Privacy Policy (PDF)

Effective Date September 1, 2025

1.0       Purpose

Seaspan ULC and all of its direct and indirect subsidiaries (“Seaspan”, “We” or “Our”) are committed to protecting the privacy of a l l personal information that we collect, use and maintain in connection with its operations and programs, including information about current, past and prospective customers, employees and members of the public.

Seaspan complies with all applicable privacy legislation, including the Personal Information Protection and Electronic Documents Act, S.C. 2000, c. 5 (“PIPEDA”), which applies to Seaspan’s federally regulated operations, and the Personal Information Protection Act, S.B.C., c. 63 (“PIPEDA”) which applies to its provincially regulated operations (“Applicable Privacy Laws”).

This Policy describes how Seaspan complies with applicable privacy principles when collecting, using or disclosing Personal Information about employees, customers and members of the public.

Questions about this Policy should be directed to our Privacy Officers, whose information is provided below.

2.0       SCOPE

This Policy applies to all employees, including limited term employees, and contracted service providers of Seaspan (together, “Staff”). It applies to the ways in which we collect, use, disclose and protect the personal information of Staff, customers and members of the public.

3.0       STAFF RESPONSIBILITIES

We rely on Staff to uphold and comply with their obligations under this Policy and under Applicable Privacy Laws. Staff who do not comply with these requirements may be subject to discipline, up to and including termination.

Staff must ensure that they:

  • exercise appropriate care and protect Personal Information that they access and use in the course of carrying out their employment responsibilities;
  • limit the collection, use and disclosure of Personal Information of co-workers, customers, and other individuals to what is required to carry out their authorized employment duties;
  • refrain from accessing or using Personal Information for personal or unauthorized purposes; and
  • immediately report to the Privacy Officers any access, collection, use, disclosure or the loss or theft of any Personal Information not authorized by this Policy or Applicable Privacy Laws.

4.0       POLICY

  • Definitions

Seaspan – includes Seaspan ULC, Vancouver Shipyards, Vancouver Drydock, Victoria Shipyards, Seaspan Ferries, Marine Petrobulk, and any of Seaspan’s affiliates.

Collection – means the act of gathering, acquiring, recording or obtaining Personal Information

Disclosure – means making Personal Information available to a Third Party.

Personal Information – means all information about an identifiable individual. This can include information which directly or indirectly identifies an individual. This does not include business contact information such as the name, title or business address, business email, or telephone number of an employee of an organization.

Third Party – means an individual or organization outside the applicable Seaspan legal entity.

Use – means the treatment, handling and management of Personal Information by and within an organization.

4.2       Privacy Principles

  • We are accountable for the Personal Information We Collect and Use
  1. Seaspan is responsible for Personal Information it collects, uses and discloses in the course of its operations. We have designated Privacy Officers to be accountable for the organization’s compliance with this Policy and the Applicable Privacy Laws.
  2. Seaspan views the unauthorized collection, use, and/or disclosure of the Personal Information of our customers or Staff as a serious matter. A l l Staff are expected to be familiar with and comply with this Policy.

4.2.2      The Personal Information that We Collect and Use

  1. We seek to be open and transparent about our privacy management practices, including by identifying and providing notice to affected individual of the purposes for which we may collect, use or disclose their Personal Information.
  2. We seek always to minimize the Personal Information we collect to what is required in the circumstances.
  3. We collect, use and disclose employee Personal Information that is reasonably required for purposes related to establishing, managing and terminating an employment relationship with Seaspan. This includes the following purposes:
    1. managing the recruitment process, reviewing prospective candidates and selecting employees;
    2. maintaining records to ensure accurate pay and benefits administration and employment documentation required by law;
    3. maintaining such records as are necessary and reasonably appropriate for managing Seaspan’s business and operations;
    4. for other purposes relating to managing and administering the employment relationship, including performance and conduct management, staffing and scheduling;
    5. monitoring and managing compliance with regulations and Seaspan rules and policies;
      1. managing technology and tools used by employees;
      2. for security, safety, and loss prevention;
      3. to comply with legal and regulatory requirements that apply to the employment relationship; and
      4. for purposes related to planning, evaluating and improving employment and hiring policies and practices.
  1. The categories and types of Personal Information we may collect and use for these purposes include:

a. Information needed for managing the hiring process, employment relationship, and payroll and benefits:

  • name, social insurance number, contact information, date of birth, marital status, preferred language, and employment history, education, qualifications, letters of recommendation;
  • performance information, conduct, discipline, attendance, accommodation information and agreements;
  • financial and banking information;
  • tax withholding, and information needed for payroll, pension and benefits administration;
  • information related to any workplace investigations or incidents or needed to respond to complaints and concerns.

b.     Information needed to manage use of technology and tools:

  • user names, passwords, and communications using company email address and internal and external messaging apps and tools.

c.     Information needed for compliance with regulations and internal rules:

  • information resulting from surveillance activities relating to the technology systems, information on the use of internet and telephone networks and/or mobile applications, geolocation data when using certain applications, information regarding access to intranet pages, and video surveillance.

d.     Information needed for security, safety, and loss prevention purposes:

  • authentication or access data relating to the facilities or computer systems (including identification codes, passwords and magnetic cards), footage from the video surveillance system.
  1. Seaspan will not collect, use or disclose Personal Information for other purposes not authorized under Applicable Privacy Laws without providing appropriate notices and/or obtaining necessary consents.

