Privacy Policy

THE PRIVATE INVESTIGATOR’S ASSOCIATION OF BC’S PRIVACY
CODE


Table of Contents


Introduction
Summary of Principles
Scope and Application
Definitions
The Private Investigator’s Association of BC Privacy Code in Detail
Principle 1 – Accountability
Principle 2 – Identifying Purposes for Collection of Personal Information
Principle 3 – Obtaining Consent for Collection, Use or Disclosure of Personal Information
Principle 4 – Limiting Collection of Personal Information
Principle 5 – Limiting Use, Disclosure, and Retention of Personal Information
Principle 6 – Accuracy of Personal Information
Principle 7 – Security Safeguards
Principle 8 – Openness Concerning Policies and Procedures
Principle 9 – Member and Employee Access to Personal Information
Principle 10 – Challenging Compliance
Additional Information

Introduction


At The Private Investigator’s Association of BC, respecting privacy is an important part of our
commitment to our members and employees. That is why we have developed The Private
Investigator’s Association of BC Privacy Code. The Private Investigator’s Association of BC
Privacy Code is a statement of principles and guidelines regarding the minimum requirements
for the protection of personal information provided by The Private Investigator’s Association of
BC to its members and employees. The objective of The Private Investigator’s Association of
BC Privacy Code is to promote responsible and transparent personal information management
practices in a manner consistent with the provisions of the Personal Information Protection Act
(BC) and/or where applicable Personal Information Protection and Electronic Documents Act
(Canada).

The Private Investigator’s Association of BC will continue to review The Private Investigator’s
Association of BC Privacy Code to make sure that it is relevant and remains current with
changing industry standards, technologies and laws.

Summary of Principles


Principle 1 – Accountability

The Private Investigator’s Association of BC is responsible for personal information under its
control and shall designate one or more persons who are accountable for The Private
Investigator’s Association of BC’s compliance with the following principles.

Principle 2 – Identifying Purposes for Collection of Personal Information

The Private Investigator’s Association of BC shall identify the purposes for which personal
information is collected at or before the time the information is collected.

Principle 3 – Obtaining Consent for Collection, Use or Disclosure of Personal Information

The knowledge and consent of a member or employee are required for the collection, use, or
disclosure of personal information, except where inappropriate.

Principle 4 – Limiting Collection of Personal Information

The Private Investigator’s Association of BC shall limit the collection of personal information to
that which is necessary for the purposes identified by The Private Investigator’s Association of
BC. The Private Investigator’s Association of BC shall collect personal information by fair and
lawful means.

Principle 5 – Limiting Use, Disclosure, and Retention of Personal Information

The Private Investigator’s Association of BC shall not use or disclose personal information for
purposes other than those for which it was collected, except with the consent of the individual or
as required by law.

Principle 6 – Accuracy of Personal Information

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

Principle 7 – Security Safeguards

The Private Investigator’s Association of BC shall protect personal information by security
safeguards appropriate to the sensitivity of the information.

Principle 8 – Openness Concerning Policies and Procedures

The Private Investigator’s Association of BC shall make readily available to members and
employees specific information about its policies and procedures relating to the management of
personal information.

Principle 9 – Member and Employee Access to Personal Information

The Private Investigator’s Association of BC shall inform a member or employee of the
existence, use, and disclosure of his or her personal information upon request and shall give the
individual access to that information. A member or employee shall be able to challenge the
accuracy and completeness of the information and have it amended as appropriate.

Principle 10 – Challenging Compliance

A member or employee shall be able to address a challenge concerning compliance with the
above principles to the designated person or persons accountable for The Private Investigator’s
Association of BC’s compliance with The Private Investigator’s Association of BC Privacy
Code.

Scope and Application


The ten principles that form the basis of The Private Investigator’s Association of BC Privacy
Code are interrelated and The Private Investigator’s Association of BC shall adhere to the ten
principles as a whole. Each principle must be read in conjunction with the accompanying
commentary. As permitted by the Personal Information Protection Act (BC) and/or where
applicable Personal Information Protection and Electronic Documents Act (Canada)
, the
commentary in The Private Investigator’s Association of BC Privacy Code has been drafted to
reflect personal information issues specific to The Private Investigator’s Association of BC.

