Privacy Policy

Privacy Policy

Effective: September 1, 2014, amended and restated February 12, 2024

PrairieSky Royalty Ltd. (“PrairieSky” or the “Company”) is committed to protecting the privacy of personal information collected, used and disclosed in the conduct of its business in accordance with applicable privacy laws.

Application of This Policy

To Whom Does This Policy Apply?

This Privacy Policy (the “Policy”) applies to all individuals engaged in company business, including all former, present and prospective employees, contractors, officers and directors of PrairieSky, including any subsidiaries thereof from time to time (collectively “covered persons” or “you”). Subcontractors used by PrairieSky are expected to develop and enforce privacy policies that are consistent with this Policy.

What Does This Policy Cover?

For the purposes of this Policy, “personal information” refers to information about an identifiable individual, such as home mailing address or personal email address, compensation information, employment terms, salary details, performance reviews and health benefit qualifications. Personal information does not include anonymous or non-personal information, such as business contact information used for business purposes.

Will This Policy Change?

PrairieSky may need to change this Policy from time to time. PrairieSky will alert you to significant changes by posting an updated version of this Policy on the PrairieSky intranet with a new “amended and restated” date. PrairieSky’s use and disclosure of personal information it collects now is subject to the Policy in effect at the time PrairieSky uses or discloses that personal information.           

Do You Have Any Obligations With Respect to This Policy?

You are responsible for furthering the objectives of and handling the personal information of others in accordance with this Policy. Any covered person who breaches this Policy or accesses or attempts to access the personal information of others, other than on a need-to-know basis in connection with their employment obligations, may be subject to disciplinary action up to and including termination of employment for just cause or termination of contract, as applicable. PrairieSky may refer violations of this Policy or relevant laws to the appropriate regulatory authorities.

Complying With Applicable Laws

PrairieSky complies with applicable laws within each jurisdiction in which it operates. Sometimes the applicable laws and covered persons’ right to privacy are different from one jurisdiction to another. This Policy has a limited scope and application and the rights and obligations contained in this Policy may not be available to all covered persons or in all jurisdictions.

Collecting and Using Personal Information

What Personal Information Does PrairieSky Collect?

PrairieSky collects and uses personal information in connection with human resources, including hiring, performance evaluation, scheduling of work hours, administration of benefits, travel management and payroll and compensation, including audit, expense tracking and reimbursements, employee share ownership plans and stock option plans and accounting.

PrairieSky may collect, use, store and transfer different kinds of personal information which PrairieSky has grouped together as follows:

  • Background check information, including criminal record, copies of identification documents and medical reports;
  • Emergency information, including emergency contact information, medical condition and allergies;
  • Financial information, including banking information, tax information, benefits information and information related to employee share ownership plans and stock option plans;
  • Health information, including information about covered individuals’ injuries, diagnoses, accident reports, insurance information and other information related to a covered individual’s health condition as relevant to their workplace;
  • Identity information, including first and last names, date of birth, education history, email address, phone number(s), residential address, social insurance number/social security number, employee ID number and frequent traveler program membership number;
  • Government IDs, including passport and driver’s license number, nationality, place and date of issue and expiration date;
  • Security information, including videos of you as captured by PrairieSky’s CCTV cameras and key card and other building access logs; and
  • Technical information, including your username(s), credential(s), logs of both successful and failed attempts to connect to PrairieSky systems, your location when using PrairieSky systems, your use of, including information accessed through or stored on, IT assets, systems and resources owned or made available by PrairieSky (“IT Resources”), as described in more detail in the Company’s Information Technology Security Policy.

PrairieSky may also collect, use and share aggregated personal information, such as statistical or demographic information, for any purpose. Aggregated personal information could be derived from your personal information but is not considered personal information in law as this information will not directly or indirectly reveal your identity. For example, PrairieSky may aggregate your demographic information to produce workforce statistics. However, if PrairieSky combines or connects aggregated personal information with your personal information so that it can directly or indirectly identify you, PrairieSky treats the combined information as personal information which will be used in accordance with this Policy.

If you provide PrairieSky with personal information of another individual (e.g. members of your family), you represent that you have obtained all necessary consents from such person to enable PrairieSky to collect, use and disclose such personal information for the purposes set forth in this Policy.

How Does PrairieSky Collect Personal Information?

PrairieSky may collect personal information directly from you through various means, including through conversations, correspondence, forms, paper and electronic records and your use of IT Resources, including your PrairieSky email and internet applications, as described in more detail in the Company’s Information Technology Security Policy.

PrairieSky may also collect personal information, such as banking information and background information, indirectly from third parties. The third parties may include financial institutions, travel companies, insurance companies, companies performing background and medical checks and building management companies.

Why Does PrairieSky Collect and Use Personal Information?

PrairieSky will only collect and use your personal information as permitted by applicable laws. Most commonly, PrairieSky will use your personal information in the following circumstances to carry out and support human resources functions and activities, including:

Purpose of Collection and Use of Personal Information

Type of Personal Information Involved

Recruiting, hiring and determining eligibility of job applicants
  • Background check information
  • Emergency information
  • Identity information
  • Financial information
  • Government IDs

Monitoring, evaluating and managing performance, attendance and talent development
  • Background check information
  • Identity Information
  • Financial information
  • Security footage
  • Technical information

Administering compensation, benefits and other prerequisites
  • Identity information
  • Financial information

Managing information technology and communications systems, such as the corporate email system, the organization’s directory or corporate networks
  • Identity information
  • Technical information

Facilitating mobility, travel, immigration and managing international assignments

 
  • Background check information
  • Emergency information
  • Identity information
  • Financial information
  • Government IDs

