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
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:
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.
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,
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
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.
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.
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,
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
- If it would
reveal personal information about another individual
- if the information is subject to solicitor-client
- if the information would reveal confidential
- 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.