VICWEST INCOME FUND PRIVACY POLICY AND PROCEDURES

Introduction

Vicwest Income Fund (the "Fund") has a need to collect, use and disclose customer and employee personal information for legitimate business purposes. This policy outlines the principles, policy and procedures that the Fund will follow with respect to the collection, use and disclosure of employee and customer personal information to ensure the employees' and/or customers' right to privacy is protected in accordance with applicable legislation, where relevant. The Fund will continue to review this Policy on an ongoing basis to ensure that it complies with changing technologies and laws, and our evolving relationships with our customers and our employees.

Definitions

The following definitions are applicable to this policy:

Procedures

•  Accountability

1.1 Accountability for ensuring compliance with the provisions of this policy rest with Vicwest's Privacy Officer or designate. Vicwest's Privacy Officer is the Director of Human Resources.

1.2 The Fund is committed to the implementation of a comprehensive privacy program. Therefore, the Fund is:

•  Implementing procedures to protect personal information;

•  Establishing procedures to proceed with and respond to inquiries or complaints;

•  Training and communicating to staff about the relevant policies and practices;

•  Monitoring the Fund's compliance with the Policy and Procedures; and

•  Developing public information to explain the Fund's Policies and Procedures and its practices.

•  Identifying Purposes For Collection of Personal Information

2.1 The Fund will identify the purposes for which personal information is collected and will specify the identified purposes to the affected individual at or before the time the personal information is collected. On request by the individual, the Fund will also provide the individual with the position, name or title and the contact information of the employee of the Fund who is able to answer the individual's questions about the collection of information.

2.2 Unless required by law, the Fund will not use or disclose, for any new purpose, any personal information that has been collected without first identifying and documenting the new purpose and obtaining the consent of the employee to the use and/or disclosure of such personal information.

•  The Fund collects personal information about its employees, contractors, and/or customers for the following purposes:

Employees

•  To process applications for employment;

•  To generally administer the employment relationship; and

•  To meet legal and regulatory requirements .

Customers

•  For developing, enhancing, marketing or providing products and services;

•  To understand and meet customer needs; and

•  To meet legal and regulatory requirements.

•  Consent For Collection, Use or Disclosure of Personal Information

3.1 The Fund normally collects customer and employee information directly from our customers and employees. We may, however, collect such information from other persons with employee or customer consent, or as authorized or required by law.

3.2 The Fund will use reasonable efforts to ensure that individuals are advised of and understand how their personal information will be collected, used or disclosed, and generally obtains consent as required by law.

3.3 Generally, the Fund will seek the consent to use and disclose personal information at the same time it is collected. In determining the appropriate form of consent, the Fund will take into account the sensitivity of the personal information and the reasonable expectations of its employees and customers.

3.4 The Fund will require new employees to consent to the collection, use or disclosure of necessary personal information as a condition of employment. In general, the acceptance of and/or the continuation of employment and the continued acceptance of, or participation in, employment benefits constitutes the employee's implied consent for the Fund to collect, use and disclose personal information for all identified purposes.

3.5 The Fund will not necessarily seek express consent from existing employees and/or customers with respect to all personal information that has already been provided. However, the Fund will ensure that employees and customers are notified as to how the Fund uses and discloses this information on a "go-forward" basis. The information previously collected shall not be used or disclosed for purposes other than those for which it was originally collected. Except as otherwise stated in this Policy, if the Fund has intentions to use this information for new purposes, it will ensure consent is obtained.

3.6 The Fund requires 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.

3.7 In certain circumstances, personal information may be collected, used or disclosed by the Fund without the knowledge or consent of the individual, such as in circumstances where:

•  The collection, use or disclosure is clearly in the interest of the individual, and consent cannot be obtained in a timely way (ie., an individual is seriously ill);

•  Obtaining prior consent would defeat the purpose of collecting the information, such as an investigation of a breach of an agreement or a contravention of federal or provincial law;

•  There is an emergency, where the life, health or security of the individual is threatened;

•  Disclosure is to counsel representing the Fund;

•  The Information is publicly available; or

•  The information is otherwise required by law.

•  An employee or a customer may withdraw his/her consent at any time, subject to legal or contractual restrictions and upon providing reasonable notice. Employees and customers may contact the Vicwest Privacy Officer or designate for more information regarding the implications of withdrawing such consent. At the time that consent is withdrawn, the Fund shall inform the individual in writing with respect to the implications, if any, of the withdrawal.

•  Collection of Personal Information

4.1 The Fund will limit the amount and type of personal information collected to that which is necessary for the identified purpose(s).

4.2 Examples of the types of personal information that are collected from employees to manage the employment relationship include, but are not limited to:

•  Contact information such as home address, telephone number, date of birth, social insurance number, emergency contacts;

•  Medical information for various purposes including, but not limited to, attendance management, administration of benefits and/or assessing available workplace accommodation;

•  Education and employment history;

•  Banking or financial information where requested for the purposes of payroll; and

•  Information needed to meet regulatory or legal requirements; and

•  Any other information deemed necessary by the the Fund to administer the employment relationship.

