Bison
Security Group
Corporate
Code of Privacy
INTRODUCTION
Bison
Security Group, a division of BSG Corporation, is a provincially
based company with offices in Calgary, Red Deer and Lethbridge,
Alberta, Canada that handles local, national and international enquiries.
Our firm and our investigators are properly licensed and are regulated
by the Ministry of the Solicitor General of Alberta, Canada.
As
a full service security consulting and investigation firm we are
in the business of conducting investigations and gathering information.
Bison Security Group collects personal information on individuals
daily. We understand the societal value in protecting personal information
and ensuring its safekeeping.
At
Bison Security Group we embrace the new federal Personal Information
Protection and Electronic Documents Act (PIPEDA) and acknowledge
the importance of national standards that are designed to protect
the personal information that we collect. In accordance with the
Act, we collect personal information on individuals where there
is a potential contravention of the law or breach of agreement or
other circumstances that permit us to legally collect this information
under the laws of Canada.
The
Code of Privacy for Bison Security Group follows and complies with
the CSA Model Code of Personal Information Privacy and is as follows:
Bison
Security Group - Code of Privacy
1.
ACCOUNTABILITY
Bison
Security Group will be responsible for all personal information
under our control. We have designated several individuals to form
a Privacy Committee headed up by our Chief Privacy Officer, whose
responsibility it is to ensure our organization remains privacy
compliant through adherence with the policies and procedures indicated
in our Standards of Practice.
The
Chief Privacy Officer for Bison Security Group is Darryl Stark,
Operations Manager. Any enquires respecting privacy compliance or
information management should be directed to his attention. Upon
receiving an enquiry, Mr. Stark will respond within 30 days. Mr.
Stark can be contacted at:
Bison
Security Group
3402 - 8 Street SE
Calgary, Alberta
T2G 5S7
Telephone: (403) 262-4545
Facsimile: (403) 266-3827
Toll Free: 1-800-661-2245
E-mail: dstark@bsgcorp.com
Bison
Security Group has made a commitment to:
- Protect
personal information under our control,
- Allow
individuals to request information; seek amendments to their personal
information; and file complaints against Bison Security Group
with our Chief Privacy Officer,
- Provide
continuous training on information management to our staff,
- Develop
information to explain to the public and our clients, those policies
and procedures that make Bison Security Group privacy compliant.
- 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 is employed by Bison Security Group.
2.
IDENTIFY PURPOSES
Bison
Security Group will identify the purpose for which we collect personal
information on affected individuals at or before the time of collection.
All assignments received from our corporate, government, and other
clients will be vetted to ensure their requests for information
are compliant with PIPEDA. We may choose to verbally explain to
affected individuals the purposes for which personal information
is being collected and then place a notation in the applicable file
indicating that this has been done or alternatively, an application
form may be used.
Subsequent
to the collection of personal information, Bison Security Group
may identify a new purpose or use for the information. In such an
instance, we will seek to obtain prior consent for this new use,
even if we have already identified certain initial purposes. These
efforts will only be undertaken when the intended "new purpose"
or "use" is markedly different from the purpose initially
identified.
3.
CONSENT
Bison
Security Group will obtain the appropriate consent from individuals
regarding the collection, use or disclosure of personal information,
except where the law provides an exception. We may obtain express
consent for the collection, use or disclosure of personal information,
or may act accordingly when we determine that consent has been implied
by the circumstances.
Express
consent is specific authorization given by the affected individual
to Bison Security Group, either orally or in writing. Implied consent
is when Bison Security Group 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, particularly with
respect to a contravention of a law or breach of an agreement. Personal
information will only be collected, used and disclosed by Bison
Security Group employees 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
Bison
Security Group will limit its collection of personal information
to that which is necessary for purposes we have identified. We will
only collect personal information for specific, legitimate purposes
and will not collect personal information indiscremently.
