The Aliant Telecom Code of Fair Information Practices complies fully with the Personal Information Protection and Electronics Document Act and incorporates the ten principles of the Canadian Standards Association (CSA) Model Code for the Protection of Personal Information (CAN/CSA-Q830-96) which was published in March 1996 as a National Standard of Canada. Certified by QMI, a Division of CSA, November, 2000.

Introduction

Aliant Telecom is Atlantic Canada's largest telecommunications company, offering customers a complete suite of leading edge telecom products and services.

Aliant Telecom is committed to maintaining the accuracy, confidentiality, security and privacy of customer and employee personal information. This is reflected in existing privacy and confidentiality provisions found in various Aliant Telecom policies and in applicable service rules approved by regulatory agencies over the years. It is also reflected in the high regard and trust with which customers and employees view the management of personal information by Aliant Telecom.

In March 1996, the new Canadian Standards Association Model Code for the Protection of Personal Information, CAN/CSA-Q830-96 (the "CSA Code"), was published as a National Standard of Canada. Aliant Telecom's Code of Fair Information Practices describes how we subscribe to the principles of the CSA Code.

The Aliant Telecom Code of Fair Information Practices (the "Aliant Telecom Code") is a formal statement of principles and guidelines concerning the minimum requirements for the protection of personal information provided by Aliant Telecom to our customers and employees. The objective of the Aliant Telecom Code is responsible and transparent practices in the management of personal information, in accordance with the National Standard and all applicable legislation.

Aliant Telecom will review the Code at least every five years to make sure it is relevant and remains current with changing technologies and laws and the evolving needs of Aliant Telecom, our customers and employees.

Summary of Principles

Principle 1 - Accountability
Aliant Telecom is responsible for personal information under its control and shall designate one or more persons who are accountable for the company's compliance with the following principles.

Principle 2 - Identifying Purposes for Collection of Personal Information
Aliant Telecom shall identify the purposes for which personal information is collected at or before the time the information is collected.

Principle 3 - Obtaining Consent for Collection, Use or Disclosure of Personal Information
The knowledge and consent of a customer or employee are required for the collection, use or disclosure of personal information, except where inappropriate.

Principle 4 - Limiting Collection of Personal Information
Aliant Telecom shall limit the collection of personal information to that which is necessary for the purposes identified by the company. Aliant Telecom shall collect personal information by fair and lawful means.

Principle 5 - Limiting Use, Disclosure and Retention of Personal Information
Aliant Telecom shall not use or disclose personal information for purposes other than those for which it was collected, except with the consent of the individual or as required by law. Aliant Telecom shall retain personal information only as long as necessary for the fulfillment of those purposes.

Principle 6 - Accuracy of Personal Information
Personal information shall be as accurate, complete and up-to-date as is necessary for the purposes for which it is to be used.

Principle 7 - Security Safeguards
Aliant Telecom shall protect personal information by security safeguards appropriate to the sensitivity of the information.

Principle 8 - Openness Concerning Policies and Practices
Aliant Telecom shall make readily available to customers and employees specific information about its policies and practices relating to the management of personal information.

Principle 9 - Customer and Employee Access to Personal Information
Aliant Telecom shall inform a customer or employee of the existence, use and disclosure of his or her personal information upon request and shall give the individual access to that information. A customer or employee shall be able to challenge the accuracy and completeness of the information and to have it amended as appropriate.

Principle 10 - Challenging Compliance
A customer or employee shall be able to address a challenge concerning compliance with the above principles to the designated person or persons accountable for Aliant Telecom's compliance with the Aliant Telecom Code.

Scope and Application

The 10 principles that form the basis of the Aliant Telecom Code are interrelated and Aliant Telecom shall adhere to the 10 principles as a whole. Each principle must be read in conjunction with the accompanying commentary. As permitted by the CSA Code, the commentary in the Aliant Telecom Code has been tailored to reflect personal information issues specific to Aliant Telecom.

The scope and application of the Aliant Telecom Code are as follows:

• The Aliant Telecom Code applies to personal information about Aliant Telecom's customers and employees that is collected, used or disclosed by the company.
• The Aliant Telecom Code applies to the management of personal information in any form whether oral, electronic or written.
• The Aliant Telecom Code does not impose any limits on the use or disclosure of the following information by Aliant Telecom:
  a) Information that is publicly available, such as a customer's name, address, telephone number and electronic address, when listed in a directory or made available through directory assistance; or
  b) The name, title or business address or telephone number of an employee of an organization.
• The application of the Aliant Telecom Code is subject to the requirements or provisions of any applicable legislation, regulations, tariffs or agreements (such as collective agreements), or the order of any court or other lawful authority.

