Privacy Policy

Introduction

ICPC is in the business of litigation and conducting investigations. We collect, use and disclose personal information. We understand the societal value in protecting personal information and ensuring its safekeeping. We at ICPC embrace the new federal Personal Information Protection and Electronics Documents Act (PIPEDA) and acknowledge the importance of national standards to protect the personal information that we collect. We will only collect personal information on individuals where there is a potential contravention of the law or breaches of agreements or other circumstances that permit us to legally collect this information under the laws of Canada. The ICPC complies to the CSA Model Code of Personal Information Privacy as follows:

1. Accountability

ICPC will be responsible for all personal information under our control. We will respond to privacy inquiries within 30 days. Its ICPC commitment to:

• Protect personal information;
• Allow individuals to make inquiries and seek amendments to their personal information;
• Train and educate our staff on privacy matters; and
• Develop information which explains these procedures to the public and our clients. 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 ICPC maintains.

2. Identify Purposes

ICPC 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 orally 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. Alternatively, an application form may be used.

ICPC may identify any new purposes that arise during the course of dealings with personal information and obtain prior consent required for this new use, even if we have already identified certain initial purposes. However, we will only do this when the intended new use purpose truly constitutes a “new” use, i.e., when the new purpose being proposed is sufficiently different from the purpose initially identified.

3. Consent

ICPC will obtain the appropriate consent from individuals for collection, use or 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 ICPC, either orally or in writing. Implied consent is when ICPC 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, 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 ICPC employees without consent in accordance with Section 7 of the Personal Information Protection and Electronics Documents Act, S.C. 2000, c.5 (PIPEDA), by court order, or under other lawful means.

4. Limiting Collection

The personal information that ICPC collects will be limited to that which is necessary for purposes we have identified. We will only collect personal information for specific, legitimate purposes. We will not collect personal information indiscriminately. We will only collect information by fair and lawful means. Our policies and procedures relating to the limitations on collection of personal information will be regularly communicated to our staff 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. ICPC will only retain personal information as long as necessary for the fulfillment of those purposes. Personal information that is no longer required to fulfill identified purposes will be destroyed, erased, or made anonymous.

6. Accuracy

The personal information ICPC collects will be accurate, complete and up-to-date as necessary for its intended purposes. Our goal is to minimize the possibility that inappropriate information may be used to make a decision about any individual whose personal information we process.

7. Safeguards

ICPC 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 filling cabinets. All ICPC staff have been properly trained in the policies that pertain to these safeguards. ICPC will take precautions in the disposal or destruction of personal information to prevent unauthorized parties from gaining access to information.

8. Openness

ICPC 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. We will make available to the public easily understandable information about our company, it’s privacy policies, the Code of Privacy, both in hard copy or by requesting a copy by email at admin@investigationcounsel.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 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:

• Personal information about another person being revealed;
• Commercially confidential information being revealed;
• The life or security of a third party being compromised;
• 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;
• The information was generated during the course of a formal dispute resolution process; and
• The information is protected by the Solicitor/Client privilege.

10. Challenging Compliance

An individual may address a challenge concerning compliance with the aforementioned policies and procedures to our office as described above.