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Privacy Policy Northwood & Associates conducts investigations and gathers information when there is a potential contravention of the law or breaches of agreements or other circumstances that permit us to legally collect this information under the laws of Canada. We are licensed and regulated by the Ministry of Public Safety & Security of Ontario, Canada. Northwood & Associates understands the importance of protecting personal information for safekeeping and agree with the Federal Personal Information Protection and Electronics Documents Act (PIPEDA). Under PIPEDA, private investigation companies have the designation "Investigative Body" status defined as a firm "licensed by a province to engage in the business of providing private investigators or detectives and that has a privacy code that is compliant with the Canadian Standards Association Standard CAN/CSA-Q830-96, Model Code for the Protection of Personal Information, as amended from time to time, and (ii) that is a member in good standing of a professional association that represents the interest of private investigators or detectives and that has such a privacy code." "Investigative Body" status allows for the collection and dissemination of information without the individual's consent if there has been a contravention of a law or breach of an agreement. Northwood & Associates is a member of the Council of Private Investigators - Ontario (CPIO) and follows and complies with their Code of Privacy and the CSA Model Code of Personal Information Privacy. Our Privacy Policy Officer is James McNamee, who may be reached through our Toronto Corporate Office. Upon receiving written inquiry, Mr. McNamee will respond within 30 days. Ten interrelated principles form the basis of the Canadian Standards Association Model Code for the Protection of Personal Information. Each principle is a core element in the Council of Private Investigators - Ontario (CPIO) Code of Privacy. 1. Accountability Northwood & Associates is responsible for personal information under its control and designated three individuals who are accountable for the company's compliance with the following principles. Northwood & Associates is committed to: The CPIO's Ethics Committee is accountable for enforcement of the CPIO's Code of Privacy. An annual report of the Ethics Committee will be posted on the CPIO's website. 2. Identifying Purposes Northwood & Associates will identify the purposes for which personal information is collected at or before the time of collection. Northwood & Associates' purpose for collecting personal information is to facilitate the investigation of contraventions of the law and breaches of agreements. Personal information collected as part of the investigation of a contravention of the law may include information pertaining to individuals involved in criminal activity, individuals suspected of involvement in criminal activity, individuals with knowledge of criminal activity, and individuals who may advance an investigation by providing information relating to the identity of those involved or suspected of criminal activity. Personal information collected in the investigation of the breach of an agreement may pertain to individuals who are party to an agreement, individuals who have knowledge of the terms and conditions of an agreement, individuals who have knowledge of the breach of an agreement, or individuals who may advance an investigation by providing information relating to a breach of an agreement. 3. Consent We will obtain the appropriate consent of the individual as required for the collection, use, or disclosure of personal information, except when PIPEDA allows an exception. 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 by Northwood & Associates without consent in accordance with section 7 of the Personal Information Protection and Electronic Documents Act (PIPEDA), S.C. 2000, c.5 (PIPEDA). 4. Limiting Collection The personal information that we shall collect will be limited to that which is necessary for the purposes identified by Northwood & Associates. Information shall be collected by fair and lawful means. We 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. We 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, 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. Northwood & Associates may only use or disclose personal information for the purposes for which it was collected. Northwood & Associates may only keep personal information for as long as may be necessary to satisfy such purpose or unless governed by a specific law. We may disclose personal information only to law enforcement agencies, other Investigative Bodies or our clients for the purpose for which the personal information was collected. 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. We will ensure to the best of our ability that the personal information we collect, use, and disclose is accurate, complete, current, and relevant to the stated purpose. 7. Safeguards Security safeguards appropriate to the sensitivity of the information shall protect personal information. Northwood & Associates will ensure that personal information is stored in secure electronic and hard copy files. 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 encrypted with an industry standard encryption program before being transferred electronically. Distribution of personal information will be on a need-to-know basis. 8. Openness Northwood & Associates shall make readily available to individuals specific information about its policies and practices relating to the management of personal information. We will make available to the public easily understandable information about our privacy policy, both in hard copy and on CPIO's web site www.cpio.org . 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. In accordance with paragraph 9(3)(c.1) of PIPEDA, if such disclosure does not defeat the purposes for which the information was collected, Northwood & Associates will, upon request by an individual, advise the individual whether we have personal information 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 Northwood & Associates, we 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 Northwood & Associates denies an individual's request for access, we 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 Ontario as the case may be. A few lawful exceptions listed below, but not limited to, will prevent us from providing an individual's request for access of their personal information: 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. Our Privacy Policy Officer is James McNamee, who may be reached through our Toronto Corporate Office. Upon receiving written inquiry, Mr. McNamee will respond within 30 days. In addition, individuals may send complaints with respect to Northwood & Associates' compliance with its own privacy policies and procedures to the CPIO's Ethics Committee. The CPIO Ethics Committee will investigate the complaint and respond to the individual. If the CPIO Ethics Committee finds that Northwood & Associates is in violation of the CPIO Code of Privacy, we will have thirty days in which to change its policies or procedures. If the individual is still not satisfied, he/she will be advised by the CPIO Ethics Committee of his or her right to appeal to the Office of the Privacy Commissioner of Canada or Ontario as the case may be. |
