Privacy Policy: SECURaGLOBE

I. Interpretation and Definition

II. Objectives of SECURaGLOBE's Privacy Policy

SECURaGLOBE has developed this Privacy Policy for implementation January 1, 2007.

This Policy describes the manner in which SECURaGLOBE collects, uses, retains, safeguards, discloses and disposes of the personal information of its customers.

This Policy describes the way that SECURaGLOBE will, subject to applicable legal requirements, adhere to all relevant federal and provincial legislative privacy requirements.

The Policy follows the 10 Canadian Standards Association (CSA) principles identified in the federal Personal Information Protection and Electronic Documents Act (PIPEDA).

The Policy describes each principle and the method of implementing each. SECURaGLOBE will strive to meet or exceed federal and provincial legislative requirements and will ensure that it remains current with changing technologies and laws.

Any and all changes will immediately be posted to the SECURaGLOBE web site.

III. Privacy Procedures

1.1. SECURaGLOBE will appoint a staff person (the "Privacy Officer") whose responsibilities will include the implementation and monitoring of the SECURaGLOBE Privacy Policy.

1.2. The Privacy Officer will be responsible for SECURaGLOBE's compliance with privacy principles. The Privacy Officer will also be responsible for responding to access requests in accordance with this Policy.

1.3. The Privacy Officer will report to the President and the ultimate responsibility for Privacy issues will rest with the President of SECURaGLOBE.

1.4. The Privacy Officer may at his/her discretion enlist assistance from other staff members and/or volunteers within the organization. This will not in any manner mitigate his/her responsibility for Privacy issues.

1.5. The Privacy Officer's identity will be fully disclosed and be publicly accessible to SECURaGLOBE members and the public in general.

1.5.1. SECURaGLOBE's Privacy Officer is Rene Beaulieu CPP.

1.5.2. The Privacy Officer may be contacted by telephone at 519-204-7418 ext 310 or through his e-mail address at This e-mail address is being protected from spambots. You need JavaScript enabled to view it

1.6. SECURaGLOBE's Privacy Officer will ensure that SECURAGLOBE manages all personal information in its possession in accordance with this Policy including that which may be transferred to a third party. Third party organizations who handle information on behalf of SECURaGLOBE shall be contractually obligated to adhere to the standards of SECURaGLOBE.

1.7. SECURAGLOBE will implement internal policies which will facilitate adherence to this Privacy Policy including but not limited to the following:

1.7.1. Security measures at all levels designed to protect personal information in our possession;

1.7.2. Implementing procedures designed to respond to complaints and/or inquiries;

1.7.3. Staff training in all facets of information management, including awareness of SECURaGLOBE's Privacy Policy and policies and procedures developed in accordance with the Policy.

2.1. SECURaGLOBE shall only collect the information reasonably necessary to perform the investigative and security services and deliver the services as agreed with its customers.

2.2. Access to SECURaGLOBE's Privacy policies and procedures will be readily available. Similarly, the process by which challenges may be made of SECURaGLOBE's compliance and/or adherence to the legislation in question shall be readily available and transparent. To obtain further information, contact the SECURaGLOBE Privacy Officer.

2.3. SECURaGLOBE collects personal information from its customers and members of the public for the following purposes:

2.3.1. To collect, on behalf of its clients, information relating to the identity, activity and other relevant information to assist in the detection, apprehension and prosecution of offences against the laws of Canada, its provinces or other jurisdictions that can be legally obtained.

2.3.2. To collect, on behalf of its clients, information relating to the identity, activity and other relevant information to assist in civil litigation being brought against a party subject of the investigation.

2.3.3. To collect, on behalf of its customers, names, dates, addresses, times of access and times of exit of members of the public to premises for which security services are provided by SECURaGLOBE so as to provide a record of such access and egress to its customers.

2.3.4. To provide security and surveillance services for and on behalf of its customers to ensure the safety and security of the premises for which its services have been retained.

2.3.5. To collect personal information for the purposes of identifying its customers and extending credit to its customers and prospective customers and monitoring the credit of its customers in respect of providing its goods and services.

2.3.6. To identify products or services of value to current, past and prospective customers and to sell or promote such products and services of SECURaGLOBE, including direct marketing.

2.3.7. To comply with legal and regulatory requirements.

2.4. SECURaGLOBE will obtain assurances and representations that the necessary consents have been obtained from its customers before providing and/or implementing the services set forth above.

2.5. SECURaGLOBE may also compile information about an individual who accesses our web site at www.SECURAGLOBE security.com. This information may include the name, address, e-mail address, age, sex and other personal information.

2.6. SECURaGLOBE's web site may also collect other information about users such as the IP addresses, sections of the web site visited and the information downloaded. SECURaGLOBE may use this information and disclose it to service providers, for system administration purposes and to improve the web site.

3.1. SECURaGLOBE will use the personal information for the uses specified above in section 2 and in Sections 3.2 and 3.3 below.

3.2. In addition to using personal information for providing security and investigative services, SECURaGLOBE may from time to time wish to use customer names, addresses and contact information for the purposes of providing promotional opportunities, including providing the information to SECURaGLOBE's marketing and sales departments and other third parties whom SECURAGLOBE believes provide services or goods that may be of interest to our customers.

3.3. SECURaGLOBE and any such third parties may contact the individual to discuss potential promotions. SECURaGLOBE will provide an opportunity for the recipient to consent to these opportunities. Should the recipient consent than later wish to opt out of this use of information, he/she may do so by contacting SECURaGLOBE as described at Section 3.4 below.

