PRIVACY AND CONFIDENTIALITY POLICY SUMMARY POLICY
GLACIER-VIEW INVESTIGATIVE SERVICES INC. meets the highest ethical and professional standards in the field of private investigation in BC. Glacier-View Investigative Services Inc. is committed to maintaining the privacy of personal information with which it is entrusted.
Glacier-View Investigative Services Inc.'s - DESIGNATED PRIVACY OFFICER is: J. Wayne RUSHTON.
We believe we share a responsibility with our employees and clients for ensuring personal information is current, accurate and complete, remains secure and is used appropriately. Glacier-View Investigative Services Inc. has adopted the Canadian Standards Association's Model Code for the Protection of Personal Information (CAN/CSA-Q-830-96). Our policy is based on the 10 principles of this code:
Glacier-View Investigative Services Inc. is responsible for personal information under its control and shall designate one person who is accountable for compliance with the following principles.
2. Identifying Purpose
Glacier-View Investigative Services Inc. shall identify the purposes for which personal information is collected at or before the time the information is collected.
The knowledge and consent of clients or employees are required for the collection, use, or disclosure of personal information, except where inappropriate. In most instances, obtaining the knowledge and consent of individuals would defeat the purpose of an investigation. Personal information will only be collected, used and disclosed without consent in accordance with the definition of "investigation", as it is defined within the Personal Information Protection Act of B.C. or in accordance with section 7 of the Personal Information Protection and Electronic Documents Act, S.C. 2000, c.5 (PIPEDA).
4. Limiting Collection
Glacier-View Investigative Services Inc. shall limit the collection of personal information to that which is necessary for purposes identified by our firm. Glacier-View Investigative Services Inc. shall collect personal information by fair and lawful means.
Glacier-View Investigative Services Inc. will collect information about individuals only if there are reasonable grounds to believe that the information relates to dishonest conduct, breaches of agreements or contraventions of the laws of Canada, a province, or a foreign jurisdiction. Glacier-View Investigative Services Inc. will only collect the personal information that is required for the preventative and investigative purposes set out above.
5. Limiting Use, Disclosure and Retention
Personal information shall not be used or disclosed, for purposes other than those for which it was collected, by Glacier-View Investigative Services Inc. 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 that is collected under the definition of "investigation", as it is defined within the Personal Information Protection Act of B.C. , which means an investigation related to:
(a) a breach of an agreement,
(b) a contravention of an enactment of Canada or a province,
(c) a circumstance or conduct that may result in a remedy or relief being available under an enactment, under the common law or in equity,
(d) the prevention of fraud, or
(e) trading in a security as defined in section 1 of the Securities Act if the investigation is conducted by or on behalf of an organization recognized by the British Columbia Securities Commission to be appropriate for carrying out investigations of trading In securities, if it is reasonable to believe that the breach, contravention, circumstance, conduct, fraud or improper trading practice in question may occur or may have occurred.
Information will not be disclosed in accordance with Section 23(c)(3) of the Personal Information Protection Act of B.C., to the person under investigation under the following circumstances:
(a) the personal information is protected by solicitor-client privilege;
(b) the disclosure of the personal information would reveal confidential commercial information that if disclosed, could, in the opinion of a reasonable person, harm the competitive position of the organization;
(c) the personal information was collected without consent, as allowed under section 12, for the purposes of an investigation and the investigation and associated proceedings and appeals have not been completed;
(d) the personal information was collected or created by a mediator or arbitrator in the conduct of a mediation or arbitration for which he or she was appointed to act
(i) under a collective agreement,
(ii) under an enactment, or
(lii) by a court.
Unless consent is given by those who authorized the investigation or have the authority to release it.
Personal information shall be as accurate, complete, and up to date as is necessary for the purposes which it is to be used.
Glacier-View Investigative Services Inc. shall protect personal information by security safeguards appropriate to the sensitivity of the information. Hard copy files will be stored in locked file cabinets with restricted access. Electronic files will be stored in secure systems that include power-on password protection and a secure firewall. Electronic files will be password protected before being transferred electronically. Distribution of personal information will be on a need-to-know basis.
Glacier-View Investigative Services Inc. shall make readily available to individuals, clients and employees specific information about its policies and procedures relating to the management of personal information.
9. Individual Access
Personal information gathered within British Columbia: Glacier-View Investigative Services Inc. shall inform a client or employee of the existence, use and disclosure of his or her personal information upon request and shall give the client or employee access to that information. A client or employee shall be able to challenge the accuracy and completeness of the information and have it amended as appropriate.
If Glacier-View Investigative Services Inc. denies an individual's request for access, it will state the reasons for the denial and advise the individual of his/her right to appeal to the Office of the Privacy Commissioner of British Columbia.
Personal information gathered from provinces other than British Columbia: Personal information gathered in provinces other than British Columbia, that have not passed a Personal Information Protection Act where the Personal Information Protection & Electronics Documents Act is enforceable, will, upon request by an individual, 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.
In accordance with paragraph 9(3)(c.l) ofPIPEDA, if such disclosure does not defeat the purposes for which the information was collected, Glacier-View Investigative Services Inc. will, upon request by an individual, advise the individual whether such personal information exists concerning him or her, what that information is, what it is being used for and to whom their information has been disclosed.
If the individual can provide proof of an error in the personal information held by Glacier-View Investigative Services Inc., the firm will amend the information and send the corrected information to others who have used the incorrect information. If the individual challenges certain information but cannot disprove its accuracy, we will note the challenge so that those using the information will be aware of the unresolved challenge.
If Glacier-View Investigative Services Inc. denies an individual's request for access, it will state the reasons for the denial and advise the individual of his/her right to appeal to the Office of the Privacy Commissioner of Canada or British Columbia as the case may be.
10. Challenging Compliance
A client, individual or employee shall be able to address a challenge concerning compliance with the above principles to the designated person or persons accountable for Glacier-View Investigative Services Inc. compliance with Glacier-View Investigative Services Inc. Privacy Code.