The scope and application of The Private Investigator’s Association of BC Privacy Code are as
follows:

  • The Private Investigator’s Association of BC Privacy Code applies to personal
    information collected, used, or disclosed by The Private Investigator’s
    Association of BC in the course of commercial activities.
  • The Private Investigator’s Association of BC Privacy Code applies to the
    management of personal information in any form, whether oral, electronic or
    written.
  • The Private Investigator’s Association of BC Privacy Code does not impose any
    limits on the collection, use or disclosure of the following information by The Private
    Investigator’s Association of BC:

    • an employee’s name, title or business address or telephone number;
    • information that The Private Investigator’s Association of BC collects,
      uses or discloses for journalistic, artistic or literary purposes and does not
      collect, use or disclose for any other purpose; or
    • other information about the individual that is publicly available and is
      specified by regulation pursuant to the Personal Information Protection
      Act (BC) and/or where applicable Personal Information Protection and
      Electronic Documents Act (Canada).
  • The Private Investigator’s Association of BC Privacy Code will not typically
    apply to information regarding The Private Investigator’s Association of BC’s
    corporate Members. However, such information may be protected by other
    policies and practices and through contractual arrangements of The Private
    Investigator’s Association of BC.
  • The application of The Private Investigator’s Association of BC Privacy Code is
    subject to the requirements and provisions of the Personal Information Protection
    Act (BC) and/or where applicable Personal Information Protection and
    Electronic Documents Act (Canada)
    , the regulations enacted there under, and any
    other applicable legislation or regulation.

Definitions


collection: The act of gathering, acquiring, recording, or obtaining personal information from
any source, including third parties, by any means.

consent: Voluntary agreement for the collection, use and disclosure of personal information for
defined purposes. Consent can be either express or implied and can be provided directly by the
individual or by an authorized representative. Express consent can be given orally, electronically
or in writing, but is always unequivocal and does not require any inference on the part of The
Private Investigator’s Association of BC. Implied consent is consent that can reasonably be
inferred from an individual’s action or inaction.

member: An individual who purchases or otherwise acquires or uses any of The Private
Investigator’s Association of BC’s products or services or otherwise provides personal
information to The Private Investigator’s Association of BC in the course of The Private
Investigator’s Association of BC’s commercial activities.

disclosure: Making personal information available to a third party.

employee: An employee of or independent contractor to The Private Investigator’s Association
of BC.

personal information: Information about an identifiable individual, but does not include the
name, title, business address or telephone number of an employee of an organization.

name of organization: The Private Investigator’s Association of BC:

third party: An individual or organization outside of The Private Investigator’s Association of
BC.

use: The treatment, handling, and management of personal information by and within The
Private Investigator’s Association of BC or by a third party with the knowledge and approval of
The Private Investigator’s Association of BC.

The Private Investigator’s Association of BC Privacy Code in Detail


Principle 1 – Accountability


The Private Investigator’s Association of BC is responsible for personal information under its
control and shall designate one or more persons who are accountable for The Private
Investigator’s Association of BC’s compliance with the following principles.

1.1 Responsibility for compliance with the provisions of The Private Investigator’s
Association of BC Privacy Code rests with The Private Investigator’s Association of BC
Privacy Officer who can be reached at 604-878-4388 or via info@piabc.ca. Other
individuals within The Private Investigator’s Association of BC may be delegated to act
on behalf of The Private Investigator’s Association of BC Privacy Officer or to take
responsibility for the day-to-day collection and/or processing of personal information.
1.2 The Private Investigator’s Association of BC shall make known, upon request, the title of
the person or persons designated to oversee The Private Investigator’s Association of

BC’s compliance with The Private Investigator’s Association of BC Privacy Code.

