CivicTrust Integrity Services

Effective Date: 03/09/2026

Last Updated: 03/09/2026

1. Our Commitment to Privacy

CivicTrust Integrity Services is committed to protecting personal information and handling confidential reports, complaints, and investigation records with care, integrity, and accountability.  We provide independent complaint intake, whistleblower reporting, case management, workplace and organizational investigations, and related advisory services for municipalities, public-sector organizations, non-profit organizations, First Nation entities, and private companies.  Because our work may involve sensitive information about individuals, workplaces, governance matters, misconduct allegations, financial concerns, harassment, discrimination, fraud, safety issues, and other confidential matters, we apply privacy, confidentiality, and security safeguards appropriate to the sensitivity of the information we handle.

2. Scope of This Policy

This Privacy Policy explains how CivicTrust Integrity Services may collect, use, and disclose personal information. This policy applies to personal information we receive through:

• Our website;
• Complaint lines or reporting portals;
• Email, telephone, online forms, video meetings, or written communications;
• Intake, triage, investigation, and reporting processes;
• Client engagements and service agreements;
• Inquiries from prospective clients, complainants, witnesses, respondents, employees, contractors, and members of the public.

Where CivicTrust Integrity Services provides services to a client organization, additional privacy terms may apply under our agreement with that client. In some cases, the client organization may be the organization primarily responsible for the collection, use, and disclosure of records and the attendant legal obligations.

3. What Personal Information We Collect

Depending on the nature of the interaction or matter, we may collect the following types of personal information:

A. Complainant information

• Name, if provided;
• Contact information;
• Role, title, department, or relationship to the organization;
• Preferred method of contact;
• Information provided in a report, complaint, interview, or supporting document.

B. Information about individuals involved in a matter

• Names of respondents, witnesses, employees, officials, contractors, board members, volunteers, or third parties;
• Workplace, governance, or organizational role;
• Allegations, concerns, observations, timelines, and events;
• Relevant communications, documents, records, screenshots, notes, or attachments.

C. Sensitive information

Depending on the matter, reports or investigations may include sensitive personal information such as information related to workplace conflict, harassment, discrimination, health, disability, finances, discipline, performance, safety, legal issues, or allegations of misconduct.  We ask individuals not to provide more personal information than is reasonably necessary for the concern being reported or investigated.

D. Website and technical information

• When you visit our website, we may collect limited information generated by your visit, such as:
• IP address and other related information;
• browser type;
• operating system;
• pages visited;
• date and time of visit;
• referral source; and
• cookies or similar technologies used for website functionality, security, or analytics.

4. Why We Collect Personal Information

CivicTrust Integrity Services collects and uses personal information for purposes that include:

• Receiving and documenting complaints, disclosures, or reports;
• Operating confidential or anonymous reporting channels;
• Assessing, triaging, and classifying reported concerns;
• Conducting independent investigations or reviews;
• Contacting complainants, witnesses, respondents, client representatives, or other relevant individuals;
• Gathering, reviewing, and assessing documents and evidence;
• Preparing investigation summaries, findings, recommendations, or reports;
• Managing client relationships and service agreements;
• Maintaining case records, audit trails, and quality control; and
• Complying with legal, regulatory, contractual, professional, insurance, or risk-management obligations.

5. Consent

Where required, we collect, use, and disclose personal information with consent. 

By submitting information to CivicTrust Integrity Services through our website, reporting line, intake process, or direct communication, you consent to our collection, use, and disclosure of that information for the purposes described in this policy and any applicable notice provided at the time of collection.

6. Anonymous Reporting

Where available, individuals may submit reports anonymously.  If you choose to report anonymously, CivicTrust Integrity Services will not require you to provide your name or contact information. However, anonymity cannot be absolutely guaranteed in every case. Your identity may become apparent from the nature of the information provided, the facts of the matter, document metadata, follow-up communications, or legal and procedural requirements.  Anonymous reporting may also limit our ability to follow up, verify information, complete an investigation, or advise you of next steps.

7. Confidentiality of Reports and Investigations

CivicTrust Integrity Services treats complaint and investigation information as confidential.  However, confidentiality is not absolute. Information may need to be shared where reasonably necessary to:

• Assess or investigate a concern;
• Provide procedural fairness to a person responding to allegations;
• Communicate with authorized client representatives;
• Obtain legal, technical, investigative, or professional support;
• Comply with law, court orders, regulatory requirements, or contractual obligations;
• Address threats to safety, security, or property;
• Prevent or respond to serious misconduct, fraud, harassment, violence, discrimination, retaliation, or other significant risk.

We limit disclosure to what is reasonably necessary in the circumstances.

8. Disclosure of E-Personal Information

We do not sell personal information.

CivicTrust Integrity Services may disclose personal information to:

• Authorized representatives of a client organization;
• Boards, councils, audit committees, ethics officers, senior administration, legal counsel, or designated contacts, where appropriate;
• Investigators, consultants, translators, transcription providers, technology providers, secure case-management providers, or other service providers assisting us;
• Insurers, auditors, professional advisors, or legal counsel;
• Regulators, law enforcement, courts, tribunals, or government authorities, where required or permitted by law;
• Individuals involved in a process where disclosure is necessary for fairness, response, verification, or resolution.