4.3 Examples of the types of personal information that are collected from customers for the purpose of providing services to our customers include, but are not limited to, personal information needed to:

•  Process a customer order;

•  Deliver requested products or services;

•  Provide warranties for products or services; and

•  Meet regulatory or legal requirements.

•  The Fund may also collect personal information from sources other than the employee or customer, such as credit bureaus, previous employers or personal references, or any other third part y as long as those sources represent that they have the right to disclose the information.

•  Limiting Use, Disclosure And Retention of Personal Information

5.1 The Fund 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 where the use or disclosure is required by law.

5.2 The Fund shall retain personal information only as long as it is necessary for the fulfillment of the purpose for which it is collected.

5.3 The Fund shall comply with applicable laws with respect to the retention and destruction of personal information.

•  Personal information that is no longer required to fulfill the identified purposes or required by law to be retained will be destroyed by confidential means (ie., shredding). Adherence to disposal/destruction procedures for personal employee or customer information shall be strictly complied with to prevent unauthorized parties from obtaining access to the information.

•  Accuracy

6.1 Personal information used by the Fund shall be sufficiently accurate, complete and up-to-date to minimize the possibility that any inappropriate information would be used to make a decision about an employee or customer.

6.2 The Fund shall update personal information about employees and customers when necessary to fulfill the identified purpose or upon notification by the employee or customer. Employees and customers have a responsibility to ensure that their personal information is kept current.

•  Where the Fund receives revised information from employees or customers, but determines that there is no error or omission, it will annotate its records to indicate that the correction was requested but not made.

•  Security Safeguards

7.1 The Fund shall protect personal information by maintaining security safeguards which are appropriate to the sensitivity of the information.

7.2 The Fund shall protect personal information against such risks as loss or theft, unauthorized access, disclosure, copying, use, modification or destruction, through appropriate security measures. The Fund shall protect the information regardless of the format in which it is held.

7.3 The Fund has developed and implemented policies and procedures for security of personal employee information as appropriate to the sensitivity of the information. These measures include:

a) Physical measures, including, but not limited to: locked filing cabinets, desks and office areas, and restricted access to corporate file rooms.

b) Organizational measures, including, but not limited to: HR approval for access to payroll and HR files, and medical information and claims managed and retained by a third party.

c) Technological measures, including, but not limited to: password protection on computer access of payroll files, restricted key access to HR offices and corporate filing rooms.

7.4 The Fund shall protect personal employee and customer information disclosed to third parties by contractual agreement stipulating the confidential nature of the information , the obligation to maintain the confidentiality of same , and the limited purposes for which the information is to be used.

7.5 All employees of the Fund with access to personal employee or customer i nformation shall be required, as a condition of employment, to respect the confidentiality of personal employee and customer information. All employees with such access will be required to sign a confidentiality and non-disclosure agreement.

•  The Fund will make all reasonable efforts to ensure that all employees understand the importance of maintaining confidentiality of employee information by providing them with a copy of the Policy and with relevant training.

•  Openness Concerning Policies, Procedures and Practices

8.1 Upon written request by an employee or a customer, Vicwest will make available specific information about its policies and procedures relating to the management of personal information, including:

a) Identification of the individual (as designated by the Fund) to oversee the Fund's compliance with this Policy;

b) Identification of personal information held by the Fund and a general account of its use; and

c) Information with respect to how to gain access to personal information.

8.2 To make an inquiry about the Fund's personal information handling and security policies and procedures, contact Vicwest's Privacy Officer.

9. Employee And Customer Access to Personal Information

9.1 Personal information which the Fund holds with respect to employees and customers can be obtained by submitting a written request to the Director of Human Resources or designate.

9.2 Upon receipt of the request, the Fund shall afford the employee or customer a reasonable opportunity to review the personal information in the employee's file or customer's file, as applicable. The personal information shall be provided within a reasonable period of time.

9.3 In certain situations, the Fund may not be able to provide access to all of the personal information it holds regarding an employee or customer, such as where:

•  in so doing, the Fund would reveal personal information about a third party which could reasonably be expected to threaten the life or security of another individual;

•  disclosure would reveal confidential information protected by a solicitor-client privilege;

•  the information was generated in the course of formal dispute resolution processes;

•  the information was collected in relation to the investigation of a breach of an agreement or contravention of a law; or

•  the information is protected from disclosure by law.

9.4 If access to personal information cannot be provided, Vicwest shall provide the reasons for denying access to such information upon request.

•  The Fund 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, the Fund shall transmit to third parties having access to the personal information in question, any amended information or the existence of any unresolved differences.

10. Challenging Compliance

10.1 The Fund shall maintain procedures for addressing and responding to all inquiries or complaints from its customers or employees.

10.2 The Fund will investigate all complaints concerning compliance with the Privacy Policy and Procedures. The response to the investigation will be received within 30 days of receipt of a complaint.

10.3 If the complaint is found to be justified, Vicwest shall take appropriate measures to resolve the complaint, including, if necessary, amending this Privacy Policy and Procedures.

•  An employee or customer shall be informed of the outcome of the investigation regarding his or her complaint in writing.