1.3 The Private Investigator’s Association of BC is responsible for personal information in its
possession or control. The Private Investigator’s Association of BC shall use contractual
or other means to provide a comparable level of protection while information is being
processed or used by a third party.
1.4 The Private Investigator’s Association of BC shall implement policies and procedures to
give effect to The Private Investigator’s Association of BC Privacy Code, including:
(a) implementing procedures to protect personal information and to oversee The
Private Investigator’s Association of BC’s compliance with The Private
Investigator’s Association of BC Privacy Code;
(b) implementing procedures to receive and respond to complaints or inquiries;
(c) training and communicating to staff about The Private Investigator’s Association
of BC’s policies and procedures; and
(d) developing information materials to explain The Private Investigator’s
Association of BC’s policies and procedures.

Principle 2 – Identifying Purposes for Collection of Personal Information

The Private Investigator’s Association of BC shall identify the purposes for which personal
information is collected at or before the time the information is collected.

2.1 The Private Investigator’s Association of BC collects personal information only for the
following purposes:
Member services:
  • Contact and billing member services
  • Information relating to individual’s eligibility for membership in accordance with
    association by-laws
  • Information to determine individual’s eligibility for participation in association programs
  • Carrying out investigations regarding member compliance with association by-laws and
    code of ethics
Employees:
  • Employment related purposes for payment, tax related, and other purposes relating to
    personnel management.Further reference to “identified purposes” mean the purposes identified in this Principle.
2.2 The Private Investigator’s Association of BC shall specify orally, electronically or in
writing the identified purposes to the member or employee at or before the time personal
information is collected. Upon request, persons collecting personal information shall
explain these identified purposes or refer the individual to a designated person within The
Private Investigator’s Association of BC who can explain the purposes.
2.3 When personal information that has been collected is to be used or disclosed for a
purpose not previously identified, the new purpose shall be identified prior to use. Unless
the new purpose is permitted or required by law, the consent of the member or employee
will be acquired before the information will be used or disclosed for the new purpose.

Principle 3 – Obtaining Consent for Collection, Use or Disclosure of Personal
Information


The knowledge and consent of a member or employee are required for the collection, use, or
disclosure of personal information, except where inappropriate. In certain circumstances
personal information can be collected, used, or disclosed without the knowledge and consent
of the individual.

3.1 In obtaining consent, The Private Investigator’s Association of BC shall use reasonable
efforts to ensure that a member or employee is advised of the identified purposes for
which personal information will be used or disclosed. The identified purposes shall be
stated in a manner that can be reasonably understood by the member or employee.
3.2 Generally, The Private Investigator’s Association of BC shall seek consent to use and
disclose personal information at the same time it collects the information. However, The
Private Investigator’s Association of BC may seek consent to use and/or disclose
personal information after it has been collected, but before it is used and/or disclosed for
a new purpose.
3.3 The Private Investigator’s Association of BC may require members to consent to the
collection, use and/or disclosure of personal information as a condition of the supply of a
product or service only if such collection, use and/or disclosure is required to fulfill the
explicitly specified, and legitimate identified purposes.
3.4 In determining the appropriate form of consent, The Private Investigator’s Association of
BC shall take into account the sensitivity of the personal information and the reasonable
expectations of its members and employees.
3.5 The purchase or use of products and services by a member, or the acceptance of
employment or benefits by an employee, may constitute implied consent for The Private
Investigator’s Association of BC to collect, use and disclose personal information for the
identified purposes.
3.6 A member or employee may withdraw consent at any time, subject to legal or contractual
restrictions and reasonable notice. Members and employees may contact The Private
Investigator’s Association of BC for more information regarding the implications of
withdrawing consent.
3.7 The Private Investigator’s Association of BC may collect or use personal information
without knowledge or consent if it is clearly in the interests of the individual and consent
cannot be obtained in a timely way, such as when the individual is seriously ill or
mentally incapacitated.
3.8 The Private Investigator’s Association of BC may collect, use or disclose personal
information without knowledge or consent if seeking the consent of the individual might
defeat the purpose of collecting, using or disclosing the information, such as in the
investigation of a breach of an agreement or a contravention of a law or where it is
reasonable to expect the consent may compromise the investigation.
3.9 The Private Investigator’s Association of BC may collect, use or disclose personal
information without knowledge or consent in the case of an emergency where the life,
health or security of an individual is threatened.
3.10 The Private Investigator’s Association of BC may use or disclose personal information
without knowledge or consent to a lawyer representing The Private Investigator’s
Association of BC, to collect a debt, to comply with a subpoena, warrant or other court
order, or as may be otherwise required or authorized by law.

