Code of Privacy

 

January 2019

PANTHER ASSOCIATED CONSULTANTS INC.

(Hereinafter referred to as PANTHER)

Purpose of this Code of Privacy

The purpose of this Code of Privacy is to outline how PANTHER collects, uses, retains, safeguards, discloses and disposes of the personal information of its customers, employees, investigative subjects and third-party collateral subjects.

This Code of Privacy describes the way that PANTHER will, subject to applicable legal requirements, adhere to all relevant federal and, where applicable, provincial legislative privacy requirements. The Code of Privacy follows the Canadian Standards Association (CSA) principles identified in the federal Personal Information Protection and Electronic Documents Act (PIPEDA). This Code of Privacy describes each principle and the method of implementation. PANTHER will strive to meet or exceed federal and provincial legislative requirements and will ensure that it remains current with changing technologies and laws.

Introduction

Protecting the privacy and the confidentiality of personal information—over the Internet, on the telephone, or through our offices—has always been fundamental to the way PANTHER conducts its affairs. PANTHER operates based on a Privacy Policy and related procedures that guide the handling of the personal information collected. This privacy statement has been created to demonstrate PANTHER’s firm commitment to protecting the privacy of its clients, employees, partners and potential Website visitors. This policy and related procedures are consistent with the Canadian Standards Association Model Code for the Protection of Personal Information (herein “CSA Model Code) and applicable privacy legislation.

Privacy Statement

This policy deals only with personal information handled by PANTHER. Personal information is information about an identifiable individual, excluding business contact information. The following explains how PANTHER handles personal information. PANTHER reserves the right to change this policy and it may be updated periodically. These changes may affect the use of personal information. Accordingly, please check for changes regularly.

Accountability

PANTHER is accountable for all personal information under its control. PANTHER Privacy Officer is Senior Director – Investigations; Panther Investigations and Security Ltd., as well as the President and CEO of Panther Associated Consultants Inc.; both of whom are designated as responsible for PANTHER privacy policy. The Privacy Officer can be reached by:

    • Email: info@pantherconsultants.com
    • Telephone: 902-482-2671
    • Fax: 902-453-2907or
    • Mail: PANTHER Privacy Officer, 1959 Upper Water Street, Suite 1301, Halifax NS B3J 3N2

Any questions about the PANTHER handling of personal or private corporate information should be directed to the Privacy Officer. In cases where the question concerns an access request, individuals must follow the request process described under Accuracy of and Access to Personal Information Collected.

Purposes for Collection, Use and Disclosure of Personal Information

The purpose for which PANTHER collects personal information will be identified at or before the time the information is collected. Personal information may be collected for such purposes as:

    • In the commission of performing and/or administering PANTHER services;
    • Registering for PANTHER events, for example Corporate Human Resources Projects, Security Programs;
    • Processing and administering the above or other purposes as necessary.

PANTHER will not use personal information for any other purpose than identified at or before the time of collection.

Client Services

PANTHER may report on; and/or collect client information (including but not limited to contact Information) as well as proprietary business information from its clients in order to:

    • Perform, develop and implement contracted services
    • Send out invoices and otherwise administer PANTHER business

This contact information is voluntarily provided by PANTHER clients. Clients may, at any time, be taken off PANTHER mailing lists at their request.

Consent

PANTHER seeks consent for all personal information it collects, uses and discloses through information provided to individuals prior to collection, or at the time of collection. For information, which is more sensitive, PANTHER will ask for a signature as a sign of consent.

If information is voluntarily provided, this is interpreted as consent to the collection, use and disclosure of personally identifiable information as described in this Privacy Policy. As required by the CSA Model Code, PANTHER will not use personal information for any purpose other than that for which consent has been provided. Should PANTHER require use of personal information for a new purpose, consent will be sought for that new use.

Limits for Collecting, Using, Disclosing and Keeping Personal Information

PANTHER does not collect, use or disclose personal information of individuals except when individuals give consent and provide the information on a voluntary basis. There may be occasions where more specific personal information is necessary for PANTHER to proceed with a request for information or provide a product or service. In such cases, PANTHER will describe the information required. In all such cases, PANTHER limits the amount and type of information collected to only the personal information that is required to provide the client with the requested information, product, or service. PANTHER collects only information that is voluntarily provided by the individual and undertakes that such information will be kept strictly confidential.

PANTHER may disclose personal information collected by it without the knowledge or consent of the individual, for example to its lawyers or principle clients; for purposes relating to an investigation under, the enforcement of or the administration of a law or where required by law to disclose the information. PANTHER will not use or disclose personal information without the knowledge or consent of the individual except as authorized by applicable law.

PANTHER retains personal information only if is necessary to provide the individual with the requested product, service or information. For example, if personal information is given to register for an event, the personal information will only be used for this event and will then be deleted or destroyed. In some cases, however, legal reporting or retention requirements necessitate that PANTHER retains information for a specific amount of time. In general, PANTHER retains personal information for a period not longer than seven years, in secure storage.

PANTHER does not sell or trade any personal information with third parties. Information may be transferred to third parties where information processing is outsourced by PANTHER in the course of its activities or administrative procedures in specific cases. Some personal information collected by PANTHER is transferred to our service providers for processing and storage. Some of our service providers are located outside of Canada and accordingly your data may be processed and stored outside of Canada and may be subject to the laws of the jurisdiction in which it is processed or stored. PANTHER requires service providers to respect this Privacy Policy. Service providers are restricted from using or disclosing personal information transferred to them for any purpose other than the provision of services to PANTHER.

