In carrying out its business of security and investigation services for pre employment screening and background check solutions in the country, Triton (“Triton”, “we” and “us”) gathers Personal Information (as defined hereafter) about candidates from individual clients or from employer clients. In this Privacy Policy, the terms “you”, “user”, and “your” refer to individuals who use our products and services (“Services”), visit our website (“Website”), otherwise interact or communicate with us.

We are strongly committed to transparency and excellence in protecting your privacy and your Personal Information and we want you to understand how we collect, use, disclose and protect your Personal Information.

This Privacy Policy governs our processing of Personal Information. It explains what Personal Information we collect, why we use and disclose it, and the steps we take to protect it. This Privacy Policy also explains your rights with respect to your Personal Information, how to contact us if you have any questions about those rights or about our privacy practices. This Privacy Policy also sets out how you can manage the Personal Information we collect from you.

If you do not agree with our data processing practices as set forth in this Privacy Policy, please do not use the Services. If you do not understand or have any questions about this Privacy Policy, please contact us before using or continuing to use the Services.

CHANGES TO THIS POLICY

Triton continually reviews and updates its procedures to protect the privacy of individuals. Any changes to the Triton Privacy Policy will be posted on Triton’s Website.

1. INFORMATION

Personal Information means information about an identifiable individual. It also includes non-identifying information which, when combined with other information, creates a serious possibility of identifying an individual (collectively, “Personal Information”). Personal Information does not include:

1. business contact information when we collect, use or disclose it solely for the purpose of communicating or facilitating communication with you in relation to your employment, business or profession; or
2. information that cannot be attributed to an identifiable individual, such as information of an aggregate or anonymous nature (collectively, “Non-personal Information”).

2. Consent

Triton requires consent of individuals from whom the collection, use or disclosure of Personal Information is requested. Triton does not collect any Personal Information or provide Services without the consent of the individuals seeking Triton’s Services. Triton’s consent forms clearly define the purposes for which Triton collects Personal Information from individuals.

You may always refuse to provide your Personal Information. However, this may prevent you from using our Services or receiving responses to your inquiries or other information of interest. If you are not prepared to provide your consent or if you have questions about Triton’s collection of Personal Information, you are invited to contact Triton’s Privacy Officer.

Triton does not intentionally collect Personal Information from anyone under the age of 14.

3. COLLECTION OF PERSONAL INFORMATION

A. Types of Personal Information collected

Name and contact information. Name, email address, postal address, phone number and other contact information.

Identification information. Social security number, passport number, birth certificate, place of birth, nationality and Canadian status.

Demographic information. Date of birth, gender.

Education information. Educational background, training courses and diploma.

Professional or employment-related information. Title, occupation, professional association, union activities, references and past and current employers.

Financial information: Annual income and credit score.

Public records information: Information about you lawfully made available by federal, provincial or local governments. This includes information about legal proceedings in court records and bankruptcy registrations.

Technical Information. Geolocation information, computer and connection information, statistics on page views, traffic to and from the Website, referring URL, advertising data and standard web log information.

Other information. Criminal records.

B. How Personal Information is collected

Personal Information you provide to us.

We collect Personal Information directly from you when you submit an application form (online or on paper) in the context of a background screening check. We also collect Personal Information in the course of our interactions with you, for example when you visit our Website, contact client support or correspond with us by telephone, email or in any other way.

Personal Information we collect from third parties.

With your consent, we collect your Personal Information from other sources such as from third-party service providers, in order, among other things, to enable us to complete, verify or update Personal Information contained in our files and to carry out background checks, where applicable.

Your Personal Information may be provided to us by law enforcement agencies, screening and recruitment agencies, credit reporting agencies, your employer or your future employer. We can also collect your Personal Information from court clerks/registries, your previous and current employers, educational institutions, consumer reporting agencies, government agencies and from the references you provided.

When you visit our Website, Personal Information is collected by cookies and similar tracking technologies. A cookie is a small amount of data generated by our Website and stored by your web browser. Triton uses cookies only for language preferences and session identification.