Principle 4 – Limiting Collection of Personal Information


The Private Investigator’s Association of BC shall limit the collection of personal information
to that which is necessary for the purposes identified by The Private Investigator’s Association
of BC. The Private Investigator’s Association of BC shall collect personal information by fair
and lawful means.

4.1 The Private Investigator’s Association of BC collects personal information primarily
from its members and employees.
4.2 The Private Investigator’s Association of BC may also collect personal information from
other sources including credit bureaus, employers or personal references, or other third
parties who represent that they have the right to disclose the information.

Principle 5 – Limiting Use, Disclosure, and Retention of Personal Information


The Private Investigator’s Association of BC shall not use or disclose personal information for
purposes other than those for which it was collected, except with the consent of the individual
or as required or permitted by law. The Private Investigator’s Association of BC shall retain
personal information only as long as necessary for the fulfillment of those purposes.

5.1 The Private Investigator’s Association of BC may disclose a member’s personal
information to:
  • It’s employees/directors/committee designates for purposes of providing membership
    services
  • Other members limited to the consent for release of the information is authorized by the
    member
  • Licensing or statutory authority as required by law
5.2 The Private Investigator’s Association of BC may disclose personal information
about its employees:
  • Tax authorities as required by provisions of the Income Tax Act
  • WCB authorities as required by law
  • Any other authority as required by law or statute
5.3 Only the Private Investigator’s Association of BC’s employees with a business need-toknow, or whose duties reasonably so require, are granted access to personal information
about members and employees.
5.4 The Private Investigator’s Association of BC shall keep personal information only as
long as it remains necessary or relevant for the identified purposes or as required by law.
Depending on the circumstances, where personal information has been used to make a
decision about a member or employee, The Private Investigator’s Association of BC shall
retain, for a period of time that is reasonably sufficient to allow for access by the member
or employee, either the actual information or the rationale for making the decision.
5.5 The Private Investigator’s Association of BC shall maintain reasonable and systematic
controls, schedules and practices for information and records retention and destruction
which apply to personal information that is no longer necessary or relevant for the
identified purposes or required by law to be retained. Such information shall be
destroyed, erased or made anonymous.

Principle 6 – Accuracy of Personal Information


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

6.1 Personal information used by The Private Investigator’s Association of BC shall be
sufficiently accurate, complete, and up-to-date to minimize the possibility that
inappropriate information may be used to make a decision about a member] or employee.
6.2 The Private Investigator’s Association of BC shall update personal information about
Members and employees as necessary to fulfill the identified purposes or upon
notification by the individual.

Principle 7 – Security Safeguards


The Private Investigator’s Association of BC shall protect personal information by security
safeguards appropriate to the sensitivity of the information.

7.1 The Private Investigator’s Association of BC shall protect personal information against
such risks as loss or theft, unauthorized access, disclosure, copying, use, modification or
destruction, through appropriate security measures, regardless of the format in which it is
held.
7.2 The Private Investigator’s Association of BC shall protect personal information disclosed
to third parties by contractual agreements stipulating the confidentiality of the
information and the purposes for which it is to be used.
7.3 All of The Private Investigator’s Association of BC’s employees with access to personal
information shall be required to respect the confidentiality of that information.

Principle 8 – Openness Concerning Policies and Procedures


The Private Investigator’s Association of BC shall make readily available to Members and
employees specific information about its policies and procedures relating to the management
of personal information.

