Kroll Consulting Canada Co.
Canada Co. (“KCC”) is committed to maintaining the privacy of personal
information collected by us in connection with our services. This Privacy
Policy covers the personal information handling practices of KCC and describes
the principles KCC follows with regard to personal information collected, used,
and disclosed in connection with our provision of our services. All KCC
Personal information that KCC handles is subject to the federal Personal
Information Protection and Electronic Documents Act (“PIPEDA”). This Policy
adopts the definition of personal information as set out in PIPEDA and is
summarized as: any information about a reasonably identifiable individual, with
the exception of business card information such as name, title, business
address, and business telephone number.
Collection of Personal Information
KCC only collects
personal information for the purposes of providing its services. KCC collects
personal information in accordance with the law. Generally, KCC collects
personal information directly from the individuals to which it relates. Such
collection may be done at the start of our relationship with a client or during
the course of our representation or retainer.
KCC may collect information about individuals from other sources including,
- a government agency or registry;
- other professionals who serve our clients;
- information contained in publicly available sources;
- other parties or witnesses in the context of investigation or litigation files; or
- other parties or participants to a commercial transaction.
Personal information is collected for the purpose of processing and
information collected via our website. KCC does not collect personal
information for the purpose of marketing to clients/customers.
Before KCC engages in collection, use and/or
disclosure of personal information, it obtains consent from the individual to
which the personal information pertains, except if the information is publicly
available, and/or as may be permitted or required by law. In some cases,
written express consent is obtained, and, in other cases, consent may be implied
or obtained orally (such as when a customer calls and asks about the status of a
In keeping with the principles set out in PIPEDA, and as a general rule for
readers of this Policy, KCC determines the level of consent (written versus
oral, and express versus implied) needed based on the sensitivity of the
personal information at issue - the more sensitive the personal information, the
more likely that the consent will be obtained on an express written basis.
Consent may, at any time, be withdrawn or varied. KCC requires that a request
for withdrawal or variation of consent be provided in writing to KCC’s Privacy
As an internationally recognized provider of specialized services, KCC works
with its related companies and uses some of the advanced information storage
measures made available though Kroll, Inc. and its affiliates and service
providers. In doing so, personal information may be transferred outside of
Canada to be processed, stored, or maintained, including in the United States.
Personal information transferred outside of Canada is subject to the laws of the
receiving jurisdiction, including laws relating to disclosure of personal
Use, Disclosure and Retention of Personal Information
KCC does not use or
disclose personal information for purposes other than those for which it was
- with the express consent of individual;
- as required by a lawful order, subpoena, warrant or other request for disclosure;
- as may be required by law;
- in order to comply with the requirements of any regulatory body that governs any of our professional practices;
- when the services we are providing requires us to give a client's personal information to third parties – in such case, his or her consent will be implied, unless he or she tells us otherwise;
- where it is necessary to collect fees or disbursements;
- to anyone we reasonably believe is an agent of a client;
- where the disclosure is to a purchaser or prospective purchaser of all or a part of Kroll’s business;
- if we engage a third party to provide administrative services to us (such as computer back-up services, data processing, archival file storage, or insurance) and the third party is bound by privacy obligations that are consistent with this Policy; or
- if we retain other professional firms on behalf of a client that require disclosure of personal information.
In addition, where KCC is acting in the capacity of an investigative body,
KCC may collect, use and disclose pesonal information when the disclosure is
reasonable for purposes related to investigating a breach of an agreement or a
contravention of the laws of Canada, a province or a foreign jurisdiction.
KCC only retains personal information for as long as reasonably necessary to
fulfil the purposes for which it was collected and to comply with its legal and
Personal information will be as accurate,
complete and up-to-date as is reasonably possible and as is necessary for the
purposes for which it is to be used. Although we acknowledge the importance of
having accurate personal information, Kroll does not vouch for, and is not
responsible for, the accuracy of personal information that may be supplied by
third party sources of information.
Pursuant to PIPEDA, and subject to certain
exceptions, individuals may seek to access their personal information that is in
the custody or control of KCC. To obtain access, an individual must submit a
written request to KCC’s Privacy Officer setting out sufficient detail to
enable, with reasonable effort, the identification of the personal information
pertaining to such written request.
Minimal fees may be imposed to process the access request. If information is
withheld, KCC will communicate its reasons for doing so.
KCC uses physical, organizational, technological
and other measures to to keep personal information secure from unauthorized
access. KCC maintains secure office premises and work environments conducive to
private discussions and enforces confidentiality obligations that are
communicated and agreed to by all KCC employees. For information about personal
KCC has appointed a Privacy Officer who is
responsible for ensuring KCC’s compliance with the requirements of these privacy
principles and applicable privacy laws. Should you have any questions regarding
this Policy or concerns with respect to KCC’s compliance with these privacy
principles and applicable privacy laws, please submit inquiries, in writing, to
KCC’s Privacy Officer at 70 University Avenue, Suite 200, Mailbox 9, Toronto,
ON, M5J 2M4, or via email at KCCPrivacyOfficer@Kroll.com.
Changes to this Policy
We may amend this Policy at any
time. We will post the Policy as amended on our website and will take reasonable
steps to inform you of any amendments. We will obtain the necessary consents
required under applicable privacy laws if we seek to collect, use or disclose
your personal information for purposes other than those to which consent has
been obtained unless otherwise required or permitted by law.