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Mitchell Lyman & Associates Inc. is a private investigations
firm, regulated by the Ministry of Community Safety and Correctional
Services, which gathers information throughout Ontario, and
Canada. In compliance with the new federal Personal Information
Protection and Electronics Documents Act (PIPEDA) we have made
available our Code Of Privacy. We understand 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. Our Code of Privacy follows and complies to the CSA Model
Code of Personal Information Privacy:
1. ACCOUNTABILITY
Mitchell Lyman Associates will be responsible for all personal
information under our control. We have designated two individuals,
headed up by Dale Lyman, our Chief Privacy Officer, to ensure
compliance with the policies and procedures indicated in our Code of Conduct.
Any enquiries should be directed to
Mitchell Lyman Associates Inc.
Hamilton Business Park
320-1100 South Service Road
Hamilton, Ontario
L8E 0C5
Telephone: (905) 643-6004
Facsimile: (905) 643-7005
Toll Free Telephone: 1-800-563-6200
E-mail: dale@mitchell-lyman.com
Upon receiving an enquiry, we will respond within 30 days.
We are committed to:
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Protect personal information and allow individuals to request their
personal information. We also acknowledge their right to change
personal information; and file complaints against Mitchell Lyman
Associates Inc. with our Privacy Officer:
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Security, Storage and Collection of all personal information in our control.
2. IDENTIFY PURPOSES
Mitchell Lyman will identify the purpose for which we collect
personal information on affected individuals at or before the time of collection.
All assignments received will undergo careful study to ensure that
the requested information is compliant with the new PIPEDA standards.
3. CONSENT
The knowledge and consent of the individual are required 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. If
information is collected with respect to an investigation involving a
suspected breach of an insurance policy, or other agreement, or
breach of Canadian law, then consent may not be obtained.
Likewise, when we believe that information relates the breach of an
insurance policy, or other agreement, or Canadian law, or where we
are required by law to disclose the information, consent may not be obtained.
In most incidences, obtaining the knowledge and consent of
individuals would defeat the purpose of an investigation. Personal
information will only be collected, used and disclosed by Mitchell
Lyman and Associates Inc. employees without consent in accordance
with Section 7 of the Personal Information Protection and Electronics
Documents Act, S.C. 2000, c.5 (PIPEDA).
4. LIMITING COLLECTION
Personal information collected will be limited to that which is
necessary for purposes identified by our organization. Our office
will only collect personal information where 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 foreign jurisdictions.
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. Personal information will only be
retained for as long as necessary for the fulfillment of those
purposes. Personal information will then be disposed of properly,
once the purpose for which it was collected is no longer relevant.
6. ACCURACY
Personal information collected will be as 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
Mitchell Lyman Associates Inc. will safeguard all personal
information under our control in a manner that is appropriate to the
sensitivity of the information. Our information is secured by
alarms and properly locked facilities and secure filling cabinets.
Distribution of personal information will be on a need-to-know basis.
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.
Mitchell Lyman Associates Inc. staff will make available to the
public easily understandable information about our company, and
our Code of Privacy, both in hard copy or by requesting a copy
of same by calling 905-643-6004 or by accessing our website at www.mitchell-lyman.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:
1. Personal information about another person might be revealed.
2. Commercially confidential information might be revealed.
3. Someone's life or security might be compromised.
4. 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.
5. The information was generated during the course of a formal
dispute resolution process.
6. The information is protected by the Solicitor/Client privilege.
7. 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. |