Limiting Collection

Triton limits the collection of Personal Information to that is necessary for the purposes identified for the Services provided. Triton collects information by fair and lawful means. Triton continually reviews the amount and the type of information collected from clients to ensure that no more information is collected than what is necessary to carry out Triton’s work.

4. USE OF INFORMATION

Identifying Purposes

Unless we have your prior consent, or as may be permitted or required by law, we will only use and disclose your Personal Information for the purposes for which it was collected (and in accordance with this Privacy Policy).

Triton collects Personal Information from candidates and third parties in order to facilitate our background checks and to provide information to clients and to employers. The services offered by Triton can consist of criminal background checks, employment background check (history verification), education history verification, credit check verification, reference check verification, social media background check and pre employment screening.

Triton’s consent forms clearly identify the purposes for which Personal Information is requested for the Services provided. Triton does not collect more Personal Information than is necessary for the Services provided.

Triton does not use Personal Information for purposes other than those disclosed to clients for the Services provided. If Triton wishes to use Personal Information in its possession for other purposes, the consent of clients is obtained in advance. Triton retains Personal Information only as long as necessary for the Services provided.

Information that is non-identifiable to specific individuals (Non-personal Information) may be used for statistical purposes.

5. DISCLOSURE OF INFORMATION

With your consent, Personal Information collected may be disclosed to our employer clients, such as potential employers. We only disclose information at the employer’s request for the Services provided (reference checks, credit reports or social media background check).

Limiting Use, Disclosure 

Triton does not use or disclose Personal Information for purposes other than those for which it was collected with the consent of the individual, except to regulatory authorities as required by law. For example, we and our third party service providers may disclose your Personal Information to law enforcement, government bodies or other organizations in response to a warrant, subpoena, or other court order. Such disclosures may also be made for the purposes of investigating a breach of an agreement or contravention of law, for detecting, suppressing or preventing fraud, or as otherwise may be required or permitted by applicable law.

Only our employees and our third party service providers with a need to know Personal Information will have access to this data. All such employees and third party service providers have agreed to maintain the confidentiality of this information. Your Personal Information can also be shared with our certified Managed Service Provider which has been retained by us to assist with services and expertise in networking, security, cloud services and server architecture.

Your Personal Information is confidential and will only be shared with your potential employer and its staff with your consent.

6. RETENTION PERIOD 

Triton retains Personal Information only as long as necessary for the fulfillment of the identifying purposes as disclosed at the time of collection.

Personal Information related to criminal records are retained for a period of two (2) years for audit purposes as required by Triton’s partners. Generally, other Personal Information is destroyed, in accordance with Triton’s Privacy Policy and principles, once the results of the background checks have been communicated to the person who requested them. However, in some cases, Triton’s employer clients may determine the period of time for which they require information to be available for their purposes.

Personal information related to criminal records and criminal background check are retained for a period not shorter than two (2) years from the time it was submitted.

In all cases, Triton retains information that has been collected for a period no longer than seven (7) years from the time of collection, subject to applicable legal and regulatory requirements.

Personal Information is removed from our database as required by Triton’s clients, in accordance with Triton’s Privacy Policy and as required by law. When Personal Information is no longer required for Triton’s work or no longer required to be retained by law, Triton destroys the information in accordance  with its Privacy Policy and principles. Paper records containing Personal Information are disposed using cross-cut shredders (no use of single-strip continuous shredding). Information Technology Equipment containing Personal Information is safely disposed of by physically damaging the item and discarding it or by using a wipe utility to remove the original information.

7. TRANSFER OF INFORMATION OUTSIDE QUEBEC AND CANADA

While most of our work is done by our employees or authorized personnel who access Personal Information directly from our systems, we employ third-party service providers for certain specialized tasks such as data storage and processing, cloud computing, information technology support, or office services. Some of our third-party service providers are based outside Quebec, notably in British Columbia (Canada), the United States or the European Union. As a result, the Personal Information may be sent to these jurisdictions for processing, and while the information is in these jurisdictions, the courts, law enforcement authorities and national security authorities may have access to it.

Your Personal Information will only be transferred where the recipient jurisdiction offers adequate protection for your Personal Information, and only where there is a written agreement requiring the recipient to protect your Personal Information.

