S. Young Investigations Inc. (SYI) has been, and will continue to be, committed to the highest ethical and legal standards regarding privacy legislation, and other relevant legislation, that governs the way in which we conduct business. With a client base comprised primarily of the legal profession, the corporate sector, the insurance industry, and government, we recognize the need for a stringent privacy policy to protect the interests of our clients, the public, and ourselves. More specifically, SYI will adhere to the following ten principles included in Schedule 1 of PIPEDA, as set out in the Canadian Standards Association's Model Code for the Protection of Personal Information:

1. Accountability

SYI will be responsible for all personal information under its control and has designated a privacy officer to ensure our organization's compliance with the following principles.

2. Identifying Purposes

SYI shall identify the purpose(s) for which personal information is to be collected at or before the time the information is collected.

Generally, the purpose for which SYI collects 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

Except where inappropriate, SYI will obtain consent (express or implied), prior to the collection, use, or disclosure of personal information.

In most instances, obtaining the knowledge and consent of individuals would defeat the purpose of an investigation. Personal information will only be collected, used and disclosed by SYI, without consent, in accordance with section 7 of the Personal Information Protection and Electronic Documents Act, S.C. 2000, c.5 (PIPEDA).

4. Limiting Collection

SYI will limit the collection of personal information to that which is necessary for the purposes of the investigation. The information will be collected by fair and lawful means.

SYI 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. SYI 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 collected by SYI will not be used or disclosed for purposes other than those for which it was collected, except with the consent of the individual or as required by law. Personal information shall be retained only as long as necessary for the fulfillment of those purposes.

SYI may disclose personal information only to law enforcement agencies, other investigative bodies, or its clients for the purpose for which the personal information was collected.

SYI will destroy personal information in its possession once it is no longer required for the purpose for which it was collected, which will be dictated by the client of SYI.

6. Accuracy

Personal information collected, used, and disclosed by SYI will be as accurate, complete, and up-to-date as is necessary for the purposes for which it is to be used.

7. Safeguards

SYI shall protect personal information by security safeguards appropriate to the sensitivity of the information. These include: physical measures (locks, alarms, restricted access), technological tools (passwords, encryption, firewalls), and organizational controls (background checks, access on a "need-to-know basis", staff training, confidentiality agreements).

8. Openness

SYI shall make readily available to individuals specific information about its policies and practices relating to the management of personal information.

Easily understood information about SYI, its privacy policies, and this Code of Privacy are available in hard copy upon written request.

9. Individual Access

Upon request, an individual shall be informed of the existence, use and disclosure of his or her personal information and shall be given access to that information except:

• If it would reveal personal information about another individual
• if the information is subject to solicitor-client privilege
• if the information would reveal confidential commercial information\
• if disclosure could harm an individual's life or security
• if the information was collected without the individual's knowledge or consent to ensure its availability and accuracy, and the collection was reasonable for purposes related to investigating a breach of an agreement or contravention of a federal or provincial law
• if the information was generated in the course of a formal dispute resolution process

Subject to the above exceptions, an individual shall be able to challenge the accuracy and completeness of the information held by SYI. If the individual can provide proof of an error in the personal information held by SYI, SYI will amend the information and send the corrected information to others who have used the incorrect information. If the individual cannot disprove the accuracy of the information, SYI will note the challenge so that those using the information will be aware of the unresolved challenge.

If SYI denies an individual's request for access, it 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 Nova Scotia, as the case may be.

10. Challenging Compliance

An individual shall be able to address a challenge concerning compliance with the above principles to the designated Privacy Officer of SYI, namely Ms. Sherry Young.

Please direct all requests for further information, access to personal information, or complaints concerning the handling of personal information to:

Ms. Sherry Young, B.A., C.F.E.
info@syiinc.com
Facsimile: (902)404-2083