CODE OF ETHICS

Prime Investigations Ltd. subscribes to the following Code of Ethics which has been established by the Alberta Association of Private Investigators to promote and inspire confidence in our profession.

All work will be performed with due diligence in a responsible and professional manner.

RIGHT OF FIRST CONTACT

When a client requests Prime Investigations Ltd. to locate an individual for personal reasons, we are bound by our company policy to ensure that the right to Personal Privacy is upheld. For non-litigation locates, Prime Investigations Ltd will make the first contact with the individual being located and request their authorization for the release of their personal information to the client.  The person being located will always have the right of keeping their information private and as such, Prime Investiagtions Ltd will honor that right and not release that information to the client. This policy ensures the safety and privacy of all parties.

CODE OF PRIVACY

The Code of Privacy for Prime Investigations Ltd. follows and complies with the CSA Model Code for the Protection of Personal Information and is as follows:

Accountability

Prime Investigations Ltd. will be responsible for all personal information under our control. We have designated a Chief Privacy Officer, whose responsibility it is to ensure our organization remains privacy compliant.

The Chief Privacy Officer for Prime Investigations Ltd. is Patrick Lam. 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. Patrick Lam can be contacted at:

204, 1440 - 52 Street NE
Calgary, Alberta T2A 4T8
Telephone: (403) 217-2137
Facsimile: (866) 696-9522
Email: primeinfo@telus.net

Identify Purposes

Prime Investigations Ltd. will identify the purpose for which we collect personal information on affected individuals at or before the time of collection. All assignments received form our clients will be vetted to ensure their requests for information is compliant with PIPEDA.

Subsequent to the collection of personal information, Prime Investigations Ltd. 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.

Consent

Prime Investigations Ltd. 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 Prime Investigations Ltd. 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.

Limiting Collection

Prime Investigations Ltd. will limit its collection of personal information to that which is necessary for purposes we have identified. We will only collect personal information for specific, legitimate purposes and will not collect personal information indiscremently.

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.

Limiting Use, Disclosure, and Retention

Prime Investigations Ltd. will limit the use, disclosure of personal information to those purposes for which it is initially collected, except with the consent of the individual or as otherwise permitted by law.
Information will only be retained for as long as necessary to fulfill those purposes. Personal information that is no longer required to fulfill identified purposes will be destroyed, erased, or made anonymous.

Accuracy

Prime Investigations Ltd. will make every effort to ensure that the personal information collected for an intended purpose is accurate, complete and up-to-date.

If a significant error or omission is identified, we will correct or amend the information as appropriate. Where necessary, we will send such corrected or amended information to third parties who have had access to the information in question.

Safeguards

Prime Investigations Ltd. will safeguard all personal information under our control in a manner that is appropriate to the sensitivity of the information. To this end we will take all the physical security measures necessary.

Personal information under the control of Prime Investigations Ltd. may be electronically stored. We will ensure that such records are protected through the application of the latest technical measures as well as physical access restriction.

Openness

Prime Investigations Ltd. will make available to the public information about our company, our privacy policies, and our Code of Privacy upon request. This information is available by requesting a hard copy by contacting Prime Investigations Ltd. at (403) 217-2137.

Individual Access

Upon request, an individual will be informed of the existence, use and disclosure of his / her personal information that is under our control. They 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 such access, which may be communicated to the individual as appropriate where access to the information is denied.

Challenging Compliance

An individual may address a challenge concerning compliance with the aforementioned policies and procedures to our Chief Privacy Officer whose details are listed within this correspondence.