Definitions

Collection - the act of gathering, acquiring, recording or obtaining personal information from any source, including third parties, by any means.

Consent - voluntary agreement with the collection, use and disclosure of personal information for defined purposes. Consent can be either express or implied and can be provided directly by the individual or by an authorized representative. Express consent can be given orally, electronically or in writing but is always unequivocal and does not require any inference on the part of Aliant Telecom. Implied consent is consent that can reasonably be inferred from an individual's action or inaction.

Customer - an individual who

(a) uses, or applies to use, Aliant Telecom's products or services;
(b) corresponds with Aliant Telecom; or
(c) enters an Aliant Telecom contest.

Disclosure - making personal information available to a third party.

Employee - an employee or pensioner of Aliant Telecom.

Aliant Telecom - a corporation composed of an amalgamation of NBTel Inc., Maritime Tel & Tel Ltd., Island Telecom Inc., Island Tel Advanced Solutions inc., NewTel Communications Inc., NewTel Mobility Limited, and our wholly owned subsidiaries MTT Mobility (Wireless Business) and Aliant Advanced Communications.

Personal information - information about an identifiable individual that is recorded in any form but not aggregated information that cannot be associated with a specific individual.

For a customer, such information includes a customer's credit information, billing records, service and equipment, and any recorded complaints.


For an employee, such information includes information found in personal employment files, performance appraisals and medical and benefits information.

Third party - an individual other than the customer or his agent or an organization other than Aliant Telecom.

Use - the treatment, handling, and management of personal information by Aliant Telecom.

The Aliant Telecom Code in Detail

Principle 1 - Accountability

Aliant Telecom is responsible for personal information under its control and shall designate one or more persons who are accountable for the company's compliance with the following principles.

1.1	Responsibility for ensuring compliance with the provisions of the Aliant Telecom Code rests with the senior management of Aliant Telecom, which shall designate one or more persons to be accountable for compliance with the Aliant Telecom Code. Other individuals within Aliant Telecom may be delegated to act on behalf of the designated person(s) or to take responsibility for the day-to-day collection and processing of personal information.
1.2	Aliant Telecom shall make known, upon request, the title of the person or persons designated to oversee the company's compliance with the Aliant Telecom Code.
	Aliant Telecom has designated the Aliant Telecom Privacy Manager to oversee compliance with the Aliant Telecom Code. The Aliant Telecom Privacy Manager can be contacted at
	The Privacy Manager Risk Management Group Aliant Telecom One Brunswick Square P.O. Box 1430 Saint John, N.B. E2L 4K2 PrivacyManager@aliant.ca
1.3	Aliant Telecom is responsible for personal information in its possession or control, including information that has been transferred to a third party for processing. Aliant Telecom shall use appropriate means to provide a comparable level of protection while information is being processed by a third party (see Principle 7).
1.4	Aliant Telecom have implemented policies and procedures to give effect to the Aliant Telecom Code, including: a) implementing procedures to protect personal information and to oversee the company's compliance with the Aliant Telecom Code; b) establishing procedures to receive and respond to inquiries or complaints; c) training and communicating to staff about the company's policies and practices; and d) developing public information to explain the company's policies and practices.

Principle 2 - Identifying Purposes for Collection of Personal Information

Aliant Telecom shall identify the purposes for which personal information is collected at or before the time the information is collected.

2.1	Aliant Telecom collects personal information only for the following purposes: a) To establish and maintain responsible commercial relations with customers and to provide ongoing service; b) To understand customer needs; c) To develop, enhance, market or provide products and services; d) To manage and develop our business and operations, including personnel and employment matters; and e) To meet legal and regulatory requirements.
	Further references to "identified purposes" mean the purposes identified in Principle 2.
2.2	Aliant Telecom shall specify orally, electronically or in writing the identified purposes to the customer or employee at or before the time personal information is collected. Upon request, persons collecting personal information shall explain these identified purposes or refer the individual to a designated person within Aliant Telecom who shall explain the purposes.
2.3	Unless required by law, Aliant Telecom shall not use or disclose, for any new purpose, personal information that has been collected without first identifying and documenting the new purpose and obtaining the consent of the customer or employee.

Principle 3 - Obtaining Consent for Collection, Use or Disclosure of Personal Information

The knowledge and consent of a customer or employee are required for the collection, use or disclosure of personal information, except where inappropriate.

