INVESTIGATIVE CONCEPTS’ PRIVACY POLICY
Investigative Concepts is a Southwestern Ontario-based company in the business of conducting investigations and gathering information on individuals for insurance, corporate, W.S.I.B., and legal inquiries. The collection of personal information, including video surveillance images of individuals is part of our daily operation. We will only collect personal information or video images of individuals whom we have been retained to conduct an investigation on and when there has been a contravention of the law, breach in an agreement or when we can legally collect this information under the laws of Canada.
The Investigative Concepts Code of Privacy follows the CSA Model Code of Personal Information Privacy and uses the same ten interrelated principles, as follows:
1) ACCOUNTABILITY
An organization is responsible for personal information under its control and shall designate an individual or individuals who are accountable for the organization’s compliance with the following principles.
Investigative Concepts personal information officer is Timothy J. Colley. He can be contacted at 6828 Hacienda Road, Aylmer ON, N6H 2R5.
All inquiries regarding Investigative Concepts’ Privacy Policy and information about our practices should be made in writing to our privacy officer. A response to all inquiries will be made within 30 days.
2) IDENTIFYING PURPOSES
The purposes for which personal information is collected shall be identified by the organization at or before the time the information is collected.
Investigative Concepts will identify the purposes for the collection of information on affected individuals at the time an investigation file is opened and the assignment information is given. All assignments received from our clients will be reviewed in order to determine if the request for information is compliant with PIPEDA.
Investigative Concepts does not accept any domestic assignments. Our clients are insurance, legal, corporate and government professionals who use our services to identify contraventions in law or breaches of agreements.
3) CONSENT
The knowledge and consent of the individual are required for the collection, use, or disclosure of personal information, except where inappropriate. As Investigative Concepts specializes in surveillance, obtaining the knowledge and consent of individuals would defeat the purpose of the investigation. Especially when the individual is the subject of a fraud or criminal investigation. Personal information will only be collected, used and disclosed by Investigative Concepts without consent when in accordance with Section 7 of the Personal Information Protection and Electronic Documents Act, S.C. 2000, c.5 (PIPEDA).
4) LIMITING COLLECTION
The collection of personal information shall be limited to that which is necessary for the purposes identified by the organization. Information shall be collected by fair and lawful means.
Investigative Concepts only uses hands-on surveillance techniques to collect information and video tape images of individuals, and only for the purposes laid out at the beginning of the investigation. We take great pains to not invade a person’s reasonable expectation of privacy, and do not make use of telephone pretext calls. We also will not trespass on individuals’ property in order to collect our information. Only information relevant to our investigation is collected and only by fair and lawful means.
5) LIMITING USE, DISCLOSURE, AND RETENTION
Personal information shall not be used or disclosed for purposes other than those for which it was collected, except with the consent of the individual or as required by law. Personal information shall be retained only as long as necessary for the fulfillment of those purposes.
Personal information collected by Investigative Concepts will not be used or disclosed for any purposes other than those for which it is collected. It will also not be used for other related cases unless the second investigation’s purposes are laid out and the information is relevant to those purposes. No information regarding any case will be used or disclosed without the express permission of the client or individual or as required by law.
We retain personal information for only as long as necessary for the fulfillment of the purposes laid out at the beginning of the case. Personal information that is no longer required is destroyed.
6) ACCURACY
Personal information shall be as accurate, complete, and up-to-date as is necessary for the purposes for which it is to be used. Investigative Concepts will ensure that all information we collect will be as accurate and up-to-date as necessary for the purposes for which it is to be used. As the bulk of our information is in the form of video tape, our video equipment is maintained and date / time indicators are checked for accuracy on a regular basis. The proper identification of the individuals that we conduct an investigation on is a priority. No information is collected unless it is relevant to our investigative purpose.
7) SAFEGUARDS
Security safeguards appropriate to the sensitivity of the information shall protect personal information.
Investigative Concepts will safeguard all personal information under our control. We will take all the security measures necessary, including properly locking our facilities and locking information in secure filling cabinets, as well as properly monitoring our video security systems. All Investigative Concepts staff are properly trained in our policies and do not verbally communicate details of our investigations to any other persons.
Members of the public are not allowed access to our facilities unless accompanied by staff. No personal information pertaining to subjects of investigations is electronically transferred to our clients or investigators unless the electronic files have been encrypted with an industry standard encryption program before being transferred. All of our computers’ anti-virus software programs are updated regularly and are constantly monitored. None of our systems are left unattended when online and no personal information files are open when an investigator is searching online.
Any information leaving our facilities in the form of paper trash or fax ribbon is shredded and incinerated.
8) OPENNESS
An organization shall make readily available to individuals specific information about its policies and practices relating to the management of personal information.
Investigative Concepts has available to the public easily understandable information about our company and its privacy policies.
Requests for a copy of our policy can be obtained by calling toll free 1-800-561-1572 or by accessing our web site at www.investigativeconepts.ca
9) INDIVIDUAL ACCESS
Upon request, an individual shall be informed of the existence, use, and disclosure of his or her personal information and shall be given access to that information. An individual shall be able to challenge the accuracy and completeness of the information and have it amended as appropriate.
An individual who requests access to their information, should we hold any, may make a written request to the Privacy Office indicated in Section 1. Upon receiving a request, the Privacy Officer will review it and search for the applicable information. Should the information be in existence, a review of the applicable file will be made and any lawful exceptions that would prevent us from providing access will also be reviewed. These exemptions include, but are not limited to the following:
- When restricted from providing this disclosure under Section 24 of the Private Investigators and Security Guards Act as follows;
Information to be confidential- 24. No person shall divulge to anyone, except as is legally authorized or required, any information acquired by him or her as a private investigator. R.S.O. 1990, c. P.25, s. 24. (1) of the Private Investigations and Security Guards Act; Revised Statutes of Ontario 1990 Chapter P.25.” - Personal information about another person might be revealed without their consent.
- Someone’s life or well-being might be compromised.
- The information was collected without consent for the purposes related to an investigation of a breach of an agreement or contravention of a law or other lawful exemption.
- The information is protected by solicitor / client privilege.
- The information will endanger the further investigation of a breach of an agreement or contravention of a law or other lawful exemption.
10) CHALLENGING COMPLIANCE
An individual shall be able to address a challenge concerning compliance with the above principles to the designated individual or individuals accountable for the organization’s privacy compliance.
Any challenges concerning compliance with the principles can be made to the privacy officer noted in section 1.
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