Code of Ethics and Privacy

The Code of Privacy for Sterling Corporate Security and Information Integrity follows and complies with the CSA Model Code of Personal Information Privacy and is as follows:

1. ACCOUNTABILITY

Sterling Corporate Security and Information Integrity will be responsible for all personal information under our control. We have designated a Chief Privacy Officer, whose responsibility is to ensure our organization remains privacy compliant.

The Chief Privacy Officer for Sterling Corporate Security and Information Integrity is Robert Michael Reynolds. Any privacy compliance or information management questions should be directed to him. Upon receiving an enquiry, the Chief Privacy Officer will respond within 30 days. Robert Michael Reynolds can be contacted at mike@sterlingsecurity.ca.

2. IDENTIFY PURPOSES

Sterling Corporate Security and Information Integrity will identify the purpose for which we collect personal information on affected individuals at or before the time of collection. All assignments received from our clients will be vetted to ensure their requests for information are compliant with PIPEDA.

Subsequent to the collection of personal information, Sterling Corporate Security and Information Integrity may identify a new purpose or use for the information. In such an instance, we will seek to obtain prior consent for this new use, even if we have already identified certain initial purposes.

3. CONSENT

Sterling Corporate Security and Information Integrity will obtain the appropriate consent from individuals regarding the collection, use or disclosure of personal information, except where the law provides an exception.

In most incidences, obtaining the knowledge and consent of individuals would defeat the purpose of an investigation, particularly with respect to a contravention of a law or breach of an agreement. Personal information will only be collected, used and disclosed by Sterling Corporate Security and Information Integrity employees without consent in accordance with Section 7 of the Personal Information Protection and Electronic Documents Act, S.C. 2000, c.5 (PIPEDA) or under other lawful means.