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Phone: 403.217.2137

Toll Free: 1.877.417.2137

Fax: 1.866.696.9522

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Alberta Association
of Private Investigators

Code of Conduct
Code of Ethics
Right of First Contact
Code of Privacy
Policy for Managing Public Complaints Against Licenced Employees


Prime Investigations Ltd. adheres to the following Code of Conduct policy under the Alberta Justice and Solicitor General Security Services and Investigators Act.

All employees are required to:

  1. Act with honesty and ingegrity.
  2. Maintain confidentiality.
  3. Comply with all federal, provincial and municipal bylaws.
  4. Comply with the policies of the Security Services and Investigators Program and the employer.
  5. Respect and use all property and equipment in accordance with the terms and conditions of the individual licensee's license and employer policy.
  6. Comply with the terms and conditions of the individual's license.
  7. Comply with the business licensee's code of conduct for individual licenses.
  8. Engage in orderly and appropriate conduct.
  9. Report all adverse information, complaints and reports about any other licensee.
  10. Make or sign truthful and accurate statements.
  11. Abstain from the use of controlled drugs and controlled substances under the Controlled Drugs and Substances Act (Canada)
  12. Abstain from possessing or consuming alcohol while on duty.



Prime Investigations Ltd. subscribes to the following Code of Ethics which has been established by the Alberta Association of Private Investigators to promote and inspire confidence in our profession.

All work will be performed with due diligence in a responsible and professional manner.

  • Each member will maintain confidentiality of information.
  • Each member will work in accordance with the law.
  • Each member will ensure that all persons paid to assist in investigations are advised of this Code of Ethics and that they are expected to adhere to it.
  • Each member will strive to determine that a client has a legitimate purpose to instruct an investigation.



When a client requests Prime Investigations Ltd. to locate an individual for personal reasons, we are bound by our company policy to ensure that the right to Personal Privacy is upheld. For non-litigation locates, Prime Investigations Ltd will make the first contact with the individual being located and request their authorization for the release of their personal information to the client.  The person being located will always have the right of keeping their information private and as such, Prime Investigations Ltd will honor that right and not release that information to the client. This policy ensures the safety and privacy of all parties.



The Code of Privacy for Prime Investigations Ltd. follows and complies with the CSA Model Code for the Protection of Personal Information and is as follows:


Prime Investigations Ltd. will be responsible for all personal information under our control. We have designated a Chief Privacy Officer, whose responsibility it is to ensure our organization remains privacy compliant.

The Chief Privacy Officer for Prime Investigations Ltd. is Patrick Lam. Any privacy compliance or information management questions should be directed to him. Upon receiving an enquiry, the Chief Privacy Officer will respond within 30 days. Patrick Lam can be contacted at:

204, 1440 - 52 Street NE
Calgary, Alberta T2A 4T8
Telephone: (403) 217-2137
Facsimile: (866) 696-9522

Identify Purposes

Prime Investigations Ltd. will identify the purpose for which we collect personal information on affected individuals at or before the time of collection. All assignments received form our clients will be vetted to ensure their requests for information is compliant with PIPEDA.

Subsequent to the collection of personal information, Prime Investigations Ltd. may identify a new purpose or use for the information. In such an instance, we will seek to obtain prior consent for this new use, even if we have already identified certain initial purposes.


Prime Investigations Ltd. will obtain the appropriate consent from individuals regarding the collection, use or disclosure of personal information, except where the law provides an exception.

In most incidences, obtaining the knowledge and consent of individuals would defeat the purpose of an investigation, particularly with respect to a contravention of a law or breach of an agreement. Personal information will only be collected, used and disclosed by Prime Investigations Ltd. employees without consent in accordance with Section 7 of the Personal Information Protection and Electronic Documents Act, S.C. 2000, c.5 (PIPEDA) or under other lawful means.

