PRIVACY POLICY

Sprague Investigation Inc. recognizes the importance of privacy and the sensitivity of personal information. As a Private Investigation Agency licenced in the Province of Ontario we have a professional obligation to keep confidential all information we receive, on behalf of our principles, which are limited to the Law Firms we act for. Generally the scope of the information we receive from our principles and obtain on their behalf is subject to a claim of legal professional privilege. Sprague Investigation Inc. is committed to protecting any information we hold.

Your privacy rights From January 1, 2004, all businesses must comply with the Personal Information Protection and Electronics Documents Act. These obligations extend to Private Investigation Agencies including Sprague Investigation Inc. The Act gives individuals rights concerning the privacy of their personal information.

Why does Sprague Investigation Inc. need personal information?

Sprague Investigation Inc. provides investigation services solely to the legal community. In so doing, we need to collect personal information to satisfy the needs of our principle law firms.

What personal information do we collect?

Personal information is any information about an individual. This could include information such as age, identification numbers, income, ethnic origin, credit and banking information, employee records, medical records and any information relevant to the issue for which we have been retained.

We must collect and use such personal information to provide investigation services to our principles.

This information may be about our principles clients, or may be about individuals who are not clients, but are involved in transactions, matters and disputes with our principles clients.

How do we collect personal information?

We collect personal information in the normal course of representing our principles clients and only by lawful and reasonable means. We collect information directly from our principles, their clients and also from sources other than the individual and other parties to a transaction, matter or dispute.

Consent

In most cases we ask individuals to specifically consent, if we collect, use or disclose their personal information, where such collection, use and disclosure is such that would not be considered normal for an investigation agencies representation of a principle law firm's client. Permission may be expressed in writing or be implied and may be given to us verbally, electronically, or through an authorized representative. Individuals may withdraw permission to collect, use and disclose their personal information at any time.

Use of personal information

We use personal information to provide privileged investigation reports and services to our principles. Due to the nature of our relationship with our principles, Sprague Investigation Inc. does not provide any personal information to third parties.

Updating personal information

It is important the information be accurate and up to date. If during the course of the retainer, if any personal information changes, the individual should inform us so we can make any necessary changes.

Information Security

Sprague Investigation Inc. takes all reasonable precautions to ensure personal information is kept safe from loss, unauthorized access, modification or disclosure. Among the steps taken to protect personal information are: premises security; restricted file access; technological safeguards like security software and fire walls; and internal password and security policies.

Access to personal Information

Individuals may ask for access to personal information we hold about them. Due to the privileged nature of our retainer by our principles, access to the information is not absolute. In most cases the investigations we undertake on behalf of our principles are subject to a claim of legal professional privilege, or is allowed under relevant privacy legislation. Information which relates to existing or anticipated legal proceedings against the individual would have an unreasonable impact on others peoples privacy; to do so would prejudice negotiations; to protect the rights and property of Sprague Investigation Inc.; or the request is frivolous or vexatious. If an individual is represented by a lawyer for a dispute or transaction we are not able to discuss privacy or any other matters directly with that person. In these circumstances, the individuals counsel must contact us. If we deny a request for access to, or refuse a request to correct information, we shall explain why.

Communicating with Sprague Investigation Inc.

Some view internet e-mail as less confidential than more traditional forms of communication. If a principle law firm or client does not wish us to use internet e-mail, please advise us in writing.

Changes to this policy

Sprague Investigation Inc. regularly reviews all of it's policies and procedures. We may change our Privacy Policy from time to time.

Request for access

If you have any privacy questions, or wish to access your personal information, please write to our privacy officer:

Paul D. Sprague, President
Unit 4 – 11 Baseline Road E.
P.O. Box 43031
London ON N6C 5Z0
or e-mail paul@spragueinvestigation.com