8.1 The Private Investigator’s Association of BC shall make information about its policies
and procedures easy to understand, including:
(a) the title and address of the person or persons accountable for The Private
Investigator’s Association of BC’s compliance with The Private Investigator’s
Association of BC Privacy Code and to whom inquiries and/or complaints can be
forwarded;
(b) the means of gaining access to personal information held by The Private
Investigator’s Association of BC;
(c) a description of the type of personal information held by The Private
Investigator’s Association of BC, including a general account of its use; and
(d) a description of what personal information is made available to related
organizations (e.g., subsidiaries).
8.2 The Private Investigator’s Association of BC shall make available information to help
members and employees exercise control of the collection, use and/or disclosure of their
personal information and, where applicable, privacy-enhancing services available from
The Private Investigator’s Association of BC.

Principle 9 – Member and Employee Access to Personal Information


Upon request, The Private Investigator’s Association of BC shall inform a member or
employee of the existence, use, and disclosure of his or her personal information and shall
give the individual access to that information. A member or employee shall be able to
challenge the accuracy and completeness of the information and have it amended as
appropriate.

9.1 Upon request, The Private Investigator’s Association of BC shall afford members and
employees a reasonable opportunity to review the personal information in the
individual’s file. Personal information shall be provided in understandable form within a
reasonable time, and at minimal or no cost to the individual.
9.2 In certain situations, The Private Investigator’s Association of BC may not be able to
provide access to all the personal information that it holds about a member or employee.
For example, The Private Investigator’s Association of BC may not provide access to
information if doing so would likely reveal personal information about a third party or
could reasonably be expected to threaten the life or security of another individual. Also,
The Private Investigator’s Association of BC may not provide access to information if
disclosure would reveal confidential commercial information, if the information is
protected by solicitor-member privilege, if the information was generated in the course of
a formal dispute resolution process, or if the information was collected in relation to the
investigation and it is reasonable to expect the access would compromise the
investigation or in relation to an investigation of a breach of an agreement or a
contravention of the laws of Canada or a province.
9.3 Upon request, The Private Investigator’s Association of BC shall provide an account of
the use and disclosure of personal information and, where reasonably possible, shall state
the source of the information. In providing an account of disclosure, The Private
Investigator’s Association of BC shall provide a list of third parties to which it may have
disclosed personal information about the individual when it is not possible to provide an
actual list.
9.4 In order to safeguard personal information, a member or employee may be required to
provide sufficient identification information to permit The Private Investigator’s
Association of BC to account for the existence, use and disclosure of personal
information and to authorize access to the individual’s file. Any such information shall
be used only for this purpose.
9.5 The Private Investigator’s Association of BC shall promptly correct or complete any
personal information found to be inaccurate or incomplete. Any unresolved differences
as to accuracy or completeness shall be noted in the individual’s file. Where appropriate, -12-
The Private Investigator’s Association of BC shall transmit to third parties having access
to the personal information in question any amended information or the existence of any
unresolved differences.
9.6 Members and employees can obtain information or seek access to their individual files by
contacting The Private Investigator’s Association of BC Privacy Officer.

Principle 10 – Challenging Compliance


A member or employee shall be able to address a challenge concerning compliance with the
above principles to the designated person or persons accountable for The Private
Investigator’s Association of BC’s compliance with The Private Investigator’s Association of
BC Privacy Code.

10.1 The Private Investigator’s Association of BC shall maintain procedures for addressing
and responding to all inquiries or complaints from its members and employees regarding
The Private Investigator’s Association of BC’s handling of personal information.
10.2 The Private Investigator’s Association of BC shall inform its members and employees
about the existence of these procedures as well as the availability of complaint
procedures.
10.3 The person or persons accountable for compliance with The Private Investigator’s
Association of BC Privacy Code may seek external advice where appropriate before
providing a final response to individual complaints.
10.4 The Private Investigator’s Association of BC shall investigate all complaints concerning
compliance with The Private Investigator’s Association of BC Privacy Code. If a
complaint is found to be justified, The Private Investigator’s Association of BC shall take
appropriate measures to resolve the complaint including, if necessary, amending its
policies and procedures. A member or employee shall be informed of the outcome of the
investigation regarding his or her complaint.

Additional Information

For more information regarding The Private Investigator’s Association of BC Privacy Code,
please contact The Private Investigator’s Association of BC Privacy Officer at 604-878-4388 or
via info@piabc.ca