•  Specific Privacy Provisions Relating to Use of the Fund's Website/Webpage

11.1 Nature of Information Collected Electronically

For each visitor to the Fund's Web page, the Web server will automatically recognize the visitor's domain name and e-mail address (where possible). Vicwest collects aggregate information ( which information does not include identifiable personal information ) concerning the pages that visitors access or visit, user-specific information concerning the pages visitors access or visit, information volunteered by the visitor such as , but not limited to survey information, and/or site registrations.

11.2 Purpose of Collection and Disclosure of Information Provided Electronically

The information the Fund collects is used to improve the content of its Web page and to notify visitors about updates to its Web site. This information is also shared with other reputable organizations to help them contact consumers for marketing purposes, but is not shared with other organizations for commercial purposes.

11.3. Use of Information Provided Electronically

Subject to 11.2 above, the information a customer or visitor supplies will only be used by the Fund (e.g. to respond to the customer's inquiries, supply the customer or visitor with requested information on the Fund products and services or track orders placed with the Fund). In addition, authorized third parties may be utilized by the Fund to collect, track and process such information. Any personal information collected from a customer will be treated in all with the strict terms of the Policy. If a customer or visitor has submitted personal information to the Fund electronically and would like the information removed or modified, the customer is to contact Vicwest's Privacy Officer at info@vicwest.com .

The Fund will use reasonable efforts to comply with the customer's request. However, if required by law or if the information is pertinent to a legal or government proceeding or investigation, it may be necessary to release a customer's personally identifiable information .

11.4 Special Provisions Relating to the Uses of Cookies:

(a) The Fund uses Cookies to record user-specific information on those pages users access or visit and to record past activity at a site in order to provide better service when visitors return to the site. Cookies are also used to customize web page content based on a visitor's browser type or other information that the visitor sends.

(b) If a customer/visitor does not want to receive e-mail from the Fund in the future, the customer/visitor must let the Fund know by sending the Fund an e-mail to this effect at the above address. The Fund will then remove the customer/visitor from its e-mailing list.

(c) If a customer/visitor supplies the Fund with a postal address on-line and states that he/she only requires specific information, the customer/visitor will receive only the requested information, where possible

(d) Persons who supply the Fund with their telephone numbers on-line may receive telephone contact from the Fund with information regarding orders they have placed on-line. In addition, persons who supply the Fund with their telephone numbers on-line may receive telephone contact from the Fund with information regarding new products and services or upcoming events. If a customer/visitor do es not wish to receive such telephone calls, he/she should advise the Fund by sending an e-mail to the above address and include his/her name and phone number. The Fund will then remove same from its contact list and [any other list that the Fund shares with other organizations] .

(e) Subject to section 5 above, from time to time, the Fund may use customer or visitor information for new, unanticipated uses not previously disclosed in the Fund's Privacy Policy and Procedures. If the Fund's information practices change at some time in the future the Fund will post the changes on its Web site to notify customers/visitors of these changes and provide them with the ability to opt out of these new uses. If the customer/visitor is concerned about how their information is used, they should review the use and disclosure provisions of this Policy on the Fund's Web site periodically.

(f) If customers are advised of a new purpose for which their information will be used, they may prevent their information from being used for purposes other than those for which it was originally collected by contacting Vicwest's Privacy Officer at the telephone number provided below.

(g) Upon request by a customer/visitor, the Fund will provide site visitors with access to information that it has collected and that the Fund maintains about them.

(h) Upon request by a customer / visitor, the Fund's will correct factual inaccuracies in information that the Fund's maintains about the customer / visitor.

(i) With respect to security: the Fund uses industry-standard encryption technologies when transferring and receiving customer/visitor data exchanged with its site. When the Fund transfers and receives certain types of sensitive information, such as financial or health information, the Fund redirects customers / visitors to a secure server and will notify customers / visitors through a pop-up screen on its site. The Fund has the necessary security measures in place in its physical facilities to protect against the loss, misuse or alteration of information that it has collected from customers/visitors at its site.

If a customer/visitor believes that the Fund's administration of its website is not following this Policy, an individual may contact the Fund at the following address or phone number:

VICWEST INCOME FUND
1296 South Service Road West
Oakville , On L6L 5T7

The Fund can be reached via e-mail at info@vicwest.com or by telephone at (905) 825-2252. Concerns and inquiries should be directed to Vicwest's Privacy Officer.

•  Monitoring Communications

12.1 Employees and customers (as well as visitors to the Fund's website or persons contacting the Fund by telephone) are advised that the Fund maintains the right to monitor voicemail and e-mail communications for the customer service purposes as well as to ensure compliance with this and other policies.

•  Amendment of the Privacy Policy and Procedures

13.1 The Fund reserves the right to alter, amend, and/or modify this Policy and Procedures at its sole discretion without notice provided such alterations, amendments, and/or modifications are not in contravention of applicable laws. Employees and customers will be advised of any changes to the Policy and Procedure.

VICWEST Income Fund
1296 South Service Road West
Oakville,ON, L6L 5T7

We can be reached via e-mail at info@vicwest.com
or you can reach us by telephone at (905) 825-2252