9. Service Providers and Storage Location

CivicTrust Integrity Services may use trusted third-party service providers for services such as secure hosting, email, case management, reporting platforms, document storage, transcription, analytics, cybersecurity, accounting, and administrative support.

Personal information may be stored or processed in Canada or in other jurisdictions, depending on the systems and service providers used. Where information is stored or processed outside Canada, it may be subject to the laws of that jurisdiction.

Where a client requires Canadian data residency or specific security controls, those requirements should be addressed in the client service agreement before services begin.

10. Safeguards

CivicTrust Integrity Services uses reasonable safeguards in an effort to protect personal information in our custody and control against unauthorized access, use, modification, and disclosure.

These may include:

• Restricted access on a need-to-know basis;
• Password protection and multi-factor authentication where available;
• Encryption or secure transfer methods where appropriate;
• Secure file storage and case-management practices;
• Confidentiality obligations for employees, contractors, and service providers;
• Internal privacy and confidentiality procedures;
• Physical, technical, and administrative safeguards;
• Secure disposal or deletion practices;
• Incident-response procedures.

No method of transmission or storage is completely risk-free. We encourage individuals not to send highly sensitive personal information by unsecured channels unless necessary.

11. Accuracy of Personal Information

We make reasonable efforts to ensure personal information used in our services is accurate, complete, and up to date for the purposes for which it is used.  In investigation matters, information may include allegations, opinions, recollections, witness statements, or disputed facts. The existence of information in an investigation file does not mean that CivicTrust Integrity Services has accepted it as proven.

12. Retention and Destruction

CivicTrust Integrity Services retains personal information only as long as reasonably necessary for the purposes for which it was collected, including to complete intake, assessment, investigation, reporting, quality control, legal compliance, insurance, audit, limitation-period, and contractual requirements.

Unless a different retention period is required by law, contract, client instruction, litigation hold, or regulatory obligation, investigation and complaint records are generally retained for five (5) years after the matter is closed.

When personal information is no longer required, we will securely destroy, delete, anonymize, or archive it in accordance with any legal requirements.

13. Access and Correction

Individuals may request access to their personal information or ask that inaccurate or incomplete information be corrected, subject to legal, contractual, confidentiality, privilege, safety, and investigative limitations.

In some cases, CivicTrust Integrity Services may not be able to provide direct access to certain records, including where the information:

• Belongs to or is controlled by a client organization;
• Contains personal information about another individual;
• Is subject to legal privilege;
• Forms part of an active investigation;
• Could compromise confidentiality, safety, fairness, or the integrity of a process;
• Cannot be disclosed under applicable law.

Where appropriate, we may direct the individual to the relevant client organization.

14. Privacy Breaches and Incidents

If CivicTrust Integrity Services becomes aware of a privacy incident involving personal information under our custody and control, we will take steps to contain, assess, investigate, document, and respond to the incident.  Where required, we will notify affected individuals, clients, regulators, or other organizations in accordance with applicable privacy laws and contractual obligations.

15. Website Cookies and Analytics

Our website may use cookies or similar technologies to support website functionality, improve user experience, measure site traffic, and protect website security. 

You can adjust your browser settings to refuse or disable cookies. Some website features may not function properly if cookies are disabled.

16. Email and Electronic Communications

If you contact CivicTrust Integrity Services by email or subscribe to receive updates, we may use your contact information to respond to your inquiry or provide information you requested.  You may unsubscribe from marketing or informational emails at any time.

We do not use complaint or investigation information for marketing purposes.

17. Use of Artificial Intelligence and Automated Tools

CivicTrust Integrity Services does not use personal information from reports, complaints, or investigations to train public artificial intelligence models.

We do not make final investigation findings or decisions about individuals solely through automated decision-making.  If technology-assisted tools are used to support administrative, transcription, document-management, translation, summarization, or analytical work, we will use reasonable safeguards and limit their use to purposes consistent with this policy, client agreements, and applicable law.

18. Public-Sector and Access-to-Information Considerations

Where CivicTrust Integrity Services provides services to municipalities, public bodies, First Nation entities, or other public-interest organizations, records may be subject to applicable public-sector privacy, access-to-information, archival, records-management, legal-hold, or disclosure obligations.  Clients are responsible for determining their own statutory access, privacy, record-retention, and disclosure obligations. CivicTrust Integrity Services will cooperate with clients in accordance with applicable law and contractual requirements.

19. Children and Youth

Our services are not directed to children. However, some matters may involve children or youth as complainants, witnesses, affected individuals, or subjects of concern.  Where we receive personal information about children or youth, we will treat it as sensitive and apply appropriate safeguards.

20. Changes to This Privacy Policy

CivicTrust Integrity Services may update this Privacy Policy from time to time to reflect changes in our services, legal obligations, technology, or privacy practices.

21. Contact Us

Questions, concerns, access requests, correction requests, or privacy complaints may be directed to:

Privacy Officer

CivicTrust Integrity Services

Email: CivicTrustIntegrity@gmail.com

We will review and respond to privacy concerns in accordance with applicable law.