An Act to support and promote electronic commerce by protecting personal information that is collected, used or disclosed in certain circumstances, by providing for the use of electronic means to communicate or record information or transactions and by amending the Canada Evidence Act, the Statutory Instruments Act and the Statute Revision Act.

The term record includes any correspondence, memorandum, book, plan, map, drawing, diagram, pictorial or graphic work, photograph, film, microform, sound recording, videotape, machine readable record, and any other documentary material, regardless of physical form or characteristics, and any copy thereof.

The term personal information is defined as information about an identifiable individual but does not include the name, title or business address or telephone number of an employee of an organization. This includes, for example, an individual's race, ethnic origin, color, age, marital status, religion, education, medical information, criminal record, employment history, financial records, address, telephone records, e-mail address, Social Insurance Number (SIN), fingerprints, blood type, and tissue or biological sample.

PURPOSE: The purpose of PIPEDA is to establish, in an era in which technology increasingly facilitates the circulation and exchange of information, rules to govern the collection, use and disclosure of personal information in a manner that recognizes the right of privacy of individuals with respect to their personal information and the need of organizations to collect, use or disclose personal information for purposes that a reasonable person would consider appropriate in the circumstances.

For more information regarding this legislation, please visit the official Web site of the Privacy Commissioner of Canada or the Electronic Commerce branch of Industry Canada.

STATEMENT OF POLICY

It is the policy of Telematics-Online to control the collection, use, and disclosure of personal information in accordance with all requirements set out in the Personal Information Protection and Electronic Documents Act. In certain circumstances personal information may be collected, used, or disclosed without the knowledge and consent of the individual. Exemptions include, but are not limited to personal information gathered for:

• Legal, medical, or security reasons.
• Detection and prevention of fraud or for law enforcement.

REQUIREMENTS

The following requirements shall be met by Telematics-Online through the following 10 Principles unless exempted by the Personal Information Protection and Electronic Documents Act:

Telematics-Online Research and Investigation Inc. accepts responsibility for personal information under its control and has designated a Privacy Coordinator, to be accountable for Telematics-Online Research and Investigation Inc. compliance with the following principles. 

Each Telematics-Online Research and Investigation Inc. employee is responsible for all personal information in their control. Telematics-Online Research and Investigation Inc. will assist all employees to ensure full compliance with the company's Privacy Policy.

2.   IDENTIFYING PURPOSE

The purposes for which Telematics-Online Research and Investigation Inc. will collect personal information are:

• To facilitate the investigation of contraventions or suspected contraventions of the law;


• To facilitate the investigation of breaches or suspected breaches of agreements;


• For the purposes of establishing, managing or terminating an employment relationship between Telematics-Online Research and Investigation Inc. and individual employees.

Personal information collected to facilitate Identifying Purposes 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 in, or suspected of criminal activity;


• Information pertaining 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 an agreement.

3.   CONSENT

Telematics-Online Research and Investigation Inc. acknowledges that knowledge and consent of the individual are required for the collection, use, or disclosure of personal information, except where inappropriate.

Telematics-Online Research and Investigation Inc. recognize that it is reasonable to expect that obtaining the knowledge and the consent of individuals would, in most instances, compromise an investigation or proceeding. In such circumstances personal information will only be collected, used and disclosed by Telematics-Online Research and Investigation Inc. in accordance with section 7 of the Personal Information Protection and Electronic Documents Act, S.C. 2000, c.5 (PIPEDA).

4.   LIMITING COLLECTION

The collection of personal information will be limited to that which is necessary for the purpose identified by Telematics-Online Research and Investigation Inc. All personal information will be collected by fair and lawful means.

Telematics-Online Research and Investigation Inc. will collect information about individuals only if there are reasonable grounds to believe that the information relates to unlawful and or dishonest conduct, breaches of agreements or contraventions of the laws of Canada, a province, or a foreign jurisdiction. Telematics-Online Research and Investigation Inc. will only collect the personal information required for the purpose set out above.

5.   LIMITING USE, DISCLOSURE AND RENTENTION

Personal information collected by Telematics-Online Research and Investigation Inc. will not be used or disclosed for purposes other than those for which it was collected, except with the consent of the individual or as required by law. Personal information shall be retained only as long as necessary for the fulfillment of those purposes.

Telematics-Online Research and Investigation Inc. may only use or disclose personal information for the purposes for which it was collected. Telematics-Online Research and Investigation Inc. may only keep personal information for as long necessary to satisfy such purposes. Telematics-Online Research and Investigation Inc. may disclose personal information only to other investigative bodies or their clients for the purpose for which the personal information was collected.

Telematics-Online Research and Investigation Inc. will destroy personal information in its possession once it is no longer required for the purpose for which it was collected.

6.   ACCURACY

Personal information collected by Telematics-Online Research and Investigation Inc. shall be as accurate, complete, and up-to-date as is necessary for the purposes for which it is to be used.

Telematics-Online Research and Investigation Inc. will ensure to the best of their ability that the personal information they collect, use, and disclose is accurate, complete, current, and relevant to the purposes for which it is to be used.

7.   SAFEGUARDS

Telematics-Online Research and Investigation Inc. shall maintain safeguards to protect personal information appropriate to the sensitivity of the information collected.

Telematics-Online Research and Investigation Inc. will ensure that personal information files, both hard copy and electronic, are stored in a secure manner. All paper files (hard copy) will be stored in locked file cabinets with restricted access. All electronic files kept on computer hard drives or removable disks, will be stored securely behind passwords and a secure firewall. Electronic files will be encrypted with an industry standard encryption program before being transferred electronically. Personal information will be accessible on a need-to-know basis only.

8.   OPENNESS

Telematics-Online Research and Investigation Inc. will make specific information about its policies and practices relating to the management of personal information readily available to individuals.

Telematics-Online Research and Investigation Inc. will make available upon request from the public, information about the company and its privacy policy. This information will also be available on the company's web site http://www.telematics-online.com.

9.   INDIVIDUAL ACCESS

Telematics-Online Research and Investigation Inc. will upon written request, inform an individual; of the existence, use, and disclosure of his or her personal information and will give the individual access to that information. An individual will be able to challenge the accuracy and completeness of the information and have it amended as appropriate.

In accordance with Section 9(3) of PIPEDA and Section 23(1) of PIPA, if such disclosure does not defeat the purposes for which the information was collected, Telematics-Online Research and Investigation Inc. will, upon request by an individual, advise the individual whether Telematics-Online Research and Investigation Inc. has personal information concerning the individual, what that information is, what it is being used for and to whom the information has been disclosed.

If the individual can provide proof of an error in the personal information held by Telematics-Online Research and Investigation Inc., the company 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, Telematics-Online Research and Investigation Inc. will note the challenge so that those using the information will be aware of the unresolved challenge.

If Telematics-Online Research and Investigation Inc. denies an individual's request for access, it will state the reasons for the denial and advise the individual of his/her right to appeal to the Office of the Privacy Commissioner of Canada or Saskatchewan as the case may be.

10.   CHALLENGING COMPLIANCE

An individual may address a challenge concerning compliance with the above principles to the Privacy Officer at Telematics-Online Research and Investigation Inc. 

Telematics-Online Research and Investigation Inc. Privacy Officer can be contacted at:

Telematics-Online Research and Investigation Inc.
4246 Albert Street, Suite #427
Regina, Saskatchewan
S4S 3R9