CODE OF PRIVACY OF WORLD INVESTIGATION INC.

Effective January 1, 2004

World Investigation Inc. is in the business of conducting Investigations, gathering information and Legal Process Serving. We handle enquiries locally, nationally and internationally. Although we collect personal information on individuals, we understand the need to protect personal information and ensure its safekeeping. We at World Investigation have adopted the new federal Personal Information Protection and Electronics Documents Act (PIPEDA) and acknowledge the importance of national standards to protect the personal information that we collect. World Investigation Inc. is properly licensed and regulated by the Province of Manitoba, Manitoba Justice. We will only collect personal information on individuals where there is a potential contravention of the law or breaches of agreements or other circumstances that permit us to legally collect this information under the laws of Canada.

1. ACCOUNTABILITY

World Investigation Inc. will be responsible for personal information under our control. We have designated three individuals, headed up by our Chief Privacy Officer, to ensure our organization’s compliance with the policies and procedures indicated in our Code of Conduct.

The Chief Privacy Officer of World Investigation Inc. is Cordell Smith, Secretary. Mr. Smith can be reached at:

World Investigation Inc.
202 – 170 Marion Street
Winnipeg, Manitoba R2H 0T4
Telephone: (204) 233-7708
Facsimile: (204) 237-5864
E-mail: worldinv@mts.net

Upon receiving an enquiry, Mr. Smith will respond to you within 30 days.

It is World Investigation Inc.’s commitment to protect personal information.

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 World Investigation Inc. maintains.

2. IDENTIFY PURPOSES

World Investigation Inc. will identify the purpose for which we collect personal information on affected individuals at or before the time of collection. This will allow us to determine the information we need to collect to fulfill these purposes. We will only collect the information for the purposes that have been identified.
World Investigation Inc. may identify any new purposes that arise during the course of dealings with personal information and obtain prior consent required for this new use, even if we have already identified certain initial purposes. However, we will only do this when the intended new use purpose truly constitutes a “new” use, i.e., when the new purpose being proposed is sufficiently different from the purpose initially identified.

3. CONSENT

We will obtain the appropriate consent from individuals for collection, use or disclosure of personal information, except where the law provides an exception. We may obtain express consent for the collection, user disclosure of personal information, or when we determine that consent has been applied by the circumstances.

Express consent is specific authorization given by the individual to World Investigation Inc., either orally or in writing. Implied consent is when World Investigation Inc. 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, in particular with respect to a breach of an agreement or contravention of a law. Personal information will only be collected, used and disclosed by World Investigation Inc. employees without consent in accordance with Section 7 of the Personal Information Protection and Electronics Documents Act, S.C. 2000, c.5 (PIPEDA) or under other lawful means.

4. LIMITING COLLECTION

The personal information that we collect will be limited to that which is necessary for purposes we have identified. We will only collect personal information for specific, legitimate purposes. We will not collect personal information indiscriminately. We will only collect information by fair and lawful means. 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

Personal information will not be used or disclosed for purposes other than those for which it is collected, except with the consent of the individual or as permitted by law. We will only retain personal information as long as necessary for the fulfillment of 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 World Investigation Inc. 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.

6. ACCURACY

The personal information we collect will be accurate, complete and up-to-date as necessary for the intended purposes for which it was used.

7. SAFEGUARDS

World Investigation Inc. 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. All World Investigation Inc. staff, including investigators and administration staff have been properly trained in the policies of that pertain to these safeguards. Members of the public are not allowed access to our facilities unless escorted by properly trained staff. No sensitive personal information, pertaining to subjects of investigations will be electronically transferred to our clients unless the electronic files have been encrypted with an industry standard encryption program before being transferred. 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 information. These measures include:

• ensuring that no one may retrieve personal information after disposal
• Shredding documents before recycling them
• Deleting electronically stored information and ensuring all computers have the most up to date security protections available.

8. OPENNESS

We will make readily available to individuals requesting specific information about our policies and procedures relating to the management of personal information that is under our control.
World Investigation Inc. will make available to the public easily understandable information about our company, it’s privacy policies, the Code of Privacy, both in hard copy or by requesting a copy of same by calling 204-233-7708 or by accessing our website at www.worldinvestigation.ca.

9. INDIVIDUAL ACCESS

Upon request, an individual will be informed of the existence, use and disclosure of his/her personal information which is under our control, and 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 access, which include, but are not limited to the following:

1. Personal information about another person might be revealed.
2. Commercially confidential information might be revealed.
3. Someone’s life or security might be compromised.
4. The information was collected without consent for the purposes related to an investigation of a breach or an agreement or contravention of a law or other lawful exemption.
5. The information was generated during the course of a formal dispute resolution process.
6. The information is protected by the Solicitor/Client privilege.
7. Restrictions from providing this information under the Private Investigators and Security Guard’s Act of Manitoba

Our Privacy Officer will reply with a response to the request, and with an estimation of the time and cost of the inquiry. Costs for retrieval of the information will be set at $55.00 per hour, plus any disbursements and G.S.T.

10. CHALLENGING COMPLIANCE

An individual may address a challenge concerning compliance with the aforementioned policies and procedures to our Privacy Officer whose details are listed in Section 1.