INTREPID INVESTIGATIONS PRIVACY POLICY

Privacy Notice: Last Updated June 1, 2022

Intrepid Investigations Inc. is highly cognizant of the need to protect any personal information that may become known to us during the course of an investigation.  Our Privacy Code embodies the ten (10) interrelated principles that form the basis of the Canadian Standards Association Model Code for the Protection of Personal Information. Each principle meets the requirements under the Personal Information Protection and Electronic Documents Act (PIPEDA).  The Privacy Code also meets requirements of Privacy Acts at the provincial level in the regions where we operate.

1. Accountability

Intrepid Investigations Inc. is responsible for all personal information under our control. We have taken appropriate measures to develop procedures for the following:

  1. Protect personal information
  2. Receive and respond to complaints and inquiries
  3. Train our employees about policies and practices relating to the protection of personal information
  4. Distribute information explaining our policies and practices relating to the protection of personal information.

We have designated an individual, Mr. John McCowan, Vice President, as our Chief Privacy Officer to ensure our organization remains compliant with these principles as well as the policies and procedures indicated in our Code of Conduct.

The Chief Privacy Officer of Intrepid Investigations Inc. can be contacted as follows:
John McCowan, Vice-President
Intrepid Investigations Inc.
8 Director Court, Suite 201
Vaughan, Ontario L4L 3Z5

Telephone: (416) 636-9686
Toll Free Telephone: (877) 636-9686
Fax: (416) 636-7586
Email: john@intrepid.ca

2. Identifying Purposes

Intrepid Investigations Inc. collects personal information for the purpose of providing investigative services to clients when there has been a contravention of the law and/or breach of agreement, as well as, for hiring purposes.  Any additional purposes for which personal information is collected or used by our organization will be identified at the time of collection.

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.

Personal information collected for hiring purposes may include information pertaining to residency, past employment, contact information, licencing information required with respect to private investigation (including without limitation automobile, driver’s, security / private investigation licences), criminal record information, as well as, any other public record information deemed relevant. Personal information of references will be collected but limited to contact information for the purpose of vetting an applicant.

3. Consent

The knowledge and consent of the individual are required for the collection, use, or disclosure of personal information, except where the law provides an exception (see below).  We may obtain express consent or when we determine that consent has been applied by the circumstances.

Express consent is specific authorization given by the individual to Intrepid Investigations Inc., either orally or in writing.

Implied consent is when the Intrepid Investigations Inc. has not received a specific consent but the circumstances allow us to collect, use, or disclose personal information.

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 Intrepid Investigations Inc. without consent in accordance with Section 7 of the Personal Information Protection and Electronic Documents Act, S.C. 2000, c.5 (PIPEDA).

4. Limiting Collection

The collection of personal information shall be limited to that which is necessary for the purposes identified by Intrepid Investigations Inc. Information shall be collected by fair and lawful means.

Intrepid Investigations 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. Intrepid Investigations 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, 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.

Intrepid Investigations Inc. may only use or disclose personal information for the purposes for which it was collected and may only keep personal information for as long as may be necessary to satisfy such purpose or as required by law. Intrepid Investigations Inc. may disclose personal information only to law enforcement agencies, other investigative bodies, or clients for the purpose for which the personal information was collected.

Intrepid Investigations Inc. will destroy personal information in its possession once it is no longer required for the purpose for which it 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.

Intrepid Investigations Inc. will ensure to the best of their ability that the personal information they 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.

Intrepid Investigations Inc. stores personal information in secure electronic and hard copy files. Personal information collected or maintained will be protected by appropriate safeguards including, without limitation:

  1. Physical security measures, such as security alarms, locked offices and locked cabinet storage
  2. Computer safeguards such passwords, encryption, as well as network and internet controls
  3. Internal security measures, including restricted computer access and limited access to personal information collected by our organization.

We take precautions in the disposal or destruction of personal information to prevent unauthorized parties from gaining access to information. These measures include:

  1. Ensuring that no one may retrieve personal information after disposal
  2. Shredding documents before recycling them
  3. Permanently deleting electronically stored information
  4. Physically destroying hard drives when they are decommissioned

Distribution of personal information is restricted to a need-to-know basis.

8. Openness

Intrepid Investigations Inc. shall make readily available to individuals specific information about its policies and practices relating to the management of personal information. Access to personal information may be denied for a number of reasons as outlined in Principal 9 below. When lawful exceptions apply, our organization shall provide a detailed reason for the denial.

Intrepid Investigations Inc. will make available to the public easily understandable information about their company, its privacy policies, this Privacy Code, both in electronic form and hard copy.

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. We may request specific information from you to help us confirm your identity and your right to access, and to provide you with the Personal Information that we hold about you or make your requested changes.

In accordance with paragraph 9(3)(c.1) of PIPEDA, if such disclosure does not defeat the purposes for which the information was collected, Intrepid Investigations Inc. will, upon request by an individual, advise the individual whether the company has personal information concerning him or her, what that information is, what it is being used for and to whom their information has been disclosed.

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 purposes 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 the Solicitor/Client privilege.
  7. When restricted from providing this disclosure under any provincial act regulating the private investigation industry.

If Intrepid Investigations 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 the provincial equivalent as the case may be.

If an individual can provide proof of an error in the personal information held by Intrepid Investigations Inc., the company 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, Intrepid Investigations Inc. will note the challenge so that those using the information will be aware of the unresolved challenge.

10. Challenging Compliance

An individual shall be able to address a challenge concerning compliance with the above principles to the Chief Privacy Officer designated in Principle 1. 


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