The staff and management of Collection Recovery Systems are committed to respecting the personal privacy of individuals we deal with.

Collection Recovery Systems will comply with (i) Personal Information Protection and Electronic Documents Act (PIPEDA), a federally enacted act which protects personal information that is collected, used or disclosed; (ii) Collection Agencies Act, which dictates how we are to perform our services, collection and use of personal information and any future provincial legislation as it relates to the rights of consumers. For the purposes of this policy, personal information means information about an identifiable individual, but does not include the name, title, or business address or telephone number of an employee of an organization. Any reference to a Customer within this policy is in reference to personal information and not business information.

The Canadian Standards Association Mode Code ("code") for the protection of personal information is a national standard that was developed by the Canadian Standards Association. The Code is the central part of PIPEDA. The Code's ten privacy principles are identified in PIPEDA as follows:

1) Accountability
2) Identifying Purpose
3) Consent
4) Limiting Collection
5) Limiting Use, Disclosure & Retention
6) Accuracy
7) Safeguards
8) Openness
9) Individual Access
10) Challenging Compliance

Collection Recovery Systems has implemented policies and procedures to give effect to the principles including:

1. Implementing procedures to protect personal information.
2. Establishing procedures to receive and respond to complaints and inquiries in connection with the collection, use and disclosure of personal information of Collection Recovery Systems
3. Training staff and communicating information to Collection Recovery Systems staff about our policies and procedures.
4. Developing information to explain the policies of and procedures of Collection Recovery Systems to Customers.

The ten (10) principles are explained in more detail as follows:

1. Accountability
Collection Recovery Systems is responsible for the personal information under its control and has designated two (2) Privacy Officers to be accountable for Collection Recovery Systems's compliance with PIPEDA.

2. Identifying Purpose
Collection Recovery Systems will identify and document the purposes for which it collects personal information. Only personal information that is necessary for those identified purposes will be collected.

Collection Recovery Systems shall only collect, use and disclose personal information about Customers for the following purpose:
a) To assist Collection Recovery Systems in the collection of debts assigned by clients or purchased by Collection Recovery Systems

Collection Recovery Systems does not collect and use personal information about Customers for the following purpose:
a) To sell Customer lists to other entities.

3. Consent
The knowledge and consent of Customers is required for the collection, use or disclosure of personal information, except when inappropriate, including where permitted or required by law.

In certain circumstances, personal information can be collected, used or disclosed without the knowledge or consent of the Customer. For example, legal, medical, debt collection or locating the Customer for their benefit.

Although information may be publicly available, Collection Recovery Systems will treat this in accordance with PIPEDA principles. Moreover, Collection Recovery Systems may provide personal in formation to its lawyers, advisors, agents and/or third parties to collect a debt, comply with a subpoena, warrant or other court order, to a government institution requesting the information upon lawful authority, or as may be otherwise required by law. In all cases, proper internal authorization for disclosure procedures will be followed.

Copies of Collection Recovery Systems's Privacy Policy will be published on the Collection Recovery Systems website at www.collectionrecovery.ca

4. Limiting Collection
The collection of personal information will be limited to that which is appropriate in the circumstances.

The Collection Recovery Systems website does not use or capture cookies; a technology that installs a small amount of in formation on a visitor's computer to permit the Website to recognize future visits from that computer.

5. Limiting Use, Disclosure & Retention
Collection Recovery Systems will not use or disclose personal information for purposes other than those for which it was collected, except with the consent of the Customer or as required by law. Personal information cannot be used or passed on in a manner inconsistent with the identified purpose.

Collection Recovery Systems may disclose a Customer's personal information to third parties retained by Collection Recovery Systems for the purposes of collecting a debt from a Customer.

Certain Collection Recovery Systems employees may be given access to a Customer's personal information collected by Collection Recovery Systems in so far as their duties require access for the purposes outlined. Collection Recovery Systems employees are governed by a non-disclosure agreement prohibiting disclosure or use of any confidential or personal information for any purposes other than the stated purpose.

Personal information that has been used to make a decision about a Customer will be retained in accordance with the Collection Recovery Systems document retention guidelines. Personal information that is no longer required will be destroyed, erased or made anonymous. Collection Recovery Systems retains personal information of a Customer only for as long as it is required for Collection Recovery Systems's business purposes or as required by federal and provincial laws.

6. Accuracy
Collection Recovery Systems will take reasonable steps to ensure that the personal information under its control is as accurate, complete and up-to-date as is necessary for the purposes for which it is to be used.

