Barrie Confidential Inc. is committed to respecting the privacy of the personal information of its employees, clients, members and the customers of those clients.
- Evaluating and improving procedures to protect personal information
- Established procedures to receive and respond to complaints and inquiries
- Training staff and communicating to staff information about our policies and practices
- Explaining our policies and procedures to our clients and the public.
Barrie Confidential Inc. is responsible for all personal information in its possession, including information that has been transferred through any third party. When Barrie Confidential Inc. enters into a contract with a third party that involves transferring personal information to that third party, the individual(s) responsible will ensure that a comparable level of protection is available while the personal information is being processed by a third party. This will include:
- Ensuring the return of all personal information to Barrie Confidential upon completion of the contract. Example: An agreement not to use such information for any other purpose.
- The destruction of any remaining records in the possession of the third party.
The purposes for which personal information is collected shall be identified by Barrie Confidential Inc. before or at the time the information is collected. Members of Barrie Confidential Inc. shall collect personal information only for the purposes of the Investigation. Identifying individuals and organizations interested in receiving information about services at or before the time the information is collected shall identify the specific purposes for which a member of Barrie Confidential Inc. is collecting personal information. Only information that is necessary for the purposes that have been identified may be collected. The purposes for the collection shall be communicated to the subject, upon request.
The knowledge and consent of the individual are required for the collection, use or disclosure of personal information, except as provided by law.
Consent is generally required for the collection of personal information and the subsequent use or disclosure of such information. The exceptions to such requirement are specified in the federal Personal Information Protection and Electronic Documents Act (PIPEDA) and the applicable provincial statutes. Barrie Confidential Inc. shall, as a general practice, provide each employee involved in the collection of personal information with a summary of such exceptions for use as a reference.
PIPEDA and the applicable provincial statutes contain provisions allowing clients to disclose personal information for the purpose of collecting a debt owed by the individual to the client. Justice Laws Website
Barrie Confidential Inc. will not, as a condition for the supply of services, require an individual to consent to the collection, use or disclosure of personal information beyond what is necessary for such purposes.
The adequacy of the form of consent depends upon the circumstances and the type of information that is being collected. The level of sensitivity of the information will dictate the amount of detail required on the consent form. In obtaining consent, we will take the reasonable expectations of the individual into account. We will not obtain consent through deception. An individual may withdraw their consent at any time, subject to legal or contractual restrictions and reasonable notice. We will inform the individual of the implications or consequences of withdrawal.
The collection of personal information shall be limited to that which is necessary for the purposes identified by Barrie Confidential Inc. The information shall be collected by fair and lawful means. Barrie Confidential will not collect personal information indiscriminately. Both the amount and the type of information collected shall be limited to that which is needed to fulfill the purposes identified.
LIMITING USE, DISCLOSURE AND RETENTION
Personal information shall not be used or disclosed for purposes other than those for which the information was collected, except with the consent of the individual or as permitted by law. Personal information shall be retained only as long as necessary for the fulfillment of those purposes. Personal information that is no longer required to fulfill the identified purposes is destroyed, returned to the client who provided the information originally, erased or made anonymous.
Personal Information shall be accurate, complete and as up-to-date as necessary for the purposes for which it is to be used. This is particularly important where the information is being used to make some evaluation or judgment about the individual. The extent to which the personal information shall be accurate, complete and up-to-date will depend upon the use of the information, taking into account the interests of the individual.
Security safeguards appropriate to the sensitivity of the information shall protect personal information.
Barrie Confidential Inc. takes significant security safeguards to protect personal information against loss or theft, as well as unauthorized access, disclosure, copying, use or modification. The nature of the safeguards varies according to the sensitivity of the information.
Barrie Confidential Inc.’s methods of protection include physical measures, organizational measures and technological measures. All personal information is handled on a “need-to-know” basis and each member of Barrie Confidential Inc. is responsible for the protection of the personal information used in his or her job function.