3.4. If at any time an individual wishes to withdraw his/her consent to the use of their information for any purposes, that individual may do so by contacting the Privacy Officer for SECURaGLOBE. SECURaGLOBE will do its best to accommodate that request in a timely fashion without diminishing the services SECURaGLOBE provides. SECURaGLOBE will explain the impact such a request may have on the services provided by SECURaGLOBE.

3.5. During the course of providing investigative and security services, SECURaGLOBE may collect personal information without consent where it is reasonable to do so and where it is permitted by law.

4.1. All information shall be collected fairly and lawfully within the criteria as set forth in the PIPEDA and the SECURaGLOBE Privacy Policy.

4.2. SECURaGLOBE shall not indiscriminately collect information. The amount and type of information collected shall be limited to that which is required to fulfill our lawful purposes.

5.1. Subject to applicable legislation, SECURaGLOBE shall limit the use of personal information it collects to the purposes as disclosed in Sections 2 and 3.

5.2. SECURaGLOBE shall maintain documents for certain periods of time dependent upon necessity. More specifically:

5.2.1. SECURaGLOBE will normally maintain occurrence reports for a 7 year period after its completion;

5.3. SECURaGLOBE may, from time to time, enlist the services of third party contractors in order to provide investigative, technical and support services. Prior to enlisting the services of these firms SECURaGLOBE will contractually commit them to treat personal information consistent with the PIPEDA and the Privacy Policy of SECURaGLOBE;

5.4. SECURaGLOBE may at some point be involved in the sale, merger, transfer or reorganization of its activities. As a result, it may be necessary to disclose personal information to the third party in such a transaction. SECURaGLOBE will contractually obligate that third party to treat this information in a manner consistent with the PIPEDA and the Privacy Policy of SECURaGLOBE;

5.5. SECURaGLOBE may disclose the personal information collected to a government authority that has asserted its lawful authority to obtain the information or where the association has reasonable grounds to believe the information could be useful in the investigation of an unlawful activity, or to comply with a subpoena or warrant or an order made by the court, person, or body with jurisdiction to compel the production of the information or otherwise as permitted by applicable law;

5.6. SECURaGLOBE may, at its discretion, release personal information for the purposes of collecting debts which may be owed to SECURaGLOBE and may disclose in this regard the personal information it collects to credit reporting agencies;

5.7. Certain documents may be subject to legislated retention periods either federally or provincially and these will be respected at all times by SECURaGLOBE.

6.1. SECURaGLOBE shall strive to ensure to the extent possible that the information entrusted to it is maintained in an accurate manner. SECURaGLOBE shall try to maintain the interests of the individual and will make all reasonable efforts to ensure that decisions are not made for or about an individual based on personal information that is flawed.

7.1. Security safeguards have been implemented to ensure that the personal information collected by SECURaGLOBE is protected from theft as well as unauthorized access, disclosure, copying, use or modification thereof.

7.2. The level of safeguards employed shall be directly related to the level of sensitivity of the personal information collected. The more sensitive the information, the higher the level of security employed.

7.3. SECURaGLOBE will restrict access to information subject of PIPEDA to those with a need to know only.

7.4. Methods of protection and safeguards to be employed shall include but in no way be necessarily limited to secure vault storage, secured filing cabinets, secured offices and storage areas, as well as technological measures such as passwords and encryption.

8.1. SECURaGLOBE will, upon request and where required by law, disclose the methods by which it handles personal information.

8.2. The information available includes:

8.2.1. The name, address and phone number of the SECURaGLOBE Privacy Officer;

8.2.2. A description of the type of personal information held by SECURaGLOBE and our general uses thereof;

8.2.3. Other information as required by PIPEDA.

9.1. Subject to applicable legislation, upon request by the individual concerned, SECURaGLOBE shall disclose whether or not it actually holds personal information on an individual. SECURaGLOBE shall disclose the source of this information where it is lawfully required and provide an account of third parties to whom the information may have been disclosed.

9.2. SECURaGLOBE will confirm the identity of any person requesting disclosure of information and will determine if that person has the lawful authority to access that information, prior to disclosing that information.

9.3. Subject to applicable legislation, SECURaGLOBE shall endeavor to provide this information within 30 days of receipt of the information requested.

9.4. This information shall be provided in an understandable format, at the time the request is made.

9.5. SECURaGLOBE will take all reasonable precautions to ensure that any information collected is accurate. Any inaccurate information that is brought to the attention of SECURaGLOBE shall be corrected as quickly as possible and any pertinent third parties shall be apprised of the corrections in due course.

9.6. SECURaGLOBE will charge a nominal fee for the purpose of off-setting its expenses incurred in supplying the requested information.

10.1. SECURaGLOBE has in place procedures for the resolution of grievances in the administration of its Privacy Policy.

10.2. Upon receipt of a complaint in writing SECURaGLOBE shall make available the complaint procedures.

10.3. SECURaGLOBE shall investigate all complaints. If the complaint is deemed justified, SECURaGLOBE shall take the appropriate steps to ensure that compliance is achieved and will make changes to its policies to allow for compliance in the future.

10.4. All complaints shall be addressed in writing to:

SECURaGLOBE Solutions Inc

215 Wellington St

London, ON N6B 2L2

Attention: Privacy Officer

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