Collection Recovery Systems will not routinely update personal information, unless such a process is necessary to fulfill the purposes for which the information was collected. Collection Recovery Systems will take reasonable steps to ensure that personal information that is used on an ongoing basis, including personal information that is disclosed to third parties, is as accurate and up-to-date.

Access to a Customer's personal information on record with Collection Recovery Systems may be requested by that Customer in order to review and amend their personal information, as appropriate.

7. Safeguards
Collection Recovery Systems will take responsible steps to protect personal information through security safeguard as appropriate to the sensitivity of the personal information. Employees of Collection Recovery Systems who have access to personal information will be made aware of the importance of maintaining the confidentiality of personal information. Security safeguards protect against loss or theft, as well as unauthorized access, disclosure, copying, use or modification.

8. Openness
Collection Recovery Systems will make available to any Customers specific information about its policy and guidelines relating to the management of personal information.

Collection Recovery Systems will be open about its policy and procedure with respect to the management of personal information, and Customers will be able to acquire information about these policies

9. Individual Access
Collection Recovery Systems will inform a Customer of the existence, use and disclosure of their personal information and will provide access to that personal information, upon written request. Collection Recovery Systems will assist a Customer in the preparation of a request for access when such a Customer requests assistance. Collection Recovery Systems will inform the Customer whether or not it holds personal information about them, and will indicate the source of any such personal information, when possible.

There may, however be situations in which Collection Recovery Systems will not be able to provide access to all the personal information that it holds about a Customer, although these situations will be limited and specific, and permitted or required by law. For example, Collection Recovery Systems will not be able to provide access to Customer's personal information where given such access would likely reveal personal information about a third party, unless that third party's personal information can be severed from the Customer's personal information. If Collection Recovery Systems refuses a request for access, the Customer will be informed in writing of the refusal, setting out the reasons for the refusal and informing the Customer of their recourse.

Collection Recovery Systems will require that Customers requesting access to their personal information will provide the appropriate verification information required to obtain access to such personal information. This information will not be used for any purpose other than to permit Collection Recovery Systems to provide an account of the existence, use and disclosure of the Customers' personal information.

Collection Recovery Systems will be as specific as possible in providing an account of third parties to which personal information has been disclosed, and will provide a list of organizations to which personal information has been disclosed.

Collection Recovery Systems will respond to the Customer's request to access their personal information within a reasonable time, and not later than 30 days after receipt of the request. Collection Recovery Systems may be entitled to a 30 day extension to respond, in limited circumstances, in which case the Customer will be notified of such an extension, the new time limit, the reasons for extending the time limit, and their right to make a complaint to the Privacy Commissioner with respect to the extension.

Collection Recovery Systems may charge a reasonable fee for responding to a request. This fee will be determined based on the request and any request specific administrative or system costs that may be incurred, and will advise the Customer, in advance, of the approximate cost. The personal information requested would be provided in a form that is generally understandable.

A Customer will be able to challenge the accuracy and completeness of the personal information and have it amended as appropriate. Depending upon the nature of the personal information challenged, amendment may involve the correction, deletion or additional of information, and the amended information will be transmitted to third parties having access to the personal information, where appropriate.

When a Customer's challenge to the accuracy and completeness of their personal information is not resolved to their satisfaction, Collection Recovery Systems will record the unresolved challenge and will transmit the existence of the unresolved challenge to third parties who have access to the personal information, where appropriate.

10. Challenging Compliance
A Customer will be able to address a challenge concerning compliance with the above principles to the Privacy Officer. Collection Recovery Systems will handle all complaints or inquiries about the policies and procedures relating to the handling of personal information in line with the processes that are in place.

Collection Recovery Systems will inform Customers who make inquiries or lodge complaints of the existence of the relevant complaint procedures. Collection Recovery Systems will investigate all complaints, and if a complaint is justified, Collection Recovery Systems will take appropriate measures, including amending policies and procedures.

How to contact us

If you have any questions or comments about this Privacy Policy or you feel that your concerns or complaints have not been resolved to your satisfaction, please contact us

by calling our Head Office at 905-434-6186,

Chief Privacy Officer: Paul Scott, President

By fax to 905-434-6825

In writing to the Privacy Division:
  Collection Recovery Systems
  286 King St. W
  Suite 102
  Oshawa, Ontario, Canada
  L1J 2J9