• Protect personal information.
  
• Allow individuals to request information; seek amendments to their personal information; and file complaints against Stuart-Andrew International Inc. with our Privacy Officer.
  
• Train and educate our staff.
  
• Develop information which explains these procedures to the public and our clients.

The purpose for which we collect 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 from individuals for collection, use of disclosure of personal information, except where the law provides an exception. We may obtain express consent for the collection, user disclosure of personal information, or when we determine that consent has been applied by the circumstances.

Express consent is specific authorization given by the individual to Stuart-Andrew International Inc. either verbally or in writing … Implied consent is when Stuart-Andrew International 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, in particular with respect to a breach of an agreement or contravention of a law. Personal information will only be collected, used and disclosed by Stuart-Andrew International Inc. employees without consent in accordance with Section 7 of the Personal Information Protection and Electronics Documents Act, S.C. 2000, c.5 (PIPEDA) or other lawful means.

4. LIMITING COLLECTION

The personal information that we collect will be limited to that which is necessary for the purposes we have identified. We will only collect personal information for specific, legitimate purposes. We will not collect personal information indiscremently. We will only collect information by fair and lawful means and 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

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 keep personal information as long as necessary. Personal information that is no longer required to fulfill identified purposes will be destroyed.

Please note that there may be situations where Stuart-Andrew International 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.

6. ACCURACY

We 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

Stuart-Andrew International Inc. will ensure that all information is stored in secure electronic and hard copy files. Hard copy files are stored in locked file cabinets with restricted access. Electronic files are stored in secure systems that include power-on password protection and a secure firewall. Electronic files are encrypted with an industry standard encryption program before being transferred electronically. Distribution of personal information will be on a need-to-know basis.

We also take precautions in disposing or destroying personal information by shredding documents before recycling them and deleting electronically stored information.

8. OPENNESS

We will make readily available to individuals requesting specific information policies and procedures relating to the management of personal information in our control.

9. INDIVIDUAL ACCESS

Upon request, an individual will be informed of the existence, use and disclosure of personal information which is under our control, and 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 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 investigation of breach of an agreement or contravention of a law or other 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 Section 25 (1) of the Private Investigations and Security Guards Act; Revised Statutes of Ontario 1990 Chapter P.25.

10. CHALLENGING COMPLIANCE

An individual may address a challenge concerning compliance with the above policies and procedures to our Privacy Officer.