3.1	In certain circumstances personal information can be collected, used or disclosed without the knowledge and consent of the individual. For example, Aliant Telecom may collect or use personal information without knowledge or consent if it is clearly in the interests of the individual and consent cannot be obtained in a timely way, such as when the individual is a minor, seriously ill or mentally incapacitated.
	Aliant Telecom may also collect, use or disclose personal information without knowledge or consent if seeking the consent of the individual might defeat the purpose of collecting the information such as in the investigation of a breach of an agreement or a contravention of a federal or provincial law.
	Aliant Telecom may also use or disclose personal information without knowledge or consent in the case of an emergency where the life, health or security of an individual is threatened.
	Aliant Telecom may disclose personal information without knowledge or consent to a lawyer representing the companies, to collect a debt, to comply with a subpoena, warrant or other court order, or as may be otherwise required by law.
3.2	In obtaining consent, Aliant Telecom shall use reasonable efforts to ensure that a customer or employee is advised of the identified purposes for which personal information will be used or disclosed. Purposes shall be stated in a manner that can be reasonably understood by the customer or employee.
3.3	Generally, Aliant Telecom shall seek consent to use and disclose personal information at the same time it collects the information. However, Aliant Telecom may seek consent to use and disclose personal information after it has been collected but before it is used or disclosed for a new purpose.
3.4	Aliant Telecom will require customers to consent to the collection, use or disclosure of personal information as a condition of the supply of a product or service only if such collection, use or disclosure is required to fulfill the identified purposes.
3.5	In determining the appropriate form of consent, Aliant Telecom shall take into account the sensitivity of the personal information and the reasonable expectations of its customers and employees.
3.6	In general, the use of products and services by a customer, or the acceptance of employment or benefits by an employee, constitutes implied consent for Aliant Telecom to collect, use and disclose personal information for all identified purposes.
3.7	A customer may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice. Customers may contact Aliant Telecom for more information regarding the implications of withdrawing consent.

Principle 4 - Limiting Collection of Personal Information

Aliant Telecom shall limit the collection of personal information to that which is necessary for the purposes identified by the company.

Aliant Telecom shall collect personal information by fair and lawful means.

4.1	Aliant Telecom collects personal information primarily from its customers or employees.
4.2	Aliant Telecom may also collect personal information from other sources including credit bureaus, employers or personal references, or other third parties that represent that they have the right to disclose the information.

Principle 5 - Limiting Use, Disclosure and Retention of Personal Information

Aliant Telecom shall not use or disclose personal information for purposes other than those for which it was collected, except with the consent of the individual or as required by law.

Aliant Telecom shall retain personal information only as long as necessary for the fulfillment of the purposes for which is was collected.

5.1	In certain circumstances personal information can be collected, used or disclosed without the knowledge and consent of the individual. (See Principle 3.1)
5.2	Aliant Telecom may disclose a customer's personal information to: a) another telecommunications company for the efficient and effective provision of telecommunications services; b) a company involved in supplying the customer with communications or communications directory related services; c) another person for the development, enhancement, marketing or provision of any of Aliant Telecom's products or services; d) an agent retained by Aliant Telecom in connection with the collection of the customer's account; e) credit grantors and reporting agencies; f) a person who, in the reasonable judgment of the company, is seeking the information as an agent of the customer; and g) a third party or parties, where the customer consents to such disclosure or disclosure is required by law.
5.3	Aliant Telecom may disclose personal information about its employees: a) for normal personnel and benefits administration; b) in the context of providing references regarding current or former employees in response to requests from prospective employers; or c) where disclosure is required by law.
5.4	Only Aliant Telecom's employees who require access for business reasons, or whose duties reasonably so require, are granted access to personal information about customers and employees.
5.5	Aliant Telecom shall keep personal information only as long as it remains necessary or relevant for the identified purposes or as required by law. Depending on the circumstances, where personal information has been used to make a decision about a customer or employee, Aliant Telecom shall retain, for a period of time that is reasonably sufficient to allow for access by the customer or employee, either the actual information or the rationale for making the decision.
5.6	Aliant Telecom shall maintain reasonable and systematic controls, schedules and practices for information and records retention and destruction which apply to personal information that is no longer necessary or relevant for the identified purposes or required by law to be retained. Such information shall be destroyed, erased or made anonymous.

Principle 6 - Accuracy of Personal Information

Personal information shall be as accurate, complete and up-to-date as is necessary for the purposes for which it is to be used.

6.1	Personal information used by Aliant Telecom shall be sufficiently accurate, complete and up-to-date to minimize the possibility that inappropriate information may be used to make a decision about a customer or employee.
6.2	Aliant Telecom shall update personal information about customers and employees as and when necessary to fulfill the identified purposes or upon notification by the individual.

Principle 7 - Security Safeguards

Aliant Telecom shall protect personal information by security safeguards appropriate to the sensitivity of the information.

