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Yorkey Investigation Inc., Code of Privacy

Yorkey Investigations Inc. is a Private Investigation Agency engaged in the business of conducting investigations and gathering information. The Ministry of Community Safety and Correctional Services for the Province of Ontario Canada, has licensed Yorkey Investigations and it’s Private Investigators, to investigate and collect personal information. Yorkey Investigations is committed to protecting personal information and ensuring its safekeeping. Yorkey Investigations is compliant with the Canadian Standards Association Model Code for Personal Information Protection and Electronics Documents Act (PIPEDA) and acknowledge the importance of national standards to protect the personal information that we collect.

1. ACCOUNTABILITY

Yorkey Investigations Inc. will be responsible for personal information under our control. We have designated Marlene Porter, Director of Yorkey Investigations to be accountable for the organization’s compliance with the following principles.

Marlene Porter can be reached at the following:

Marlene will respond to all complaints within 30 day.

Yorkey Investigations Inc. is responsible for;
The Protect of personal information in his/her/its control.
Training our staff in compliance with the CPIO’s Code of Privacy.
Maintain a Code of Ethics in conformity with the Ethics Committee of the CPIO.
CPIO Website address; http://cpi-ontario.com

2. IDENTIFY PURPOSES

The purpose for which we collect personal information on individuals by Yorkey Investigations Inc. will be identified at or before the time the information is collected.
The purpose for which Yorkey Investigations Inc. collect personal information is to facilitate the investigation of a contravention 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 with knowledge of criminal activity, and individuals who may advance an investigation by providing information related 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 a 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

The knowledge and consent of the individual are required for the collection, use, or disclosure of personal information, except where it is inappropriate.
An individual may give his/her expressed consent with a signed authorization or oral authorization. There may also be situations where Yorkey Investigations Inc. or it’s employees determine that there has been implied consent.

In most incidences, obtaining the knowledge and consent of individuals would defeat the purpose of an investigation. Personal information will only be collected, used and disclosed by Yorkey Investigations Inc. and its employees without consent in accordance with Section 7 of the Personal Information Protection and Electronics Documents Act, S.C. 2000, c.5 (PIPEDA) or under other lawful means.

4. LIMITING COLLECTION

The collection of personal information shall be limited to that which is necessary for the purposes identified by Yorkey Investigations Inc. Information shall be collected by fair and lawful means.
Yorkey 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. 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 will not be used or disclosed for purposes other than those for which it is collected, except with the consent of the individual or as permitted by law. We will only retain personal information as long as necessary for the fulfillment of those purposes.

Yorkey Investigations Inc. will only use or disclose personal information for the purposes for which it was collected. We will only keep personal information for as long as may be necessary to satisfy such purpose. We may disclose personal information only to law enforcement agencies, other investigative bodies or their 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 used.

Yorkey investigations 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.
If a significant error or omission is identified, we will correct 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.

7. SAFEGUARDS

Yorkey Investigations Inc. will safeguard all personal information appropriate to the sensitivity of the information, under our control.

We 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

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.

Yorkey Investigations Inc. will make available to the public easily understandable information about our company, it’s privacy policies, the Code of Privacy, both in hard copy and on our web-site www.yorkey-investigations.com.

9. INDIVIDUAL ACCESS

Upon request, 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 that information and be permitted to challenge the accuracy and the completeness of that information 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, we will, upon request by an individual, advise the individual whether Yorkey Investigations Inc. has personal information concerning him/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 Yorkey Investigations Inc., 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, Yorkey Investigations Inc., will note the challenge so that those using the information will be aware of the unresolved challenge.

If Yorkey Investigations Inc. 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.

10. CHALLENGING COMPLIANCE

An individual may address a challenge concerning compliance with the above principles to Marlene Porter.

Individuals may send complaints with respect to Yorkey Investigations Inc. 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 Yorkey Investigations Inc. is in violation of the CPIO Code of Privacy, Yorkey Investigations Inc. 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.

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