Bison
Security Group will only collect information by fair and lawful
means, not by misleading or deceiving individuals about the purpose
for which the information is being collected. 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
Bison
Security Group will limit the use, disclosure of personal information
to those purposes for which it is initially collected, except with
the consent of the individual or as otherwise permitted by law.
Bison Security Group will only retain personal information for as
long as necessary to fulfill 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 Bison Security Group 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 (Consent).
6.
ACCURACY
Bison
Security Group will make every effort to ensure that the personal
information collected for an intended purposes is accurate, complete
and up-to-date. Our goal is to minimize the possibility that inappropriate
or inaccurate information may be used to make a decision about any
individual whose personal information we process.
The
process for ensuring accuracy and compliance will involve:
- Clearly
defining the client's intended purpose / use of the personal information
being requested,
- Collecting
of the initial information from client,
- Asking
the client to verify the accuracy and completeness of personal
information they provide,
- Regularly
reviewing collection procedures and sources,
- Verifying
the accuracy of information 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 appropriate.
- Where
necessary, we will send such corrected or amended information
to third parties who have had access to the information in question.
7.
SAFEGUARDS
Bison
Security Group will safeguard all personal information under our
control in a manner that is appropriate to the sensitivity of the
information. We will take all the physical security measures necessary
including alarming and properly locking our facilities and/or locking
all personal information in secure filing cabinets. All Bison Security
Group 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.
Personal
information under the control of Bison Security Group may be electronically
stored. We maintain our own servers, on-site that are protected
through the application of the latest technical measures as well
as physical access restriction.
Bison
Security Group has strict policy respecting the management and distribution
of personal information, whether by electronic means or otherwise,
and we ensure that all staff are trained in these procedures. The
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 personal information. These measures include:
- Ensuring
that no one may retrieve personal information after disposal,
- Shredding
documents before recycling the chaff,
- Deleting
electronically stored information,
- Destroying
hard drives, memory sticks, disks, etc. when they are no longer
of use and are decommissioned.
8.
OPENNESS
Bison Security Group will make information respecting our policies
and procedures which govern our information management readily available
to individuals requesting same.
Investigators
and staff of Bison Security Group will make available to the public
easily understandable information about our company, our privacy
policies, and our Code of Privacy.
This
information is available by requesting a hard copy by contacting
Bison Security Group at (403) 262-4545 or 1-800-661-2245 or can
be accessed though our website at www.bsgcorp.com .
9.
INDIVIDUAL ACCESS
Upon
request, an individual will be informed of the existence, use and
disclosure of his / her personal information that is under our control.
They may be given access to and be permitted to challenge the accuracy
and the completeness of that information.
There
are lawful exceptions that will prevent us from providing such 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,
- The
information was collected without consent for the purposes related
to an investigation of a contravention of a law or a breach of
an agreement or other lawful exemption,
- 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 other Federal
or Provincial legislation.
10. CHALLENGING COMPLIANCE
An
individual may address a challenge concerning compliance with the
aforementioned policies and procedures to our Chief Privacy Officer
whose details are listed in Section 1(Accountability).
Bison
Security Group
Website Privacy Policy
Under
No Circumstances will we collect any information about you without
your explicit consent. From time to time we may offer product trials
or downloads and may request some registration information. Such
information is held in strict confidentiality. If we do collect
any information from you, we will provide a convenient means of
modifying such information to ensure it is correct and up to date.
Bison
Security Group strictly guards against any unauthorized access or
disclosure of your information. We do not engage in the buying or
selling of your information.
Bison
Security Group uses basic website statistics to track the number
of people on our website. This information collected in no way identifies
you, your computer and is not in any way traceable back to you.
Our website statistics simply tell us the number of users who visit
our site and which pages they visited and other anonymous information
as is standard with most websites.
If
for any reason whatsoever, you do not believe that your personal
information is being managed according to the above paragraphs,
please contact the Webmaster, and we will deal with the matter promptly.
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