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Privacy Code Bélanger & Assoc. Investigations Inc. is in the business of conducting investigations and gathering information. We are a provincially based company with an office in Ontario and one in Quebec. We handle inquiries locally, nationally and internationally. We collect personal information on individuals daily. We understand the value Society places on protecting personal information and ensuring its safekeeping. We at Bélanger & Assoc. Investigations Inc embrace the new federal Personal Information Protection and Electronics Documents Act and acknowledge the importance of national standards to protect the personal information that we collect. Our firm is properly licensed and regulated by the Ministry of Solicitor General of Ontario and of the Ministry of Public Security of Quebec. We will only collect personal information on individuals where there is a potential contravention of the law or breaches of agreements or other circumstances that permits us to legally collect this information under the laws of Canada. Our privacy Code complies to the CSA Model Code of Personal Information Privacy and is as follows:
Bélanger & Assoc. Investigations Inc. will be responsible for all personal information under our control. Our Privacy Officer is J. André Bélanger. He can be reached at 13A-1420 Youville Drive Orleans, Ontario K1C 7B3, 1-613-841-8665, Fax 613-841-8669, email info@belangerpi.com. Upon receiving an inquiry he will respond to you within 30 days. It is Bélanger & Assoc. Investigations Inc. commitment to: Protect personal information Allow individuals to request information, seek amendments to their personal information and file complaints against Bélanger & Assoc. Investigations Inc. with our Privacy Officer. Train and educate our staff. Develop information which explains these procedures to the public and clients. Although we rarely, if at all use third parties to process personal information we will use reasonable means to ensure that all third party transferring of personal information is afforded a comparable level of protection to that which Bélanger & Assoc. Investigations Inc. maintains.
Bélanger & Assoc. Investigations Inc. will identify the purpose for which we collect personal information on affected individuals at or before the time of collection. All assignments received from our client, corporate, government are vetted to ensure their requests for information are compliant to PIPEDA and Quebec Privacy laws. Bélanger & Assoc. Investigations Inc. may identify any new purposes that arise during the course of dealings with personal information and obtain prior consent required for this new use, even if we have already identified certain initial purposes. However we will only do this when the intended new use purpose truly constitutes a new use i.e. when the new purpose being proposed is sufficiently different from the purpose initially identified.
We will obtain or be supplied the appropriate consent from the individuals for collection use or disclosure of personal information, except where the law provides an exception. We may obtain express consent for the collection, user disclosure of personal information, or when we determine that consent has been applied by circumstances. Express consent is specific authorization given by the individual to Bélanger & Assoc. Investigations Inc. either orally or in writing. Implied consent is when Bélanger & Assoc. Investigations Inc. has not received a specified consent but the circumstances allow us to collect, use or disclose personal information. In most incidences, obtaining the consent or knowledge of the individual would defeat the purpose of an investigation, in particular with respect to a breach of an agreement or contravention of a law. Personal information will be collected, used and disclosed by Bélanger & Assoc. Investigations Inc. employees without consent in accordance with Section 7 of Personal Information Protection and Electronics Documents Act, S.C. 2000, c.5 (PIPEDA) or under other lawful means.
The personal information that we collect is limited to that which is necessary for the purpose we have identified. We only collect personal information for specific, legitimate purposes. We do not collect personal information indiscriminately. We only collect information by fair and lawful means and not by misleading or deceiving individuals about the purpose for which the information is being collected. Our policies and procedures relating to the limitations on collection of personal information are regularly communicated to our investigators who deal with collection use and disclosure of personal information.
Personal information is not used or disclosed for purposes other than those for which it is collected. Except with the consent of the individual or as permitted by the law. We only retain personal information as long as necessary for the fulfillment of those purposes. Personal information that is no longer required to fulfill identified purposes is destroyed, erased or made anonymous in accordance to the laws regulating our industry. There may be situations where Bélanger & Assoc. Investigations Inc. uses discloses or retains personal information for legitimate purposes not identified to the individual to which the information pertains, including those situations referred to in Section 3.
The personal information we collect will be accurate, complete and up to date as necessary for its intended purposes. Our goal is to minimize the possibility that inappropriate information may be used to make a decision about an individual whose personal information we process. The process for ensuring the accuracy and compliance involves:
Initial collection from client, If a significant error or omission is identified, we will correct and or amend the information as appropriate. Where necessary we will send such corrected or amended information to third parties who have had access to the information in question.
Bélanger & Assoc. Investigations Inc. will safeguard all personal information under our control in a manner that is to the sensitivity of the information. We will take all the physical security measures necessary including alarming and properly locking our facilities and placing all personal information in secure filing cabinets. Our staff including management, investigators administration have been properly vetted, trained in the policies of that pertain to these safeguards. They all have signed confidentiality and conduct agreement. Members of Public are not allowed access to our office without being identified and then are escorted by trained staff. Our data base is password protected and limited staff has access. No sensitive personal information pertaining to subjects of investigations will be electronically transferred to our clients unless the electronic files have been encrypted with an industry standard encryption program. Distribution of personal information will be on a need to know basis. We
will take necessary precautions in the disposal or destruction of
personal information to prevent unauthorized parties from gaining access
to information. These measures include:
We will make readily available to individuals requesting specific information about our policies and procedures relating to the management of personal information that is under our control. Investigators and staff of Bélanger & Assoc. Investigations Inc. will make available to the public easily understandable information about our company’s privacy policies and Code of Privacy, both in hard copy or by requesting a copy of same by calling 1-613-841-8665 or by accessing our website at www.belangerpi.com
Upon request in writing, an individual will be informed of the existence, use and disclosure of his/her personal information which is under our control and may be given access to and be permitted to challenge the accuracy and the completeness of that information. There are lawful exceptions that will prevent us from providing access, which include but are not limited to the following: 1. Personal information about another person might be revealed. 2. Commercially confidential information might be revealed. 3. Someone’s life or security might be compromised. 4. The information was collected without consent for the purpose related to an investigation of a breach or an agreement or contravention of a law or other lawful exemption. 5. The information was generated during the course of a formal dispute resolution process. 6. The information is protected by Solicitor/Client privilege.
An individual may address a challenge concerning compliance with the aforementioned policies and procedures to our Privacy Officer whose details are listed in Section 1.
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