4.2.3      Circumstances in which We May Seek Consent

  1. In the ordinary course, we collect Personal Information on the basis of consent. Consent may be express, implied, or deemed to exist. When we collect sensitive information we may require written consents to be in place.
  2. Under Applicable Privacy Laws, we are permitted to collect some Personal Information without consent, such as when we collect Personal Information for the purposes of establishing, managing or terminating our employment relationship or where otherwise permitted under Applicable Privacy Laws.
  3. If you provide Personal Information about another individual to us (e.g., emergency contact), you are responsible for obtaining their consent to do so.
  4. Consent to the collection, use or disclosure of Personal Information may be withdrawn by contacting a Seaspan Privacy Withdrawing consent may impact our ability to provide certain services to some individuals.

4.2.4      How We Collect Personal Information

  1. We collect Personal Information by fair and lawful means, and seek always to collect Personal Information directly from affected individuals except where otherwise permitted under Applicable Privacy Laws.
  2. We comply with data minimization principles, which means that we seek to limit the amount and type of Personal Information we collect to that which is necessary in the

4.2.5      How We Use, Store and Retain Personal Information

  1. We may share personal information with our Staff or service providers for the purposes described above. In such circumstances, we will only share information on a need to know basis.
  2. Seaspan endeavours to keep Personal Information for only as long as it is needed for employment, legal or operational purposes.
  3. If we use Personal Information to make a decision that directly affects a current or prospective member of Staff we will retain the information for a reasonable period of time after using it, and for at least one year after we make the decision.

4.2.6      How We Share Personal Information

  1. We share Personal Information with our Staff and contracted service providers who need to know such information for the purposes identified above and for legal, administrative and operational purposes.
  2. We may also share personal information when we are authorized or required by law to do so (e.g. court order and subpoena).

4.2.7      How We Protect Personal Information

  1. Seaspan protects Personal Information by ensuring safeguards appropriate to the sensitivity of the information are in place, including through the following measures:
    1. Physical (i.e. locked filing cabinets, restricted access, appropriate security measures when disposing of Personal Information);
    2. Administrative (i.e. security clearances, access only on a “need to know” basis); and,
    3. Technological (i.e. passwords, firewalls, data disconnection from the internet, and regular backups) and training of Staff.
  2. Seaspan may engage the assistance of service providers or contractors with operations outside of Canada. This means Personal Information may be stored outside of Canada. While such information is outside of Canada, it is subject to the laws of the country in which it is located, and may be subject to disclosure to the governments, courts or law enforcement or regulatory agencies of such other country, pursuant to the laws of such country.

4.2.8      Accuracy

  1. We endeavor always to ensure that Personal Information, including employee Personal Information, that we collect and use is as accurate, complete, and up-to-date as necessary for the purposes for which it is In some cases, we may ask you to assist us in ensuring that your information is accurate and up-to-date.
  2. You have the right under Applicable Privacy Laws to request the correction of your Personal Information. Such requests may be directed to a Seaspan Privacy Officer.

4.2.9      Access

  1. You have the right under Applicable Privacy Laws to request access to your own Personal Information, and we will receive and respond to such requests in accordance with the requirements of those In some cases, we may refuse access to certain records or information to protect other important interests, but only to the extent permitted under Applicable Privacy Laws.
  2. You may also request information from us about the ways in which your Personal Information has been used and disclosed.
  3. To exercise these rights, please send a written request to the Privacy Seaspan will respond to all such request in accordance with applicable Personal Information protection laws in the jurisdiction in which the request was made.

4.2.10   Handling Inquiries and Challenges

We respond to inquiries and complaints that we receive regarding our privacy practices. Such inquiries and complaints should be directed to a Privacy Officer.

5.0       Seaspan’s Privacy Officers

To exercise one of your rights or if you have any questions about this Policy or if there is any reason to believe that we or anyone at Seaspan has failed to adhere to this Policy, you can contact the Seaspan Privacy Officers as follows:

NAME Brent Hale Scott Shaw
TITLE Chief Administrative Officer Senior Director, Operations HR
NUMBER 604-990-3396 604-984-5370
EMAIL [email protected] [email protected]

 

6.0       Document Version Control

Policy Change Log and Amendment History:

Date (YYYY/MM/DD) Version No. Person Responsible Description/Notes
2025-09-01 V2.000 Scott Shaw Revised Privacy policy