Introspec Investigation Inc. is engaged in the business of providing quality corporate investigative and litigation services and in doing so is committed to protecting the personal information of individuals. “Personal information” means information in any format which is about an identifiable individual (other than the name, title, business address or phone number of any employee of an organization). We have implemented the following privacy policy in order to protect personal information which we collect or which is disclosed to us.

Introspec protects personal information in accordance with the requirements of Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA) which sets out standards pertaining to the collection, use and disclosure of personal information in the Model Code for the Protection of Personal Information. Our organization applies the ten principles of the Model Code as follows: 

1.         Accountability
Introspec acknowledges that is responsible for personal information collected and maintained by it or which is under its control. Out organization has taken appropriate measures to develop procedures to:

a)  Protect personal information.
b)  Receive and respond to complaints and inquiries.
c)  Train our employees about policies and practices relating to the protection of personal information.
d)  Distribute information explaining our policies and practices relating to the protection of personal information.  

We have designated an individual within our organization as our “privacy officer”, who may be contacted as follows:

Address:
Introspec Investigation Inc. – Privacy Officer
1 – 2285 Dunwin Drive
Mississauga, ON  L5L 3S3
Phone: 905-820-4100
Fax: 905-820-4181
E-Mail: privacy@ introspec.com

and who shall be responsible for coordinating our organization’s compliance with the following principles. 

2.         Purposes 

The purpose for which personal information is collected and used by Introspec is to provide investigative services to clients, including services such as investigative accounting and fraud audits, IT security and data recovery, investigations of conflict of interest claims, theft of trade secrets, secret commissions, employee harassment claims, benefits abuse, labour disputes, employee screening and wrongful dismissal claims, retail loss prevention, investigation of litigation claims, security audits and C-TPAT, electronic surveillance detection and debugging, intellectual property protection and trademark and copyright claims, and grey marketing and parallel trading claims and corporate due diligence and market investigation. Additional purposes for which personal information is collected or used by our organization may be identified at the time of collection of such information.

3.         Consent 

Introspec requires that an individual’s knowledge and consent be obtained for the collection, use or disclosure of their personal information, except when inappropriate. In most instances obtaining such consent will be inappropriate since Introspec is collecting personal information pursuant to the investigation of a breach of an agreement or a contravention of the laws of Canada or a province, or in the course of litigation or dispute resolution. Introspec will only use or disclose personal information without consent in accordance with the exceptions set out in section 7 of the Personal Information Protection and Electronic Documents Act (PIPEDA) of Canada and in this regard it should be noted that Introspec: 

a)                 is an “investigative body” further to the regulation made pursuant to section 26(1)(a.01) of the said Act

b)                 is licensed and regulated by the ministry of the Solicitor General in Ontario

c)                 is a member in good standing of the Council of Private Investigators of Ontario.

 Consent to the collection, use or disclosure of personal information by Introspec is deemed to be given either by any individual’s unrestricted release of any such personal information to Introspec or the public domain, or by the individual’s express written or oral consent as obtained through an interview or discussion and review process. Where consent to the collection, use or disclosure of personal information has expressly or impliedly been given to Introspec. You may withdraw your consent at any time upon reasonable notice, subject to legal or contractual restrictions, by contacting the privacy officer designated in principle 1.

4.                  Collection 

Introspec limits the collection of personal information to that which is necessary for the purposes identified by our organization. Personal information will only be collected by fair means in accordance with applicable laws. With respect to internet and web site administration, Introspec does not collect NETBIOS information relating to the IP address of any computer and only uses temporary (and not permanent) “cookies” which are automatically deleted from the user’s browser upon logging out of our web site (“cookies” being small text files that can collect and store a variety of information).

5.         Use, Disclosure & Retention 

Personal information will not be used or disclosed by Introspec for purposes other than those for which it was originally collected, except with the consent of the individual or as required by law. Personal information will be retained by our organization only as long as necessary for fulfillment of the purposes for which it was originally collected. Our organization shall use care when storing or destroying personal information in order to prevent unauthorized access.

6.         Accuracy 

Personal information maintained by our organization shall be as accurate, complete, and up-to-date as is necessary for the purposes for which it is to be used. If you have any concerns about the accuracy of personal information or if any concerns about the accuracy of personal information or if any information needs to be updated to reflect a change in situation, please contact the privacy officer of Introspec designated in principle 1.

7.         Safeguards 

Personal information collected or maintained by Introspec will be protected by appropriate safeguards. These safeguards include:

a)                 physical security measures, such as security alarms, video surveillance and locked offices and cabinet storage

b)                 computer safeguards such passwords and network and internet controls

c)                 internal security measures, including restricted computer access and limited access to personal information collected by our organization.

8.         Openness 

Introspec will make specific information available about its policies and practices relating to the protection of personal information. Please forward any inquiries to the privacy officer designated in principle 1.

9.         Access 

Upon request made to Introspec, an individual may be informed of the existence, use and disclosure of his or her personal information and may be given access to that information, and in such event the individual will be able to challenge the accuracy and completeness of the information and have it amended as appropriate. Kindly forward any inquiries to the designated privacy officer identified in principle 1. In most cases, however, access to personal information may be denied for the reason that it involves the investigation of a breach of an agreement or a contravention of the laws of Canada or a province. If at any time we are unable to provide you with access to the personal information we hold regarding you, then our organization shall provide you with the reasons for the denial of access.

10.       Compliance 

An individual may address a challenge concerning Introspec’s compliance with the principles governing the collection, use or disclosure of personal information by referring any inquiries to the privacy officer designated in principle 1. Introspec will take appropriate measures to resolve any complaint which is justified relating to the management of personal information, including amending our policies and practices if necessary.