The KeyNorth Professional Services Group Inc. (“the KeyNorth Group”) is an Ontario, Canada based investigations, training and consulting firm.
According to the Personal Information Protection and Electronic Documents Act, personal information means information about an identifiable individual, but it does not refer to the name, title, or business address or telephone number of an employee of an organization. Other exemptions may apply, and we recommend you consult the Personal Information Protection and Electronic Documents Act or the Office of the Privacy Commissioner of Canada for further information.
Accountability and Contact Information
The contact for privacy related matters at the KeyNorth Group is:
We collect and use personal information for four main purposes:
- To facilitate the investigation of matters we are retained to investigate. These may include, but not be limited to matters related to litigation support, alleged breaches of agreements, alleged contraventions of laws or regulations within Canada or of other jurisdictions as applicable.
- For the purposes of providing training services.
- For the purposes of our providing risk management and consulting services.
- Administrative matters such as marketing our services, hiring employees, consultants and contractors; client acceptance, collecting payment, and working with suppliers and service providers.
Collection of Information
We collect personal information about individuals directly from individuals themselves by express or implied consent; from clients who engage us where we believe they have obtained the information through express or implied consent; or without the consent of the individuals in so far as the information is collected in accordance with Section 7 of the Personal Information Protection and Electronic Documents Act, S.C. 2000, c.5 (PIPEDA).
Information we collect include may include:
- Your name, position, role, company or organization, telephone, email and postal address that you supply us.
- Information about you from public sources such as public areas of social media platforms, online directories, the Internet, news media and government records that are publicly available which we obtain through our investigations.
- Information we obtain through a lawful investigation process including but not limited to surveillance, interviews, examination for discovery, by court order, by voluntary provision of the information or by other lawful means.
- Attendance information such as your image; and your name and signature when you attend our offices.
- Information provided by our clients so that we may conduct risk management or consulting engagements.
- Interactions you have with our website such as your username and password for protected areas of our website, any information you upload to our website, completing forms, and registration information when you sign up for an event or a training program.
If you leave a comment on our site you may opt-in to saving your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year.
If you have an account and you log in to this site, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.
When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year. If you select “Remember Me”, your login will persist for two weeks. If you log out of your account, the login cookies will be removed.
If you edit or publish an article, an additional cookie will be saved in your browser. This cookie includes no personal data and simply indicates the post ID of the article you just edited. It expires after 1 day.
We also perform analytics of website visitors through Google Analytics and the analytics services provided by Sumo, a web marketing company.
When you access this website information about your visit including the pages you visit, your network and IP address, and device information (including browser, telephone and computer information), how long you visited and other information about your visit is tracked.
For more information on what Google Analytics collects please visit: https://support.google.com/analytics/answer/6004245?hl=en
For more information on Sumo Cookies, visit: https://help.sumo.com/hc/en-us/articles/115004671147-How-Sumo-Cookies-Work
- Social media interactions that you have with the social media services we operate.
- Information collected through or our e-newsletters such as your name, email address, click rates, and the network from which you joined.
Analytics are performed on our e-newsletter readership by MailChimp, our e-newsletter provider. For more information visit: https://mailchimp.com/legal/privacy/
We comply with the Canadian Anti-Spam Legislation. All e-newsletter subscribers do so by opt-in consent and may opt-out at any time. If you do not know how to opt-out of our e-newsletters and wish to do so, please contact us and we will remove you from our list.
- Information you supply through answering our surveys. When you complete a survey we collect anonymized information about you and your responses. We use SurveyMonkey to conduct surveys; and to collect and analyze responses. For more information on how SurveyMonkey processes information visit: https://www.surveymonkey.com/mp/legal/privacy-policy/
- Supplier data including contact details, payment information and other information about you or your company or organisation where you provide services to the KeyNorth Group.
- Payment information such as your bank account, email money transfer information, credit card or other information which we collect while processing your payments.
Limiting Disclosure and Retention
We will not disclose or retain your personal information that we collect for any purpose other than those purposes for which it was collected, except with the consent of the individual or as required by law.
Examples of where we may disclose information to third parties include:
- Government agencies, regulatory bodies or other persons having the lawful authority to require us to provide it.
- Companies that are affiliated with us.
- Clients who have provided information about you; or on whose behalf we have been retained to conduct an investigation, risk management engagement, consulting engagement or training engagement;
- Third parties that provide products or services to us including, without limitation, consultants, suppliers and Internet service providers, but only to the extent necessary to allow them to provide services to us;
- When it is necessary to collect payment;
- By your consent;
- Where otherwise permitted by law.
We will destroy personal information in its possession once it is no longer required for the purpose for which it was collected. Note that information retention regulations of the Private Security and Investigative Services Act of Ontario apply.
We shall ensure that all personal information that we collect; used and disclosed shall also be as current, complete and accurate to the best of our abilities. If you have changed your personal information, please advise us so that we may make the appropriate changes by contacting us.
We will ensure that personal information is stored and transferred securely whether in electronic or hardcopy format. Distribution of personal information will be on a need-to-know basis.
In accordance with paragraph 9(3)(a)(c.1)(d) of PIPEDA, if such disclosure does not defeat the purposes for which the information was collected, the information is subject to legal privilege, or the information was generated in the course of a formal dispute resolution process, we will disclose to you what personal information we hold about you, what it is being used for and to whom your information has been disclosed.
If we deny your request for access to information, we will provide you with a written explanation why the information request was denied. If you are unsatisfied with our decision to refuse disclosure you may to appeal to the Office of the Privacy Commissioner of Canada, the Ministry of Community Safety and Correctional Services of Ontario or other regulatory bodies.