Any personal information that PANTHER retains is always kept in such a manner as to ensure its security and confidentiality.

Safeguarding Personal and Client Proprietary Information

PANTHER respects the privacy of its clients, partners, potential website visitors and internet users and will protect that privacy as vigorously as possible. Personal information is stored in electronic and physical files that are secure. Security measures include secure locks on filing cabinets, and using industry standard techniques such as firewalls, encryption, intrusion detection and restricted access to computers. Unfortunately, no data transmission over the Internet can be guaranteed to be 100% secure. As a result, while PANTHER strives to protect personal information, it cannot ensure or warrant the security of any information transmitted to it or received from it electronically. This is especially true for information transmitted via e-mail. PANTHER has no way of protecting that information until it reaches it. Once a transmission is received, PANTHER makes its best efforts to ensure its security on its servers. Internally, access to personal information is restricted to employees who need access to the information in order to do their jobs. These employees are limited in number and are knowledgeable about and committed to our privacy policies.

Accuracy of and Access to Personal Information Collected

PANTHER makes every effort to keep personal information as accurate, complete, current and relevant as necessary for the identified purposes. PANTHER does not routinely update personal information.

PANTHER makes readily available to individuals its Privacy Policy and related procedures for managing personal information. Customer access to the Privacy Policy and related procedures is provided on PANTHER ’s website and in written form. Any questions about the handling of personal information by PANTHER can be raised with the Privacy Officer.

At the written request of an individual, he or she may view or edit their personal information as collected by PANTHER. PANTHER will inform them of what personal information it has about the individual, what it is being used for and, in cases where it has been disclosed, to whom it has been disclosed. There may be exceptional circumstances as provided by the CSA Model Code under which PANTHER may not be able to give an individual access to personal information held about them by PANTHER. In this case PANTHER will explain the reason for this lack of access, as provided by the CSA Model Code.

To make a request, please send a letter, email or fax addressed to our Privacy Officer at the address indicated above. In any written request, please include the following information:

    • Name
    • Contact details
    • Nature of the request, for example:
    • View and/or edit information
    • Inquire regarding use and/or disclosure

If an inquiry concerns a specific transaction, please indicate the date of the transaction, and provide a receipt number if applicable.

PANTHER will reply to requests in no later than thirty days after receipt of the request, or if it is not able to respond within this time period, a notice of extension will be sent.

Questions

Any questions or comments about PANTHER ’s handling of personal information should be directed to the Privacy Officer.

Use of PANTHER Website

PANTHER believes online privacy is important to the success of the Internet and electronic commerce in general and is strongly committed to each visitor’s right to privacy. This statement sets forth PANTHER’s Privacy Policy for its website located at pantherconsultants.com and describes the practices that PANTHER follows in respect to the privacy of the users of this site. By accessing and using materials from this Website or sending or posting materials to it, you (the “user”) agrees to the terms of this privacy commitment and to our practices to collect, use or disclose personal information.

This Privacy Statement may be updated periodically to reflect enhancements to PANTHER Website that may affect the use of personal information. Accordingly, please check back periodically.

Information on This Website

Information which includes all facts, data and other information, collectively the “Information” in the pages of this website is of a general nature, is intended only for informational purposes, is subject to change without notice, and is not intended to be relied on by visitors as binding legal advice on any particular matter.

Individual information provided to PANTHER to gain access to any feature of this website will not be sold or made available to any third party, except where information processing is outsourced by PANTHER in the course of its regular administrative procedures.

PANTHER reserves the right to perform statistical analyses of aggregated user behavior and characteristics, in order to measure interest in and use of the various sections of its site to improve design and navigation and to gather information for marketing purposes. Only aggregated data from these analyses, not individual data, will be used for this purpose.

“Cookies” are not attached to PANTHER website. A “cookie” is a piece of data that is stored on the hard drive of a computer that contains information about use of the website. Other Websites may contain “cookies” that accumulate information about website use, for example a record of the websites that an individual has visited.

Accuracy of the Information on This Website

The information is believed to be accurate, complete and current when posted, but PANTHER cannot guarantee that it will remain accurate or complete or that it will always be current.

PANTHER is not responsible for direct, indirect, special or consequential damages, regardless of the cause, arising out the use of this website.

Accuracy of Information on Linked Websites

Through the links to other sites found periodically on the PANTHER website, the user may enter domains that are beyond the boundaries of PANTHER and, once there, PANTHER is not responsible for the privacy practices or the content of these websites. PANTHER has no control over the accuracy, completeness or relevance of the information on these sites and provides links to these sites solely for the information and convenience of visitors to our website.

Copying Information from This Website

The information on PANTHER website may be used or copied if it is used or copied accurately or is used in its entirety and/or that the source of the information is clearly identified. Only a member of PANTHER may use the information for commercial purposes. PANTHER is not responsible for the way in which the information may be used or copied. PANTHER reserves the right to change, delete or add information at any time.

Arguing that you don’t care about the right to privacy because you have nothing to hide, is no different than saying you don’t care about free speech because you have nothing to say.