Barrie Confidential Inc. regularly reinforces with all staff the importance of maintaining the security of personal information. Care is used in the disposal or destruction of personal information to prevent unauthorized parties from gaining access to the information.
Barrie Confidential Inc. shall make readily available to individuals specific information about its policies and practices relating to the management of personal information.
Barrie Confidential Inc. shall be open about its policies and practices with respect to the management of personal information. Individuals shall be able to acquire information about Barrie Confidential Inc. policies and practices without unreasonable effort. This information shall be made available in a form that is generally understandable. The information made available includes:
- How the individual may contact the firm’s Privacy Officer with respect to complaints or inquiries.
- Advice on how the individual can gain access to their personal information held by Barrie Confidential Inc. by writing to the Privacy Officer, confirming and verifying their identity, and requesting the specified information
- A description of the type of personal information held by Barrie Confidential Inc. including a general account of its use.
- A copy of any brochures or other information that explains Barrie Confidential Inc.’s policies, standards or codes
- What personal information is generally made available to related organizations.
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.
Before granting an individual access to their personal information, a member of Barrie Confidential Inc. must consult the Privacy Officer. There are restrictions on the granting of access in PIPEDA and the provincial statutes. For example; where revealing the personal information about the requesting individual will reveal information about a third party that cannot be severed from the information about the individual, the personal information cannot be disclosed. Because there are some differences between the statutes, it is important for each request to be carefully reviewed in the context of the applicable legislation.
Access may be refused, where revealing the personal information would also reveal confidential commercial information; where revealing the information could reasonably be expected to threaten the life or security of another individual; if the information was collected during an investigation of a breach of an agreement or a contravention of the laws of Canada or a Province on the expectation that the knowledge or consent of the individual would compromise the availability or accuracy of the information; or where the information was generated in the course of a formal dispute resolution process.
Upon receiving a written request, Barrie Confidential Inc. shall inform the individual whether or not we hold personal information about them. When disclosure of the personal information is made to the individual, Barrie Confidential will provide an account of the use that has been made or is being made of the information and an account of the third parties to whom the information has been disclosed.
Where the request for access relates to personal information collected, used or disclosed in the course of serving a client, the client shall immediately be provided with a copy of the request.
Barrie Confidential Inc. shall respond to an individual’s request within 30 days and at minimal or no cost to the individual. Barrie Confidential may require a reasonable payment for the information provided only if the individual is informed in advance of the approximate cost and the individual has advised us that the request is not being withdrawn.
When an individual successfully demonstrates that the personal information held by Barrie Confidential is inaccurate or incomplete, the information will be amended as required. Depending upon the nature of the information challenged, amendment(s) could involve the correction, deletion or addition of information. Where appropriate, the amended information shall be transmitted to third parties having access to the information in question.
When a challenge is not resolved to the satisfaction of the individual, Barrie Confidential Inc. shall record the substance of the unresolved challenge. When appropriate, the existence of the unresolved challenge should be transmitted to third parties having access to the information in question.
Barrie Confidential Inc.’s Privacy Officer has established procedures to receive and respond to complaints or inquiries about Barrie Confidential Inc. policies and practices relating to the handling of personal information.
The Privacy Officer is able to address any challenge(s) concerning compliance with the principles of privacy.
Barrie Confidential Inc. shall investigate all complaints. If a complaint is found to be justified through either the internal or external compliant review process, Barrie Confidential Inc. will take appropriate measures, including amending its policies and practices, if necessary.
Barrie Confidential Inc. is a fully insured Private Investigation agency licensed by The Ontario Ministry of Community Safety and Correctional Services.
Barrie Confidential Inc. is also a proud member of the Counsel of Private Investigators of Ontario (CPIO) and the Canadian Society for Industrial Securities (CSIS); CASIU Canadian Association of Special Investigation Units; CAPI Canadian Association of Private Investigators.
Please contact our Privacy Officer, at (705) 735-0002 or by fax at (705) 735-2602 with regard to any questions about our privacy policies and procedures.