8. SAFEGUARDS MEASURES

Accountability

Triton is responsible for Personal Information under its control and has designated a Privacy Officer responsible for Triton’s compliance with the federal and local privacy rules and regulations. Triton requires all of its clients , including employers who request background checks on an individual, to enter into Privacy and Terms of Service Agreements, which emphasize the importance of Triton’s strict standards of privacy and accountability standards.

Triton continuously updates and trains its staff about the importance of protecting Personal Information. Triton has agreements with third-party organizations who may process information in the course of Triton’s work. Triton monitors the compliance of all third parties with Triton’s requirements and privacy principles.

Safeguards
Triton has various physical, technological and organizational measures and protocols in place to safeguard Personal Information from unauthorized access, disclosure, use, copying or modification. We continually update and upgrade our systems and protocols to avoid new threats to the safety of information in our possession.

Personal Information in Triton’s possession is stored in Triton’s secure databases and protected by security measures appropriate to the sensitivity of the information. Triton maintains physical (restricted access and secured building/rooms), technological (physical firewalls, intrusion detection, segregated network zones, encrypted data in transit and at rest) and organizational (limited access within the organization) systems and protocols to protect information from unauthorized access, disclosure, use, copying or modification. Triton continually updates and upgrades its systems and protocols to prevent new threats to the security of information in its possession.

We limit access to our client’s Personal Information to those who have a genuine business need to access it. Those who process your information will do so only in an authorized manner and are subject to a duty of confidentiality. All of our employees have been carefully selected and have undergone thorough security and privacy trainings.

9. YOUR RIGHTS

In order to benefit from Triton’s background check services, you must agree to the collection and processing of your Personal Information as described above. Your Personal Information is protected by data privacy laws which guarantee you the following rights:

• Withdraw your consent to the processing of your Personal Information at any time without having to justify your decision. This means that you will no longer be able to benefit from Triton’s Services and no further Personal Information about you will be collected. Please note that the Personal Information already collected to date based on your initial consent may not be deleted if required for legal reasons, for example under the two-year retention agreement with law enforcement authorities;
• Request information about the processing of your Personal Information, a copy of your collected Personal Information or the deletion of your Personal Information (if possible under applicable legal requirements);
• Request correction of your Personal Information if it is incorrect or incomplete;
• Request to restrict the processing of your Personal Information. This may mean that you may no longer benefit from Triton’s Services;
• File a complaint with a data protection authority.

You can also set your browser to refuse all or some browser cookies or to alert you when cookies are being sent. If you disable or refuse cookies or block the use of other tracking technologies, some parts of our Website may not be accessible or may not function properly.

Accuracy

Triton ensures that Personal Information is as accurate, complete, and up-to-date as possible for the purposes for which it is to be used, by all means available to Triton. Triton relies on its clients to provide accurate information; Triton maintains high standards of accuracy and verification with respect to its work.

Individual Access

Upon written request to Triton, 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 Triton’s possession and have it amended as appropriate. Triton provides access for individuals to review and challenge Personal Information in Triton’s possession. Triton corrects errors in information provided to employer clients. Individual clients seeking access to their Personal Information are invited to request access by writing to our Privacy Officer. Triton is committed to addressing and responding to individual client’s requests in a timely fashion.

Openness

Triton is committed to keeping its individual and employer clients informed as to its privacy policy and addressing any concerns clients may have. Clients are invited to voice any concerns by writing to our Privacy Officer.

Triton is committed to addressing and responding to your inquiries in a timely fashion.

10. Complaints

Individuals who have concerns about Triton’s privacy policies are invited to contact Triton’s Privacy Officer by writing. Triton is committed to addressing and responding to complaints in a timely fashion.

11. Contact us

For any information concerning your Personal Information and your rights, or if you wish to exercise any of your rights with respect to your Personal Information, please address your request to our Privacy Officer at:

Privacy Officer
Triton Canada Inc.
Email: privacy.offcier@tritonverify.com
Phone: (416) 494-4444
2235 Sheppard Avenue East, Suite 1503
Toronto, ON  M2J 5B5