Privacy Policy

Mastromarco Investigation Agency Inc. (M.I.A.) is a licensed, insured and bonded private investigation company. Protecting personal information we obtain is important to us. Therefore, M.I.A. supports and adheres to the federal Personal Information Protection and Electronics Documents Act (PIPEDA)

 

In accordance to PIPEDA Sec 7.1, 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.

 

The M.I.A. Code of Privacy follows and complies with the Canadian Standards Association Model Code for the Protection of Information.

 

1. Accountability

 

M.I.A. Inc. will be responsible for all personal information under our control. We have designated a Privacy Officer who is responsible for ensuring that our day-to-day procedures comply with M.I.A.’s Privacy Policy.

 

Privacy Officer
Mastromarco Investigation Agency Inc.
3800 Steeles Avenue West, Suite 310
Woodbridge, Ontario L4L 4G9
Tel: (905) 265-9710
E-mail: joe@mia-pi.ca

 

Upon receiving an enquiry, Joe Mastromarco will respond to you within 30 days.

 

M.I.A is committed to:

• Protecting personal information
• Allowing individuals to request information; seek amendments to their
  personal information
• Training and educating staff
• Developing information which explains these procedures to the public and our
  clients.

If third parties are necessary 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 M.I.A. maintains.

 

2. Identifying Purposes

 

M.I.A. will identify the purpose for which we collect personal information on affected individuals at or before the time of collection. We may choose to orally explain to affected individuals the purpose(s) 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.

 

M.I.A. may identify any new purposes that arise during the course of dealings with personal information and obtain prior consent required for this new use. However, we will only do this when the intended new 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, unless 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 M.I.A, either orally or in writing. Implied consent is when M.I.A. 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 M.I.A. 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 only collect information by fair and lawful means. We maintain the integrity of our clients as well as our company. 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 personal 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 M.I.A. 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 involves:

• Initial collection from client
• Verification, accuracy and completeness from client
• Regular reviews
• Verification of accuracy by contacting third parties (e.g. motor vehicle and driving    record authorities, etc.)

If a significant error or omission is identified, we will correct or amend the information as needed. Where necessary, we will send such corrected or amended information to third parties who have had access to the information in question.

 

7. Safeguards

 

M.I.A. will safeguard all personal information under our control in a manner that is appropriate to the sensitivity of the information. We will take all security measures necessary including, alarming and properly locking our facilities and/or locking all personal information in secure filling cabinets. All M.I.A staff, including investigators and administration staff, have been properly trained in the policies that pertain 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. Accessibility

 

M.I.A. is always readily available to our clients. Individuals requesting specific information about our policies and procedures relating to the management of personal information that is under our control can access this information by contacting our agency.

 

Investigators and staff of M.I.A. will make available to the public easily understandable information about our company; it’s privacy policies, the Code of Privacy in hard copy or by requesting a copy of it by calling toll free 1-866-774-1112.

 

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 update 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.

 

9. 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.