1. Accountability: Duncan Investigations is responsible for personal information under our control. We have designated JANIE DUNCAN as the Privacy Officer to be accountable for the firm's compliance with the C.S.A Standard Model Code of Personal Information Privacy. Janie can be reached at (204) 233-3439, 138 Hill Street, Winnipeg, Manitoba, R2H 2L6. Ms. Duncan has implemented strict company policies and procedures to protect personal information of clients, employees, and investigations. 2. Identifying Purposes: Duncan Investigations will identify the purposes for collecting information at or before the time the information is collected. If we collect information for a new purpose that is not identified in this file, this new purpose must be acknowledged in our file even before we use the information. Unless this new purpose is required by law, the consent of the individual will be required. 3. Consent: Duncan Investigations will ensure the knowledge and consent of the individual are required for the collection, use, or disclosure of personal information except where it is not appropriate to do so. In many cases, obtaining consent of individuals will defeat the purposes of an investigation, and therefore personal information will only be collected, used and disclosed by our firm without the consent of the individual in accordance with section 7 of the PIPEDA. 4. Limiting Use: Disclosure, and Retention: Duncan Investigations will only use and disclose personal information for the purposes for which it was collected except with the consent of the individual or as permitted by law. 5. Accuracy: Any personal information collected by Duncan Investigations shall be accurate, complete, and up-to-date as necessary for the purposes for which it was used. 6. Safeguards: All personal information will be protected by security safeguards appropriate to the sensitivity of the information. These safeguards will protect personal information against loss or theft as well as unauthorized access, disclosure, copying use, or modifications. Duncan Investigations employs the following current methods: a). Physical measures: locked office when not in use, and protected by alarm. b). All our computers have the most up to date security protections available, including the Norton Security Software, Norton Antivirus Software, Norton Anti Spam Software and Email Encryption software to protect against information leaks caused by Trojans, Sniffers, Worms and Viruses. We also use Spyware Blaster to disable and prevent illegal monitoring of our computers by remote means. c). Regularly deleting stored sensitive data from the hardrive; d). Use of shredders before recycling. 7. Openness: Duncan Investigations has made our privacy policy available publicly both on the internet, and by hard copy which is available by calling our toll free number at 1-877-233-2002. This copy will be forwarded to our Registrar of the Private Investigators & Security Guard's Act. 8. Individual Access: Upon request, an individual shall be informed of the existence, use, an disclosure of their personal information in our possession and shall be given access to that information. They can challenge the accuracy and completeness of the information and have it amended as appropriate. However, in certain situations, an individual will not be able to access this information and the reasons for denying this information shall be provided to the individual in writing. These exceptions may include the following: a). Information is prohibitively costly to provide; b). Information contains third party information; c). Restrictions from providing this information under the Private Investigators & Security Guard's Act in Manitoba. d). Information cannot be disclosed for legal, security or commercial proprietary reasons. e). Information is subject to solicitor-client or litigation privilege. f). The information was collected without the consent for purposes related to an investigation of a breach or an agreement or contravention of a law or other lawful exemption. Our Privacy officer will acknowledge or deny the access within a thirty day period from the date we receive the request. The Privacy officer will reply with a response to the request, an estimating time and cost of the inquiry. Costs for retrieval of the information will be set at $65.00 per hour, plus any disbursements, and G.S.T. 9. Challenging Compliance: An individual can at any time challenge compliance with the above principles to the Privacy officer. |