7.1	Aliant Telecom shall protect personal information against such risks as loss or theft, unauthorized access, disclosure, copying, use, modification or destruction, through appropriate security measures. Aliant Telecom shall protect the information regardless of the format in which it is held.
7.2	Aliant Telecom shall protect personal information disclosed to third parties by contractual agreements stipulating the confidentiality of the information and the purposes for which it is to be used.
7.3	All of Aliant Telecom's employees with access to personal information shall be required as a condition of employment to respect the confidentiality of personal information.

Principle 8 - Openness Concerning Policies and Practices

Aliant Telecom shall make readily available to customers and employees specific information about its policies and practices relating to the management of personal information.

8.1

Aliant Telecom shall make information about its policies and practices easy to understand, including: a) The title and address of the person or persons accountable for the company's compliance with the Aliant Telecom Code and to whom inquiries or complaints can be forwarded; b) The means of gaining access to personal information held by the company; and c) A description of the type of personal information held by the company, including a general account of its use.

8.2

Aliant Telecom shall make available information to help customers and employees exercise choices regarding the use of their personal information and the privacy enhancing services available from the company.

Principle 9 - Customer and Employee Access to Personal Information

Aliant Telecom shall inform a customer or employee of the existence, use and disclosure of his or her personal information upon request and shall give the individual access to that information.

A customer or employee shall be able to challenge the accuracy and completeness of the information and have it amended as appropriate.

9.1	Upon request, Aliant Telecom shall afford to a customer or an employee a reasonable opportunity to review the personal information in the individual's file. Personal information shall be provided in understandable form within a reasonable time and at minimal or no cost to the individual.
9.2	In certain situations, Aliant Telecom may not be able to provide access to all of the personal information it holds about a customer or employee. For example, Aliant Telecom may not provide access to information if doing so would likely reveal personal information about a third party or could reasonably be expected to threaten the life or security of another individual. Also, Aliant Telecom may not provide access to information if disclosure would reveal confidential commercial information, if the information is protected by solicitor-client privilege, if the information was generated in the course of a formal dispute resolution process, or if the information was collected in relation to the investigation of a breach of an agreement or a contravention of a federal or provincial law. If access to personal information cannot be provided, Aliant Telecom shall provide the reasons for denying access upon request.
9.3	Upon request, Aliant Telecom shall provide an account of the use and disclosure of personal information and, where reasonably possible, shall state the source of the information. In providing an account of disclosure, Aliant Telecom shall provide a list of organizations to which it may have disclosed personal information about the individual when it is not possible to provide an actual list.
9.4	In order to safeguard personal information, a customer or employee may be required to provide sufficient identification information to permit Aliant Telecom to account for the existence, use and disclosure of personal information and to authorize access to the individual's file. Any such information shall be used only for this purpose.
9.5	Aliant Telecom shall promptly correct or complete any personal information found to be inaccurate or incomplete. Any unresolved differences as to accuracy or completeness shall be noted in the individual's file. Where appropriate, Aliant Telecom shall transmit to third parties having access to the personal information in question any amended information or the existence of any unresolved differences.
9.6	A customer can obtain information or seek access to his or her individual file by contacting a designated representative at one of Aliant Telecom's business offices.
9.7	An employee can obtain information or seek access to his or her individual file by contacting his or her immediate supervisor within Aliant Telecom.

Principle 10 - Challenging Compliance

A customer or employee shall be able to address a challenge concerning compliance with the above principles to the designated person or persons accountable for Aliant Telecom's compliance with the Aliant Telecom Code.

10.1	Aliant Telecom shall maintain procedures for addressing and responding to all inquiries or complaints from its customers and employees about the companies' handling of personal information.
10.2	Aliant Telecom shall inform its customers and employees about the existence of these procedures as well as the availability of complaint procedures.
10.3	The person or persons accountable for compliance with the Aliant Telecom Code may seek external advice where appropriate before providing a final response to individual complaints.
10.4	Aliant Telecom shall investigate all complaints concerning compliance with the Aliant Telecom Code. If a complaint is found to be justified, the company shall take appropriate measures to resolve the complaint including, if necessary, amending its policies and procedures. A customer or employee shall be informed of the outcome of the investigation regarding his or her complaint.

For more information on Aliant Telecom's commitment to Privacy, contact us at the number shown on your monthly bill, or contact us through our websites:

www.nbtel.nb.ca
www.mtt.ca
www.newtel.com
www.islandtel.pe.ca

For additional copies of the Aliant Telecom Code of Fair Information Practices please write to us or visit an Internet web site indicated above.

For copies of the CSA Model Code for the Protection of Personal Information contact:

Canadian Standards Association
178 Rexdale Blvd.
Etobicoke, Ontario
M9W 1R3

©Copyright 2000

Aliant Telecom Privacy Policy