Gowlings contact to investigate the complaint and determine an appropriate solution. All details provided will be kept confidential.

   Gowlings may require sufficient information to allow it to confirm that the individual making the complaint is authorized to do so prior to it proceeding to address the complaint.

   The complaint will be investigated unless it appears, in our opinion, not to be legitimate (i.e. frivolous or vexatious). We will try to investigate within 10 working days. It may be necessary to contact others and to mention your name and certain details of your Personal Information in order to proceed with the investigation.

2. Discuss options: We may discuss options for resolution and, if you have suggestions about how the matter might be resolved, you should discuss these with your contact.

3. Discussion with any other parties: If your complaint deals with the conduct of our professionals or employees we will raise the matter with the individual concerned and seek his or her comment and input in the investigation stage.

4. Refer to Senior Management: If your complaint is not resolved with your Gowlings contact or the Chief Privacy Officer, at your option, it will be referred to Gowlings' Firm Managing Partner or a person designated by the Firm Managing Partner. This individual will be provided with the history and may discuss the complaint with staff, or other parties that are involved.

5. Resolution: We will decide whether or not your complaint is valid and inform you of the decision and the reason(s). If your complaint is valid, Gowlings will then take appropriate steps to resolve the complaint and prevent the problem from recurring. If the complaint is deemed not valid by Gowlings, or cannot be resolved to your satisfaction, but this procedure has been followed, the decision of the Firm Managing Partner, or his/her delegate, will be final.

If after the above steps have been followed you are still dissatisfied with the outcome, you may refer the complaint to the Office of the Privacy Commissioner (Canada) or the relevant provincial Privacy Commissioner in those provinces where provincial data protection legislation exists.

Gowlings will keep a record of your complaint and the outcome.

Gowlings may not be able to deal fully with anonymous complaints because we may not be unable to investigate and follow-up such complaints. However, in the event that an anonymous complaint is received, Gowlings will note the issues raised and try to resolve them appropriately using the facts that are conveyed to us in the complaint.

Information

For any further information about how Gowlings resolves privacy complaints, please contact the Firm's Chief Privacy Officer using the contact information indicated above.