INTRODUCTION

CSI inc (CSI inc), is a Canada based company with offices in Nova Scotia and New Brunswick that handles local, national and international enquiries. Our firm and our investigators are properly licensed and are regulated by the Department of Justice and Public Safety in Nova Scotia, New Brunswick and Prince Edward Island, Canada.  As a full service security consulting and investigation firm we are in the business of conducting investigations and gathering information. CSI inc collects personal information on individuals daily. We understand the societal value in protecting personal information and ensuring its safekeeping.  At CSI inc we embrace the federal Personal Information Protection and Electronic Documents Act (PIPEDA) and acknowledge the importance of national standards that are designed to protect the personal information that we collect. In accordance with the Act, we collect personal information on individuals where there is a potential contravention of the law or breach of agreement or other circumstances that permit us to legally collect this information under the laws of Canada.

The Code of Privacy for CSI inc follows and complies with the CSA Model Code of Personal Information, Privacy and is as follows:

1. ACCOUNTABILITY

CSI inc will be responsible for all personal information under our control. We have designated several individuals to form a Privacy Committee headed up by our Chief Privacy Officer, whose responsibility it is to ensure our organization remains privacy compliant through adherence with the policies and procedures indicated in our Standards of Practice.  The Chief Privacy Officer for CSI inc is Fred Dehmel, Managing Director. Any enquires respecting privacy compliance or information management should be directed to his attention. Upon receiving an enquiry, Fred Dehmel will respond within 30 days. Fred Dehmel can be contacted at .

CSI inc has made a commitment to:

• Protect personal information under our control,
• Allow individuals to request information; seek amendments to their personal information; and file complaints against CSI inc with our Chief Privacy Officer,
• Provide continuous training on information management to our staff,
• Develop information to explain to the public and our clients, those policies and procedures that make CSI inc privacy compliant.
• 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 is employed by CSI inc.

2. IDENTIFY PURPOSES

CSI 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 corporate, government, and other clients will be vetted to ensure their requests for information are compliant with PIPEDA. We may choose to verbally explain to affected individuals the purposes for which personal information is being collected and then place a notation in the applicable file indicating that this has been done or alternatively, an application form may be used.  Subsequent to the collection of personal information, CSI inc may identify a new purpose or use for the information. In such an instance, we will seek to obtain prior consent for this new use, even if we have already identified certain initial purposes. These efforts will only be undertaken when the intended “new purpose” or “use” is markedly different from the purpose initially identified.

3. CONSENT

CSI inc will obtain the appropriate consent from individuals regarding the collection, use or disclosure of personal information, except where the law provides an exception. We may obtain express consent for the collection, use or disclosure of personal information, or may act accordingly when we determine that consent has been implied by the circumstances.  Express consent is specific authorization given by the affected individual to CSI inc, either orally or in writing. Implied consent is when CSI inc has not received a specific consent but the circumstances allow us to collect, use, or disclose personal information.  In most incidences, obtaining the knowledge and consent of individuals would defeat the purpose of an investigation, particularly with respect to a contravention of a law or breach of an agreement. Personal information will only be collected, used and disclosed by CSI inc employees without consent in accordance with Section 7 of the Personal Information Protection and Electronic Documents Act, S.C. 2000, c.5 (PIPEDA) or under other lawful means.

4. LIMITING COLLECTION

CSI inc will limit its collection of personal information to that which is necessary for purposes we have identified. We will only collect personal information for specific, legitimate purposes and will not collect personal information indiscremently.   CSI inc will only collect information by fair and lawful means, 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 will be regularly communicated to our investigators who deal with collection, use and disclosure of personal information.

5. LIMITING USE, DISCLOSURE, AND RETENTION

CSI inc will limit the use, disclosure of personal information to those purposes for which it is initially collected, except with the consent of the individual or as otherwise permitted by law. CSI inc will only retain personal information for as long as necessary to fulfill those purposes. Personal information that is no longer required to fulfill identified purposes will be destroyed, erased, or made anonymous.

Please note that there may be situations where CSI 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 (Consent).

6. ACCURACY

CSI inc will make every effort to ensure that the personal information collected for an intended purposes is accurate, complete and up-to-date. Our goal is to minimize the possibility that inappropriate or inaccurate information may be used to make a decision about any individual whose personal information we process.  The process for ensuring accuracy and compliance will involve:

• Clearly defining the client’s intended purpose / use of the personal information being requested,
• Collecting of the initial information from client,
• Asking the client to verify the accuracy and completeness of personal information they provide,
• Regularly reviewing collection procedures and sources,
• Verifying the accuracy of information by contacting third parties (e.g. motor vehicle and driving record authorities, etc.)
• 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

CSI inc will safeguard all personal information under our control in a manner that is appropriate to the sensitivity of the information. We will take all the physical security measures necessary including alarming and properly locking our facilities and/or locking all personal information in secure filing cabinets. All CSI inc investigators and administration staff have been properly trained in the policies that pertain to these safeguards.

Members of the public are not allowed access to our facilities unless identified, logged in, and escorted by properly trained staff.  Personal information under the control of CSI inc may be electronically stored. We maintain our own servers, on-site that are protected through the application of the latest technical measures as well as physical access restriction.

CSI inc has strict policy respecting the management and distribution of personal information, whether by electronic means or otherwise, and we ensure that all staff are trained in these procedures. The distribution of personal information will be on a need-to-know basis.

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

• Ensuring that no one may retrieve personal information after disposal,
• Shredding documents before recycling the chaff,
• Deleting electronically stored information,
• Destroying hard drives, memory sticks, disks, etc. when they are no longer of use and are decommissioned.

8. OPENNESS
CSI inc will make information respecting our policies and procedures which govern our information management readily available to individuals requesting same.  Investigators and staff of CSI inc will make available to the public easily understandable information about our company, our privacy policies, and our Code of Privacy.  This information is available by requesting a hard copy by contacting CSI inc at 1-888-818-5251.

9. INDIVIDUAL ACCESS

Upon request, an individual will be informed of the existence, use and disclosure of his / her personal information that is under our control. They 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 such access, which include, but are not limited to the following:

• Personal information about another person might be revealed,
• Commercially confidential information might be revealed,
• Someone’s life or security might be compromised,
• The information was collected without consent for the purposes related to an investigation of a contravention of a law or a breach of an agreement or other lawful exemption,
• The information was generated during the course of a formal dispute resolution process,
• The information is protected by the Solicitor / Client privilege,
• When restricted from providing this disclosure under other Federal or Provincial legislation.

10. CHALLENGING COMPLIANCE

An individual may address a challenge concerning compliance with the aforementioned policies and procedures to our Chief Privacy Officer whose details are listed in Section 1(Accountability).

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WEBSITE PRIVACY POLICY

Under No Circumstances will we collect any information about you without your explicit consent. From time to time we may offer product trials or downloads and may request some registration information. Such information is held in strict confidentiality. If we do collect any information from you, we will provide a convenient means of modifying such information to ensure it is correct and up to date.

CSI inc strictly guards against any unauthorized access or disclosure of your information. We do not engage in the buying or selling of your information.

CSI inc uses basic website statistics to track the number of people on our website. This information collected in no way identifies you, your computer and is not in any way traceable back to you. Our website statistics simply tell us the number of users who visit our site and which pages they visited and other anonymous information as is standard with most websites.

If for any reason whatsoever, you do not believe that your personal information is being managed according to the above paragraphs, please contact the Webmaster, and we will deal with the matter promptly.