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Our Strict Privacy Policy

R. T. Brockbank & Associates Inc. is currently licenced and regulated by the Ministry of Community Safety and Correctional Services Private Security and Investigative Services Branch. R. T. Brockbank & Associates Inc. acknowledges the existence of the Federal Personal Information Protection and Electronics Documents Act (PIPEDA).

The Council of Private Investigators of Ontario (CPIO) with additional Provincial Investigative Associations lobbied and had PIPEDA, provide private investigation firms with the designation of "Investigative Body" status. "Investigative Body" status allows for the collection and dissemination of information without the individual's consent. The Federal Regulatory Body defined a private investigative firm as one "licensed by a province to engage in the business of providing private investigators or detectives and that has a privacy code that is compliant with the Canadian Standards Association Standard CAN/CSA-Q830-96, Model Code for the Protection of Personal Information, as amended from time to time, and (ii) that is a member in good standing of a professional association that represents the interest of private investigators or detectives and that has such a privacy code." Any privacy related issues may be directed to Robert Brockbank and he will reply in kind.

Ten interrelated principles form the basis of the Canadian Standards Association Model Code for the Protection of Personal Information. Each principle is a core element in the Council of Private Investigators - Ontario (CPIO) Code of Privacy.

1. Accountability

R. T. Brockbank & Associates Inc. is responsible fo personal information under its control and compliance with the following principles;

R. T. Brockbank & Associates Inc. is committed to:
- Safeguarding personal information against improper dissemination
- Educating our staff through training about PIPEDA and the CPIO'S Code of Privacy

The CPIO'S Ethics Committee is accountable for enforcement of the CPIO'S Code of Privacy. An annual report of the Ethics Committee will be posted on the CPIO'S website.

2. Identifying Purposes

R. T. Brockbank & Associates Inc. will identify the purposes for which personal information is collected at or before the time of collection. Our firm will collect personal information to facilitate the investigation of potential contraventions of the law, breaches of agreements that may result in pending civil litigation or for intellectual purposes.

3. Consent

We will obtain the appropriate consent of the individual as required for the collection, use, or disclosure of personal information, except when PIPEDA allows an exception.

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 R. T. Brockbank & Associates Inc. without consent in accordance with section 7 of the Personal Information Protection and Electronic Documents Act (PIPEDA), S.C. 2000, c.5 (PIPEDA).

4. Limiting Collection

The personal information that we shall collect will be limited to that which is necessary for the purposes identified by R. T. Brockbank & Associates Inc.

We will collect information about individuals only if we deem reasonable grounds exist to believe that the information relates to dishonest conduct, pending civil litigation, breaches of agreements or contraventions of the laws of Canada, a Province, or a foreign jurisdiction.

5. Limiting Use, Disclosure, and Retention

Personal information shall 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 or as required by the Ministry of Community Safety and Correctional Services.

R. T. Brockbank & Associates Inc. may only use or disclose personal information for the purposes for which it was collected. R. T. Brockbank & Associates Inc. may only keep personal information for as long as may be necessary to satisfy such purpose or unless governed by a specific law. We may disclose personal information only to law enforcement agencies, regulatory bodies, other Investigative Bodies or our clients for the purpose for which the personal information was collected.

6. Accuracy

Personal information shall be as accurate, complete, and up-to-date as is necessary for the purposes for which it is to be used.

We will ensure to the best of our ability that the personal information we collect, use, and disclose is accurate, complete, current, and relevant to the stated purpose.

7. Safeguards

Security safeguards appropriate to the sensitivity of the information shall protect personal information.

R. T. Brockbank & Associates Inc. will ensure that personal information is stored in secure electronic and hard copy files. Hard copy files will be stored in locked file cabinets with restricted access. Electronic files will be stored in secure systems that include power-on password protection and a secure firewall.

8. Openness

R. T. Brockbank & Associates Inc. shall make readily available to individuals specific information about its policies and practices relating to the management of personal information.

We will make available to the public easily understandable information about our privacy policy, both in hard copy and on CPIO'S web site www.cpio.org.

9. Individual Access

Upon request with a bona fide reason as deemed by R. T. Brockbank & Associates Inc., 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. An individual may be given the opportunity to examine the accuracy and completeness of the information and have it amended as appropriate.

In accordance with paragraph 9(3)(c.1) of PIPEDA, if such disclosure does not defeat the purposes for which the information was collected, R. T. Brockbank & Associates Inc. will, upon request by an individual, advise the individual whether we have personal information concerning him or her, what that information is, what it is being used for and to whom their information has been disclosed.

If the individual can provide proof of an error in the personal information held by R. T. Brockbank & Associates Inc., we will amend the information and send the corrected information to others who have used the incorrect information. If the individual challenges certain information, but cannot disprove its accuracy, we will note the challenge so that those using the information will be aware of the unresolved challenge.

If R. T. Brockbank & Associates Inc. deny an individual's request for access, we 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 Ontario as the case may be.

A few lawful exceptions are listed below, but not limited to, which will prevent us from responding to an individual's request for access to their personal information;

  • Personal information about another individual either related or non-related to the investigation might be revealed.

  • Commercially confidential information might be revealed.

  • The information was collected without consent for the purposes related to an investigation of a breach or an agreement, pending civil litigation or contravention of a law or other lawful exemption.

  • The information is protected by the Solicitor/Client privilege.

  • When restricted from providing this disclosure by the Ministry of Community Safety and Correctional Services Private Security and investigative Services Act, 2005.

10. Challenging Compliance

An individual shall be able to address a challenge concerning compliance with the above principles to the designated individual or individuals accountable for the organization's privacy compliance.

In addition, individuals may send complaints with respect to the decisions by R. T. Brockbank & Associates Inc. in compliance with its own privacy policies and procedures to the CPIO'S Ethics Committee. The CPIO Ethics Committee will investigate the complaint and respond to the individual. If the CPIO Ethics Committee finds that R. T. Brockbank & Associates Inc. is in violation of the CPIO Code of Privacy, we will have thirty days in which to change its policies or procedures. If the individual is still not satisfied, he/she will be advised by the CPIO Ethics Committee of his or her right to appeal to the Office of the Privacy Commissioner of Canada or Ontario.


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