Privacy Policy

Privacy Code

Progress Investigations Corporation is committed to protecting the privacy, confidentiality, accuracy and security of the personal information that it collects, uses, retains and discloses in the course of conducting business.

“Personal Information” is information – oral, electronic or written – about an identifiable individual, including (but not limited to):

  • Name, address and telephone numbers
  • Age, gender, family and marital status
  • Driving record
  • Previous insurance and claims experience
  • Employment information
  • Banking information, credit rating, payment records
  • Identification numbers
  • Assets and liabilities.

“Personal Information” – is not information, which is collected from a publicly listed, written or on-line source.

The following definitions apply in this code:

  • “Collection” – the act of gathering, acquiring or obtaining personal information from any source, including from third parties, by any means. Progress Investigation Corporation may collect personal information necessary to carry on the business of investigations.
  • “Consent” – voluntary agreement with what is being done or proposed. Consent can be either expressed or implied. Expressed consent is given explicitly, either orally or in writing. Expressed consent is unequivocal and does not require any influence on the part of Progress Investigations seeking consent. Implied consent arises where consent may be reasonably inferred from the action or inaction of the individual about whom Progress Investigations is collecting personal information in order to conduct its business.
  • “Disclosure” – making personal information available to others outside Progress Investigations
    Corporation.
  • “Use” – treatment and handling of personal information within Progress Investigation.

Accountability: Progress Investigations is responsible for the personal information under its control and has designated a Privacy Officer to be accountable for compliance with this policy. Our Privacy Officer is Glenn Spillett.

Identifying Purposes: Progress Investigations will identify the purposes for collecting personal information at or before the time the information is collected.

Consent: Progress Investigations will only collect, use or disclose personal information with knowledge and consent of the individuals, except where consent is not required by law.

Limiting Collection: Personal information collected must be limited to the information necessary for the purposes identified. Information must be collected by fair and lawful means.

Limiting Use, Disclosure and Retention: Progress Investigations will not use or disclose personal information for purposes other than those for which it was collected, except with consent or as required by law. Personal information will be retained only if necessary, for the fulfillment of those purposes.

Accuracy of Information: Personal information will be as accurate, complete and up to date as is necessary or available for the purposes for which it must be used.

Safeguards: Appropriate safeguards and security measures are required to protect personal information from loss or theft and to safeguard it against unauthorized use, access, alteration, copying, destruction or disclosure.

Openness: Progress Investigations will make available to individuals’ specific information about our policies and practices relating to the management of personal information.

Individual Access: Upon request and as applicable by law, Progress Investigations must provide an individual with information about the existence, use and disclosure of their personal information and must provide the individual access to that information. The individual must be able to challenge the accuracy and completeness of the information and have it amended as appropriate.

Challenging Compliance: An individual can address a challenge concerning compliance or complaint regarding the above standards to our National Privacy Officers, who are accountable for our compliance with these principles. Our Privacy Officers, Brian Lawrence and Glenn Spillett, can be reached at: 1-877-966-0166

Office

All confidential information will remain under lock and key when not in use by a company representative and after regular office hours.

Visitors

All individuals not employees of Progress Investigations must sign in and out at the ‘Register’ located at the front desk and given a ‘Visitor Tag’. Visitors must not enter areas where confidential information (client information, individual or subject information or company information) may be viewed.

The ‘Register’ will contain the following information: Visitor Name, Company, Who is Visiting, Time In, and Time Out.

The following statement will be provided to clients and explains how we treat “personal information” that is not public. This is information – oral, electronic or written – about an identifiable individual, including (but not limited to):

  • Name, address and telephone numbers
  • Age, gender, family and marital status
  • Driving record
  • Previous insurance and claims experience
  • Employment information
  • Banking information, credit rating, payment records
  • Identification numbers
  • Assets and liabilities

Privacy Statement to Clients

Progress Investigations is committed to protecting the privacy, confidentiality, accuracy and security of the personal information it collects, uses, retains and discloses in the course of conducting business.

As part of our relationship with you and in the course of conducting business, Progress

Investigations may collect, use and disclose personal information relating to:

  • Identity
  • Understanding client needs
  • Provide you with ongoing services, establish and maintain communication, and to respond to your questions
  • Offer and provide complementary products and services that meet your needs
  • Ongoing investigations
  • Detect and prevent fraud
  • Meet regulatory requirements
  • Share as reasonably required for the above–stated purposes with any other person, corporation, firm or enterprise, which is required to comply with privacy laws like those that apply to our company.

When possible, we will obtain your consent and explain the purposes for the collection, use or disclosure of personal information:

  • At the time that the information is collected
  • When a new use is identified

As specified by Regulation, under section 7, Bill C-6, Personal Information Protection and Electronic Documents Act, Investigative Body Status allows the collection, use and disclosure of information obtained without consent. Progress Investigations as a Licensed Private Investigation firm is governed by that Regulation.

Progress Investigations does not sell client lists, nor do we collect, use, or disclose your personal information without your consent, except where authorized by law.

It is a legal right to withhold and/or withdraw consent from Progress Investigations for the collection, use, or disclosure of personal information for certain purposes. Should this right be exercised, Progress Investigations will not unreasonably withhold requested services however, certain information must be provided in order for Progress Investigations to supply those services.

At Progress Investigations, maintaining the security of personal information is a top priority. Only authorized personnel have access to information. Our procedures and practices are designed to ensure that reasonable security measures are followed to protect against unauthorized access, use, alteration, destruction, or disclosure of personal information. Our commitment to the protection of personal information is emphasized in our Privacy Code.

We retain personal information for as long as necessary for the purpose for which it was collected in order to meet obligations we have under the law and with our clients.

At Progress Investigations, the accuracy of your personal information is important. We welcome any questions, comments, or requests you might have about privacy, and, particularly, those about your personal information.