Privacy Notice
As you may be aware, in an effort to address the
privacy concerns of Canadians, the federal government enacted the
Personal Information and Electronic Documents Act (PIPEDA).
The purpose
of PIPEDA, in general terms, is to regulate the collection, use and
disclosure of personal information.
Professional Development TSCM Group Inc. -
Privacy Code
Protecting the confidentiality of our client's
personal information has always been an important part of the way we do
business. To ensure that we protect your privacy, PDTG has adopted a
Privacy Code.
This Code sets out how and why we collect and use personal
information about our clients. It also explains limited circumstances,
which we may need or be required to disclose it.
“Personal Information” means information that
identifies you as a specific individual. It does not include the sort of
general information that could be found in a business directory or a
telephone book.
Effective January 1, 2004, the Government of
Canada is scheduled to implement the last phase of the Personal
Information Protection and Electronic Documents Act (PIPEDA).
This
federal statute will then apply to much of the industry sector. This
legislation establishes rules and principles for the use and disclosure
of personal information based on the ten privacy principles developed by
the Canadian Standards Association (CSA).
These principles recognize that we live in an era
where commercial information is exchanged and circulated by electronic
means. It balances the individual’s right to privacy in their personal
information with the reasonable need of organizations to collect, use or
disclose personal information.
Under the new legislation, an organization may
collect, use or disclose personal information only for a purpose that a
reasonable person would consider to be appropriate in the circumstances.
PIPEDA requires us to provide the same safeguards
for privacy and confidentiality that we have always provided on both a
voluntary and a mandated basis as has been required under the Private
Investigators and Security Guard Act - Ontario and the Private Career
College Act - Ontario.
Our Privacy Code sets out these principles in
simple terms. It explains how we ensure that your privacy and the
confidentiality of the personal information you provide are protected.
- Accountability for the Collection, Use or
Disclosure of Personal Information
- Identifying our purpose for the collection,
use or disclosure of Personal Information
- Obtaining Your Consent for the Collection,
Use or Disclosure of Personal Information
- Limiting our Collection of Personal
Information
- Limiting the Use, Disclosure and Retention of
Personal Information
- Keeping Personal Information Accurate
- Safeguarding Your Personal Information
- Openness Concerning our Privacy Practices
- Client Access to Personal Information
Challenging Compliance
As a client or student of Professional Development
TSCM Group Inc., you have a right to expect that all of the information
you provide, request of us, and the work performed or conducted by PDTG
on your behalf is accountable by PDTG for the personal information it
collects and uses.
“Client” means a current and former user of our professional services,
an authorized agent of the company, organization or representative to
which it represents.
We are responsible for maintaining and protecting all personal
information provided while it is under our control. This includes any
personal information that may need to be disclosed to third parties for
inquiries, processing or other administrative functions.
To help ensure the confidentiality of your personal information, we have
established policies and procedures to ensure that we comply with
PIPEDA.
We have designated a privacy administrator who is responsible
for our company’s compliance with the ten privacy principles dictated by
the Canadian Standard’s Association (CSA).
If you have any questions or
inquiries about how your personal information is stored, or when it may
need to be disclosed to others, our privacy administrator is there to
assist and explain our policies to you.
Identifying our purpose for the collection, use or disclosure of
Personal Information
Before or when we collect information, we will explain how we intend to
use it. PDTG collects personal information only for the following
purposes:
- To provide ongoing service to our clients.
- To conduct inquiries, research, and gather evidence which may be
required by law.
- To develop, enhance, market or provide training, and professional
services.
- To provide us with the information that we need to conduct our
professional services in a fair, legal and expeditious manner.
Unless required by law, PDTG will not use or disclose any personal
information that has been collected without obtaining the client’s
consent. The information provided to PDTG by the client is considered
privileged and may not be divulged to anyone other than the client
without implied or express permission granted by the client in writing.
Only information acquired relevant to an investigation may be conveyed
to the authorized client representative by PDTG in written, oral and or
electronic format.
Where it is required that a third party be provided privileged
information falling under the auspices of PIPEDA to effect service, only
required information will be provided to an authorized third party in
order to ensure verification and or accuracy of the information
acquired.
Where any information is received by PDTG, it will be retained
and secured and provided only to the authorized client or where required
by law.
Obtaining Your Consent for the Collection, Use or Disclosure of Personal
Information
PDTG will make a reasonable effort to make sure that our clients
understand and consent to how information will be used by our agency and
college. We will obtain your consent if we need to use information for
any other purpose and before collecting information from third parties
such as other investigative and regulated information bodies.
In all but exceptional circumstances, however, personal information may
need to be collected, used or disclosed without the knowledge and
consent of the subject of investigation.
For example, legal, medical, or security reasons may make it impossible
or impractical to seek consent. PIPEDA recognizes that when information
is being collected for the detection and prevention of fraud or for
matters including but not limited where statutes governed under federal,
provincial, municipal jurisdiction, for example but not limited to
Occupational Health and Safety Act, Worker’s Safety and Insurance Board,
Insurance Act etc. or for the purpose of law enforcement, seeking the
consent of any individual may defeat the purpose of collecting the
information.
Seeking consent may also be impossible or inappropriate
when the individual is a minor, seriously ill or mentally incapacitated.
In obtaining the client’s consent, we will always use reasonable efforts
to ensure that you are advised of the identified purposes for which any
personal information collected will be used or disclosed.