Preventing and managing accidents in the workplace and ensuring the safety and security of covered persons, external parties and assets
  • Identity information
  • Health information
  • Emergency information
  • Security footage

Preventing, identifying and investigating crimes involving PrairieSky assets

 

 
  • Background check information
  • Identity information
  • Financial information
  • Security footage
  • Technical information

Managing the termination process

 
  • Background check information
  • Emergency information
  • Identity information
  • Financial information
  • Technical information

Complying with applicable legal obligations, including contractual or other commitments (such as payment obligations) to external parties, including landowners

 
  • Background check information
  • Emergency information
  • Identity information
  • Financial information
  • Government IDs
  • Security footage
  • Technical information

Handling other issues with your consent
  • To be determined, based on your consent

PrairieSky may process your personal information for more than one of the purposes listed above, depending on the specific objective for which the Company is using your personal information. Please contact PrairieSky if you need details about the specific legal ground it is relying on to process your personal information.  

PrairieSky will only use your personal information for the purposes that it was collected, unless PrairieSky reasonably considers that it needs to use it for another reason and that reason is compatible with the original purpose. If PrairieSky needs to use your personal information for an unrelated purpose, the Company will notify you and explain the legal basis which allows it to do so.

Please note that PrairieSky may process your personal information without your knowledge or consent, in compliance with the above rules, where permitted or required by applicable laws. 

Disclosing Personal Information

To Whom Does PrairieSky Disclose Personal Information?

PrairieSky only discloses your personal information to outside organizations or persons as set out below, or as otherwise permitted or required by applicable laws. PrairieSky does not sell your personal information to anyone under any circumstances.

  • Service Providers

PrairieSky uses service providers to facilitate the management of human resources, payroll and compensation and employee share ownership plans and stock option plans, help administer benefits, insurance and travel arrangements, and store your personal information. This may require PrairieSky to disclose your personal information to that service provider for processing. PrairieSky will treat any personal information it discloses to service providers in accordance with this Policy.

PrairieSky does not allow its service providers to use your personal information for their own purposes and only permits them to process your personal information for specified purposes and in accordance with PrairieSky’s instructions. 

  • Transactions With Third Parties

PrairieSky may consider transactions that involves a potential third party buyer, investor or partner having access to your personal information for the purposes of considering the transaction. If the transaction is concluded, PrairieSky may disclose your personal information to such third party, who will use and disclose it in accordance with this Policy (unless otherwise permitted by applicable laws or your consent).

  • Government and Law Enforcement

PrairieSky may provide personal information to government and law enforcement authorities to the extent permitted or required by applicable laws.  

Will Your Personal Information Leave the Country?

PrairieSky may use, process, store or disclose your personal information in provinces and countries other than the one in which you reside. Laws relating to privacy vary between provinces and countries, and your personal information may be processed in a country with laws less stringent than the laws in your jurisdiction. In such cases, PrairieSky complies with applicable laws in relation to your personal information, including by putting appropriate contractual safeguards in place to ensure an adequate level of protection for your personal information. Please contact PrairieSky if you require further information about other countries where your personal information may reside, or the specific mechanisms PrairieSky uses when transferring personal information outside your home jurisdiction.

Retaining Personal Information

PrairieSky only retains your personal information for the period of time necessary to fulfill the purposes for which it was collected (including for the purpose of meeting any legal, accounting or other reporting requirements), or to comply with applicable laws, whichever is longer, after which point the personal information is destroyed or made anonymous. PrairieSky may retain your personal information for a longer period in the event of a complaint, or if PrairieSky reasonably believes there is a prospect of litigation in respect to its relationship with you.

Protecting Personal Information

PrairieSky protects personal information using reasonable security safeguards which are appropriate to the sensitivity level of the personal information. These safeguards are intended to prevent personal information from loss and unauthorized access, copying, use, modification or disclosure.

Those who process your personal information on behalf of PrairieSky, for the purposes listed above, have access to personal information, or are associated with the processing of personal information, are obliged to respect the confidentiality of the personal information of all covered persons.

Your Rights Regarding Personal Information

Can You Access Your Personal Information?

You can request that PrairieSky confirm whether it has any of your personal information and, subject to any applicable exemptions, PrairieSky will provide you with a copy of that personal information within the deadlines set out in applicable privacy laws.

Can You Rectify Your Personal Information?

You can request that PrairieSky rectify any incorrect or inaccurate personal information. If PrairieSky is satisfied that a rectification should be made, PrairieSky will amend the personal information as requested and, where appropriate and reasonable to do so, send the corrected personal information to any third parties to which it has disclosed that personal information.

Can You Withdraw Consent to Processing of Your Personal Information?

If PrairieSky relies on your implied or express consent as the legal basis for processing your personal information, you can withdraw that consent at any time. If you do so, PrairieSky may not be able to provide certain services to you, such as certain services related to payroll and compensation, human resources, hiring and employee stock ownership plans. PrairieSky will advise you if this is the case at the time you withdraw your consent.

Questions and Concerns

If you wish to submit a question or concern regarding the collection, use or disclosure of personal information by PrairieSky, please contact PrairieSky’s Privacy Officer (or such other person designated by the President & Chief Executive Officer from time to time), using the details below:

Privacy Officer: Vice-President, Finance & Chief Financial Officer
Address: 1700, 350 7th Avenue SW, Calgary, AB  T2P 3N9
Phone: 587-293-4089
Email: pam.kazeil@prairiesky.com

 If a covered person is not satisfied with the response they receive from PrairieSky’s Privacy Officer, they may contact the privacy commissioner in the relevant jurisdiction, such as the Office of the Information and Privacy Commissioner of Alberta, for further information.