Kent Legal ("Kent") recognizes the importance of privacy of personal information. Kent is committed to collecting, using, disclosing and protecting any personal information the company receives responsibly. The company’s Privacy Policy sets out how company directors, officers and employees will maintain the confidentiality and privacy of personal information.

Privacy Rights

As of January 1, 2004 all businesses engaged in commercial activities must comply with the Personal Information and Protection & Electronic Documents Act (PIPEDA) and the Canadian Standards Association model code for the protection of personal information approved by the Canadian Standards Association (CSA). These obligations extend to staffing companies such as Kent. The Act gives everyone rights concerning the privacy of their personal information.

The Need for Personal Information

Kent provides staffing and recruitment services to a wide range of clients and needs to collect personal information in order to provide staffing services.

" Personal information" means information about an identifiable individual that is recorded in any form that relates to an individual's personal characteristics, their activities and views including information relating to age, income, family status, education, medical, health history or conditions or services received by the individual, criminal, employment history, financial information, any identifying number, address, the personal opinions or views or evaluation of the individual, gender, home address, or an individual's activities.

Accountability

Kent Legal has appointed Keiran Glynnas the company's Chief Privacy Officer. She is responsible for and will oversee the day to day care and control of Kent’s personal information. Keiran Glynn is responsible for overseeing compliance with the terms of the company’s Privacy Policy.

Kent has undertaken several measures to ensure compliance with the company's Privacy Policy and procedures to ensure personal information is protected. Systems have also been setup to receive and respond to complaints and inquiries. All members of the company have received training regarding the company’s policies and procedures. All new employees will receive training during their orientation program when they join the company. The company will provide information to clients and the general public explaining the company's Policy and procedures respecting personal information by publishing same on their website.

Identifying Purposes

All employees of Kent will collect necessary information by lawful and fair means. The purposes for which personal information is collected will be identified prior to, or at the time of collection. Whenever possible, personal information will be collected directly from the individual at the initial interview and as required during the course of the company’s representation. In the event an employee identifies new purposes for the use of personal information received, the individual's consent will be obtained to use the information for the new purpose identified, except as required by law.

Consent

All individuals will be advised of the purposes for which the information is being collected, used or disclosed of and obtain the individual's prior consent to collect, use or disclose of the personal information, except as required by law.

Limiting Collection

Employees will limit the collection of personal information to that information which is necessary to fulfill the purposes identified by the company to provide the staffing services. If an individual advises that he or she no longer wishes to receive information about the company’s services, or new developments in the staffing business, the company will discontinue sending any further materials. Kent will not sell, barter, trade or give away personal information to third parties. For example, Kent does not provide client mailing lists to any third party.

Limiting Use, Disclosure and Retention

Employees will not use or disclose personal information for purposes other than those purposes for which the information was originally collected, unless the company obtains the consent of the individual from whom such information was received to use or disclose the information for another purpose, except as required by law. Kent will disclose personal information for the following purposes:

• When an individual has consented to the disclosure of private information.

• During the providing of staffing services requiring the company to give the individual's information to a third party.

• When Kent engages a third party to provide administrative services to the company such as file storage, cleaning or security services, the third party will be bound by the company’s Privacy Policy.

• If the information is already publicly known.

The company retains personal information for a period of seven years to achieve the purposes identified and, to permit the individual to have a reasonable opportunity to obtain access to the information of the services provided and as may be prescribed by regulation.

Kent considers an individual's personal information as part of a review process for employment opportunities with the company clients. Kent generally retains information from candidates for seven years, unless an individual asks the company not to retain the information. If an individual accepts a position with Kent or its client, the individual's personal information will be retained in accordance with the company's privacy procedures for employee records.

Website & Electronic Transfer of Data

Kent's website contains links to other sites which are not governed by Kent's Privacy Policy.

Kent, like most other commercial institutions, monitors traffic patterns, site usage and related site information in order to optimize the company's web service. Kent may provide aggregated information to third parties, but these statistics do not include any identifiable personal information.

Individuals should be aware that email is not a 100% secure medium when contacting the company to provide personal or confidential information.

Accuracy

In order for the company to provide staffing services and employment to individuals, it is important that an individual's information is accurate and up to date. If an individual's personal information changes during the course of the individual's relationship with the company, the individual should inform Kent of the change so that the company's records can be updated in a timely fashion.

Safeguards

All members of Kent will take reasonable precautions to ensure that personal information is kept safe from loss, unauthorized access or use, modification or disclosure. Among the steps taken to protect confidential and personal information include:

1. Premises securities
2. Restricted physical file access to personal information
3. Technological safeguards such as security software, passwords and firewalls to prevent hacking or unauthorized computer access.

Openness and Individual Access

Kent is pleased to answer any questions an individual may have regarding the collection and maintenance of personal information. Written requests for access to an individual's personal information shall be provided within 30 days after the written request is received, except as required by law. More detailed requests may require archive or other retrieval methods, which could take additional time and be subject to the company's normal disbursement fees.

Individuals with questions regarding the company's Policy and practices respecting the collection and maintenance of personal information can forward any questions in writing to the company's Chief Privacy Officer at the address set out below.

Keiran Glynn
President & Chief Privacy Officer
Kent Legal Personnel Ltd.
83 Yonge Street
Fourth Floor
Toronto, ON
M5C 1S8
sbennett@kentlegal.com

Whenever it is legal and practical, Kent may offer the opportunity to deal with general inquires without requesting an individual's name, for example, by accessing general information on the company’s website.

Kent may, on occasion, request information about individuals from the files of consumer reporting agencies to assist the company in making credit decisions about applicants, prevent fraud, and check the identity of new clients and prevent money laundering.

Challenging Compliance

Individuals can challenge the company concerning compliance with the company's Policy and procedures with respect to the company's use or disclosure, or the company's refusal to provide access to personal information requested by an individual, or with respect to any other matter relating to the collection, retention or disposal of personal information by the company by addressing the individual's complaint in writing to the Chief Privacy Officer.

Compliance with Kent’s Privacy Policy

Compliance with this Policy and the procedures is mandatory for all employees, directors and officers of Kent.

May 5, 2006