Limiting our Collection of Personal Information
We will always limit the collection of personal information to that
which is necessary for the identified purposes. Typically, this is
information that is required to enable us to conduct accurate and
responsible inquiries and or conduct investigation into specific
matters.
We may need to collect personal information from other sources
including persons or institutions providing information relative to our
inquiries.
Under certain circumstances we need to collect information to assist us
in investigating unsubstantiated claims or to prove or disprove
allegations concerning a subject of investigation.
This may involve the
use of licensed and regulated independent investigators, contractors,
and forensic experts, engineers whose skills lend to evidence gathering.
We will always collect personal information by fair and lawful means.
Limiting the Use, Disclosure and Retention of Personal Information
Personal information will not be used or disclosed for purposes other
than for which it was collected, except with your consent or as
permitted or required by law. Personal information provided will be
retained only as long as it is necessary to fulfill those purposes. PDTG
may disclose personal information to the following organizations:
- A corporation or persons as part of conducting business. This may
include a person or company or administrative personnel subject to
agreeing to manage personal information in accordance with these privacy
principles.
- Persons or corporations involved in supplying us with support services.
This may include licensed independent investigators, fire or forensic
expert, engineers and or contractors whose skills lend to the gathering
of evidence.
- A company or individuals employed by PDTG to perform data processing,
accounting, actuarial or statistical functions on our behalf.
- A company or individuals involved in the development, enhancement,
marketing or provision of our investigative products and services. This
may include a professional marketing agent or sales representative.
- An agent or agency to evaluate creditworthiness or to collect
outstanding accounts. This may include credit grantors and reporting
agencies.
- A public authority or agent of a public authority, if the information is
required to verify compliance or verify whether there exists a breach of
federal, provincial, municipal or corporate statute or governing
regulations.
- A law enforcement agency, where our client consents to such disclosure
or disclosure is required by law or emergency.
PDTG does not provide or sell its customer lists to any outside company
for use in marketing or solicitation. Only employees with a business
“need to know”, or those, whose duties require it, are granted access to
personal information about our client and subject’s of investigation.
We keep personal information only as long as it remains necessary or
relevant for the identified purposes or as required by law. Personal
information that is no longer necessary or relevant for the identified
purposes or required to be retained by law is destroyed, erased or made
anonymous.
Keeping Personal Information Accurate
PDTG makes every effort to ensure that personal information about its
clients is as accurate, complete, and up to date as is necessary for the
purposes for which it was collected.
This may require contact from time to time to confirm or update personal
information for contact purposes. If you have any questions about the
accuracy and completeness of the personal information that we have
collected or retained, please do not hesitate to contact our privacy
administrator.
If you need to update some aspect of your personal
information, please contact our administrative personnel or your
personal representative contact.
Safeguarding Your Personal Information
PDTG takes steps to protect personal information with security
safeguards appropriate to the sensitivity of the information.
Specifically, we have stringent security measures in place to protect
personal information against such risks as loss or theft, computer
hackers, unauthorized access, disclosure, copying, use, modification or
destruction.
PDTG protects your personal information regardless of the format in
which it is held. We also protect personal information we disclose to
third parties by contractual agreements stipulating the confidentiality
of the information and the purposes for which it is to be used.
Our
employees with access to personal information are required as a
condition of their employment to respect the confidentiality of personal
information.
Openness Concerning our Privacy Practices
PDTG pursues a policy of openness about the procedures it uses to manage
personal information. We will make specific information about our
policies and practices relating to the management of personal
information available to clients upon request. We ensure openness by
providing you with the following information:
- The title and address for the privacy administrator accountable for our
compliance with the policy.
- The name of the individual to whom inquiries or complaints can be
forwarded.
- The means of gaining access to personal information held by our
company or professional association.
A description of the type of personal information held by PDTG including
a general account of its use.
PDTG makes information available to help our clients exercise informed
choices regarding the use of their personal information.
Client Access to Personal Information
PDTG inform its clients of the existence, use, and disclosure of the
personal information provided upon request and provides access to that
information. Our clients are able to challenge or correct the accuracy
and completeness of their personal information and have it amended when
appropriate.
When a request is made in writing, we will inform you in a timely
fashion, of the existence, use, and disclosure of your personal
information and you will be given access to that information. In certain
situations, we may not be able to provide you with access to all of the
personal information we hold.
Exceptions may include information that is prohibitively costly to
provide, information that contains references to other individuals,
information that cannot be disclosed for legal, security or commercial
proprietary reasons, information that is subject to solicitor-client or
litigation privilege, or, in certain circumstances, information of a
medical nature and or in the case where a confidential source of
information has provided required information.
If this is the case, PDTG
will provide the reason for denying access upon request.
Clients can obtain information or seek access to their individual file
by contacting our designated privacy administrator at our Mississauga
corporate facility.
Compliance
A client has the right to challenge PDTG compliance with the above
principles by contacting the privacy administrator accountable for our
compliance with the policy.
PDTG maintains strict procedures for addressing and responding to all
inquiries or complaints from its clients about its handling of personal
information. We inform our clients about our privacy practices as well
as availability of complaint procedures, if necessary.
Our privacy administrator will investigate all complaints concerning
compliance with the privacy policy. If a complaint is found to be
justified, we will take appropriate measures to resolve the complaint
including the amendment of our policies and procedures.
Circumstances may warrant the privacy administrator accountable for
compliance with our privacy policy to seek external legal advice where
appropriate before providing a final response to individual complaints.
For further Information please contact our privacy administrator at
tsb@pdtg.ca
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