Portal Privacy Policy

Commissionaires collects information by fair and lawful means. Commissionaires strictly adheres to industry standards and applicable laws for all our business lines.

Commissionaires’ Criminal Record Checks are fully compliant with applicable Canadian privacy and human rights guidelines, including The Personal Information Protection and Electronic Documents Act (PIPEDA) and the Canadian Criminal Records Act.

Recognizing that Criminal Record Checks are a particularly sensitive matter, Commissionaires works in close contact with the Royal Canadian Mounted Police (RCMP), which regulates the industry.

Commissionaires is responsible for personal information under its control and has designated a Privacy Officer responsible for Commissionaires’ compliance with the federal and local privacy rules and regulations.

Commissionaires continuously updates and trains its staff with regard to the importance of protecting personal information, and monitors their compliance on an ongoing basis.

Commissionaires requires vendors to enter into Privacy and Terms of Service Agreements, which identify the importance of Commissionaires’ strict privacy and accountability standards, and monitors their compliance on an ongoing basis.

Commissionaires maintains physical, technological and organizational systems and protocols to safeguard information from unauthorized access, disclosure, use, copying or modification.

Commissionaires has well-defined network boundaries that employ a current Public Key Infrastructure (PKI) solution, the same used by the Government of Canada, the RCMP and the Provinces of Ontario and Quebec.

This strong 2-factor identification and authentication PKI solution is certified and accredited by the RCMP and PWGSC Canadian Industrial Security Directorate (CISD), including the equipment, physical facilities and personnel to process Protected B.

All information received is maintained in confidential, secured files, with restricted access to only those who are authorized and required to access this information and these files.

Commissionaires continually updates and upgrades its systems and protocols to avoid new threats to the safety of information in its possession.

In order to conduct any type of Criminal Record Check, several guidelines must be followed, including:

• verification of each candidate’s identity
• verification of the candidate’s age
• obtaining informed consent to perform the search
• collecting authorization to disclose results to a third party

Commissionaires gathers no more personal information than is necessary for the services being provided. Commissionaires does not use personal information for any other purposes than those that are disclosed to individuals for the services being provided to them.

If Commissionaires wishes to use personal information in its possession for any new purpose, the consent of individuals is obtained prior to use. Commissionaires maintains personal information only for as long as is required for the services being provided.

In Canada, informed consent is required from each candidate to perform a Criminal Records Check.

To provide this service through the online portal, Commissionaires requires the express, informed consent of individuals from whom the collection, use or disclosure of personal information are being sought.

Commissionaires does not collect any personal information or provide services without the unequivocal, informed consent of the individuals seeking Commissionaires’ services.

Commissionaires does not use personal information for reasons other than those specified for the services being provided. Only information that is non-identifiable to specific individuals may be used for statistical purposes.

When using the online platform, the candidate must first review an RCMP-issued “Authorization and Consent” form and provide consent to authorize the Criminal Records Check search by way of a digital signature.

The candidate must also provide consent to authorize the release of the results to a third party, and/or the third party’s agents.

The consent forms clearly set out the purposes for which Commissionaires collects personal information from individuals. Individuals who are not prepared to provide their consent or who have questions about Commissionaires’ collection of personal information are invited to contact Commissionaires’ privacy officer by writing to:

Commissionaires retains information that has been collected for a period no shorter than two (2) years from the time it was submitted, in accordance with RCMP CCRTIS directives. Commissionaires comply with all privacy laws, regulations, and directives including without limitation the provisions of the Personal Information Protection and Electronic Documents Act (PIPEDA), which are applicable to its performance of its obligations.

Commissionaires purges captured biometric data within thirty (30) days after the day on which it collected them from Livescan systems. Commissionaires will retain the nominal information respecting each request for a Criminal Record Check that Commissionaires received from the customer, for a period of two (2) years beginning on the day on which Commissionaires provided the customer with the results of the request.

Nominal information consists of the transaction date, name, date of birth and address of a Customer’s applicant that is the subject of the criminal record check.

Individuals who have concerns or complaints about Commissionaires’ privacy policies are invited to contact Commissionaires’ Privacy Officer by writing to:

Commissionaires is committed to addressing and responding to concerns and complaints in a timely fashion.

Upon written request to Commissionaires, an individual shall be informed of the existence, content, use and disclosure of his or her personal information and shall be given access to that information. Individuals may challenge the accuracy and completeness of the information in Commissionaires’ possession and have it amended as appropriate.

Commissionaires provides access for individuals to review and challenge personal information in Commissionaires’ possession. Individuals seeking access to their personal information are invited to request access by writing to:

Commissionaires is committed to addressing and responding to requests for individual access in a timely fashion.