Personal Information Protection
Private Sector Privacy Legislation
Personal Information Protection Policy
Surge Business Productions

Personal Information Protection Policy
At Surge Business Productions on behalf of the Cheese and Meat Festival and the Victoria Wine Festival, we are
committed to providing our customers with exceptional service. As providing this service involves the collection,
use and disclosure of some personal information about our customers, protecting their personal information is one
of our highest priorities.
While we have always respected our customers’ privacy and safeguarded 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, sets out the ground rules for
how B.C. businesses and not-for-profit organizations may collect, use and disclose personal information.
We will inform our customers of why and how we collect, use and disclose their personal information, obtain their
consent where required, and only handle their personal 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 customers’ personal information. Our privacy commitment includes ensuring the accuracy,
confidentiality, and security of our customers’ personal information and allowing our customers to request access
to, and correction of, their personal information.
Scope of this Policy
This Personal Information Protection Policy applies to Surge Business Productions Inc.
This policy also applies to any service providers collecting, using or disclosing personal information on behalf of
Surge Business Productions Inc.

Personal Information –means information about an identifiable individual, for example personal email. Personal
information does not include contact information (described below).

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.

Privacy Officer – means the individual designated responsibility for ensuring that Surge Business Productions Inc.
complies with this policy and PIPA.

Policy 1 – Collecting Personal Information
1.1 Unless the purposes for collecting personal information are obvious and the customer voluntarily provides
his or her 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.
1.2 We will only collect customer information that is necessary to fulfill the following purposes:
● To contact our customers to facilitate distribution of our newsletter;
To establish contact we may collect personal or business email addresses as well as First and Last

Policy 2 – Consent
2.1 We will obtain customer consent to collect, use or disclose personal information (except where, as noted
below, we are authorized to do so without consent).
2.2 Consent can be provided orally or it can be implied where the purpose for collecting using or disclosing the
personal information would be considered obvious and the customer voluntarily provides personal
information for that purpose.
2.3 Consent may also be implied where a customer is given notice and a reasonable opportunity to opt-out of
his or her personal information being used for newsletters and the customer does not opt-out.
2.4 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), customers can withhold
or withdraw their consent for Surge Business Productions Inc. to use their personal information in certain
ways. A customer’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
the customer in making the decision.
2.5 We may collect, use or disclose personal information without the customer’s knowledge or consent in the
following limited circumstances:
● When the collection, use or disclosure of personal information is permitted or required by law;
● When we require legal advice from a lawyer;
● To protect ourselves from fraud;
● To investigate an anticipated breach of an agreement or a contravention of law

Policy 3 – Using and Disclosing Personal Information
3.1 Surge Business Productions Inc. retains the rights to share the contact information among our subsidiaries.
3.2 We will only use or disclose a customer’s personal information where necessary to fulfill the purposes
identified at the time of collection.
3.3 We will not use or disclose a customer’s personal information for any additional purpose unless we obtain
consent to do so.
3.4 We will not sell customer lists or personal information to other parties unless we obtain consent to do so.

Policy 4 – Retaining Personal Information
4.1 If we use customer personal information to make a decision that directly affects the customer, we will retain
that personal information for at least one year so that the customer has a reasonable opportunity to
request access to it.
4.2 Subject to policy 4.1, we will retain customer personal information only as long as necessary to fulfill the
identified purposes or a legal or business purpose.

Policy 5 – Ensuring Accuracy of Personal Information
5.1 We will make reasonable efforts to ensure that customer personal information is accurate and complete
where it may be used to make a decision about the customer or disclosed to another organization.
5.2 Customers may request correction to their personal information in order to ensure its accuracy and
completeness. A request to correct personal information must be made in writing and provide sufficient
detail to identify the personal information and the correction being sought.
5.3 If the personal information is demonstrated to be inaccurate or incomplete, we will correct the information
as required and send the corrected information to any organization to which we disclosed the personal
information in the previous year. If the correction is not made, we will note the customers’ correction
request in the file.

Policy 6 – Securing Personal Information
6.1 We are committed to ensuring the security of customer personal 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 that customer personal information is
appropriately protected:
● Proper use of user IDs
● Passwords
● Restricting employee access to personal information as appropriate (i.e., only those that need to
know will have access)
● Contractually requiring any service providers to provide comparable security measures
6.3 We will use appropriate security measures when destroying customer’s personal information such as
deleting electronically stored
6.4 We will continually review and update our security policies and controls as technology changes to ensure
ongoing personal information security.

Policy 7 – Providing Customers Access to Personal Information
7.1 Customers have a right to access their personal information, subject to limited exceptions.
● The disclosure could reasonably be expected to threaten the safety or physical or mental health of
an individual other than the individual who made the request
● The disclosure can reasonably be expected to cause immediate or grave harm to the safety or to
the physical or mental health of the individual who made the request
● The disclosure would reveal personal information about another individual
● The disclosure would reveal the identity of an individual who has provided personal information
about another individual and the individual providing the personal information does not consent to
disclosure of his or her identity
● The information is protected by solicitor-client privilege
● The disclosure of the information would reveal confidential information that if disclosed, could, in
the opinion of a reasonable person, harm the competitive position of the organization
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 customers 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 the customer of the cost and request further direction from the customer 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 the customer in writing, providing the reasons for
refusal and the recourse available to the customer.

Policy 8 – Questions and Complaints: The Role of the Privacy Officer or designated individual
8.1 The Privacy Officer is responsible for ensuring Surge Business Production Inc.’s compliance with this
policy and the Personal Information Protection Act.
8.2 Customers should direct any complaints, concerns or questions regarding Surge Business Production
Inc.’s compliance in writing to the Privacy Officer. If the Privacy Officer is unable to resolve the concern,
the customer may also write to the Information and Privacy Commissioner of British Columbia.

Contact information for Surge Business Production Inc.’s Privacy Officer:
(206) 395-3673

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