THE RENWICK GROUP INC.
PRIVACY POLICY
January 2004
INTRODUCTION
The Renwick Group Inc. prides itself on high quality investigative
services, using the latest technology and a tenacious hard work ethic,
ensuring our clients professional and detailed results.
The Renwick Group Inc. is a multi-faceted investigation company, providing
a wide range of services to insurance companies, legal firms, financial
institutions and corporations; acting pro-actively to provide evidence
to avoid costly litigation.
The Renwick Group Inc. employs a diverse network of professionals with
extensive experience in all sectors of the investigation industry. The
Renwick Group Inc. obtains information and evidence in an accurate,
timely and cost effective manner. This allows our clients to actively
manage their files.
1. ACCOUNTABILITY
The Renwick Group Inc. will be responsible for all personal information
under our control. We have designated one person to ensure our organization's
compliance with the policies and procedures indicated in our Code of
Conduct. The Privacy Officer of The Renwick Group Inc. is Katherine
Renwick and can be reached at (705) 722-9807.
Upon receiving an inquiry, Mrs. Renwick will respond to you within
30 days. It is The Renwick Group Inc. commitment to protect personal
information, allow individuals to request information; seek amendments
to their personal information; and file complaints against The Renwick
Group Inc. with our Privacy Officers, train and educate our staff, 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 The Renwick Group Inc. maintains.
2. IDENTIFY PURPOSES
The Renwick Group Inc. 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.
The Renwick Group Inc. may identify any new purposes that arise during
the course of dealings with personal information and obtain poor 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
We 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
The Renwick Group Inc., either orally or in writing. Implied consent
is when The Renwick Group Inc. 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 The Renwick Group 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 under other lawful means.
4. LIMITING COLLECTION
The personal information that we collect 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 and not by misleading or deceiving individuals about
the purposes 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 retain 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.
Please note that there may be situations where The Renwick Group 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
The personal information we collect 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.
The process for ensuring accuracy and compliance will involve:
- initial collection from client
- client will be asked to verify accuracy and completeness
- regular reviews; and
- verifying accuracy by contacting third parties (e.g. motor vehicle
and driving authorities, etc.)
If a significant error or omission identified, we will correct or amend
information as appropriate. Where necessary, we will send such corrected
or amended information to third parties that have had access to the
information in question.
7. SAFEGUARDS
The Renwick Group Inc. 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 filing cabinets. All The Renwick
Group Inc. staff, including investigators and administration staff have
been properly trained in the policies of that pertaining to these safeguards.
Members of the public are not allowed access to our facilities unless
identified logged in, and escorted by properly trained staff. No sensitive
personal information pertaining to subjects of investigations will be
electronically transferred to our clients unless the electronic files
have been encrypted with an industry standard encryption program before
being transferred. Distribution of personal information will be on a
need-to-know basis.
We will take precautions in the disposal or destruction of personal
information to prevent unauthorized parties from gaining access to information.
These measures include:
- ensuring that no one may retrieve personal information after disposal
- shredding documents before recycling them
- deleting electronically stored information
8. OPENNESS
We 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.
Investigators and staff of The Renwick Group Inc. will make available
to the public easily understandable information about our company.
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 might be revealed
- Commercially confidential information might be revealed
- Someone's life or security might be 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
- The information is protected by the Solicitor/Client privilege
- 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
aforementioned policies and procedures to our Privacy Officer whose
details are listed in Section 1.
All Content Copyright© The Renwick Group
Inc. 2002-2007
