Privacy Policy

RN Nielsen + Company Inc.
Privacy Policy

RN Nielsen & Company Inc. is in the business of providing high quality private investigation services to individuals, corporations, law firms and the insurance and risk management industry.  We are committed to the highest ethical standards and to the accuracy and careful treatment of personal information that comes into our possession as part of the services we render to our clients.  We treat personal information carefully and with respect.  RN Nielsen + Company adhere to the Council of Private Investigators-Ontario (CPIO) and the CSA Model Code of Personal Information Privacy ten interrelated principles for the Protection of Personal Information.

1.Accountability

RN Nielsen + Company Inc. are accountable for the personal information under our control.  We have designated one person to ensure our firms compliance with the policies and procedures outlined in the CPIO Code of Conduct.  Our Privacy and Compliance Officer is our firm's President, R. Norm Nielsen.  Norm can be reached at 416.778.6728.

Upon receiving an inquiry, we will respond to you within 30 days.

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 RN Nielsen + Company maintain.

2.Identifying Purposes

RN Nielsen + Company collects personal information 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 the agreement.

The purpose for which personal information is collected is identified at or before the time the information is collected.

3.Consent

We will obtain the appropriate consent from individuals for the collection, use or disclosure of personal information, except where inappropriate or the law provides an exception.  We may obtain express consent for the collection, use or 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 RN Nielsen + Company, either orally or in writing.  Implied consent is where RN Nielsen + Company Inc. has not received a specific consent but the circumstances allow us to collect, use, or disclose personal information.

In most instances, obtaining the knowledge and consent of individuals would defeat the purpose of an investigation, in particular with respect to a breach of agreement or contravention of the law.  Personal information will only be collected, used and disclosed by us without consent in accordance with section 7 of the Personal Information Protection and Electronic Documents Act, S.C. 2000. c.5 (PIPEDA) or under other lawful means.

4.Limiting Collection

The collection of personal information is limited to that which is deemed necessary for the purposes for which it is intended.  Information is collected in a fair and lawful manner for specific, legitimate purposes.  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 in our possession is only used or disclosed for the purposes for which it has been collected, except with the consent of the individual or as required by law.  Personal information is retained only as long as necessary for the fulfillment of the purposes for which it was collected.  Personal information is only disclosed to law enforcement agencies, other investigative bodies or our clients for the purpose for which the personal information was collected.

Please note that there may be situations where RN Nielsen + Company 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

RN Nielsen + Company strives to ensure that the personal information we collect is as accurate, complete, and up-to-date as is necessary for the purposes for which it has been collected.

The process for ensuring accuracy and compliance will involve:

• Initial collection from client
• Client will be asked to verify accuracy and completeness
• Regular reviews
• Verifying accuracy by contacting third parties (e.g. motor vehicle and driving authorities, etc.)

If a significant error or omission is identified, we will correct or amend the information as is 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

RN Nielsen + Company take the protection of personal information seriously.  Appropriate security safeguards are in place to ensure all sensitive personal information in our possession in electronic and hard copy files are stored in a secure environment with restricted access.  Distribution of personal information is conducted on a need-to-know basis.  All RN Nielsen + Company staff, including investigators and administrative staff, has been properly trained in the policies of that pertaining to these safeguards.

8.Openness

RN Nielsen + Company adhere to the CPIO and CSA principle of ‘Openness’.  All information about our firms Privacy Policy and practices relating to the management of personal information is available upon written request.

9.Individual Access

Upon written 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 information.  An individual shall be able to challenge 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, upon request by an individual, RN Nielsen + Company will 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 the member, the member 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, the member will note the challenge so that those using the information will be aware of the unresolved challenge.

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
• 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 exception
• 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

If an individuals request for access is denied, the individual will be informed of the reasons for the denial and their right to appeal to the Office of Privacy Commissioner of Canada or Ontario as the case may be.  

10.  Challenging Compliance

An individual shall be able to address a challenge concerning compliance with the above principles to our firms designated Privacy Officer.


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