Limiting Collection

Prime Investigations Ltd. will limit its collection of personal information to that which is necessary for purposes we have identified. We will only collect personal information for specific, legitimate purposes and will not collect personal information indiscriminately.

Our policies and procedures relating to the limitations on collection of personal information will be regularly communicated to our investigators who deal with collection, use and disclosure of personal information.


Limiting Use, Disclosure, and Retention

Prime Investigations Ltd. will limit the use, disclosure of personal information to those purposes for which it is initially collected, except with the consent of the individual or as otherwise permitted by law.
Information will only be retained for as long as necessary to fulfill those purposes. Personal information that is no longer required to fulfill identified purposes will be destroyed, erased, or made anonymous.


Prime Investigations Ltd. will make every effort to ensure that the personal information collected for an intended purpose is accurate, complete and up-to-date.

If a significant error or omission is identified, we will correct or amend the information as appropriate. Where necessary, we will send such corrected or amended information to third parties who have had access to the information in question.


Prime Investigations Ltd. will safeguard all personal information under our control in a manner that is appropriate to the sensitivity of the information. To this end we will take all the physical security measures necessary.

Personal information under the control of Prime Investigations Ltd. may be electronically stored. We will ensure that such records are protected through the application of the latest technical measures as well as physical access restriction.


Prime Investigations Ltd. will make available to the public information about our company, our privacy policies, and our Code of Privacy upon request. This information is available by requesting a hard copy by contacting Prime Investigations Ltd. at (403) 217-2137.

Individual Access

Upon request, an individual will be informed of the existence, use and disclosure of his / her personal information that is under our control. They may be given access to and be permitted to challenge the accuracy and the completeness of that information.

There are lawful exceptions that will prevent us from providing such access, which may be communicated to the individual as appropriate where access to the information is denied.

Challenging Compliance

An individual may address a challenge concerning compliance with the aforementioned policies and procedures to our Chief Privacy Officer whose details are listed within this correspondence.



As per sections 24, 25, 26 and 27 of the Security Services and Investigators Act (the Act), if a public complaint is received about an employee licensed under the Act, the following process will be followed.  This policy only applies to individuals directly employed by the company and does not apply to the licensed employees of contract service providers.

For the purposes of this section, Registrar refers to the Registrar, Security Services and Investigators Act, Alberta Solicitor General and Public Security.



Complaints against individual licensees must be made in writing to the licensee’s employer within 90 days of the action or circumstances that prompted the complaint.

If a complainant is unable to provide a written document due to a valid reason such as language barrier or disability, an employee or manager shall take the necessary steps to have the complaint recorded in writing on behalf of the complainant.  The complainant must sign the written complaint.



Within 30 days of receiving the complaint the employer must acknowledge receipt, in writing, to the complainant (as per section 26 of the Security Services and Investigators Ministerial Regulation).



In acknowledging the complaint, the employer must notify the licensed employee who is subject of the complaint. 

The employer may delay notification to the employee under the following circumstances.  In the case where it is uncertain as to the appropriateness of informing a licensee about a complaint, the Registrar, should be consulted.

  • The complainant may be placed in danger,
  • The complainant may face other inappropriate action by the licensed employee should the licensed employee be informed,
  • The notification may impede the gathering of evidence during an internal investigation.
  • A reasonable likelihood exists that the complaint may lead to charges under federal or provincial legislation and that notification could impede any resulting police or other investigative agency investigation.
  • Any other situation identified by the employer or Registrar in which it may be appropriate to delay informing the licensed employee about the complaint.


The employer must, within 90 days,

  • Investigate and dispose of the complaint (unless 3.0 below applies), and
  • Notify the complainant, the licensed employee who is the subject of the complaint and the Registrar (use Public Complaint Outcome Form PS3749), in writing, of the disposition of the complaint with reasons

1.4.1   The letter of disposition must advise the complainant of their right to request a review of the outcome by the Registrar.  The letter must indicate the following:

  • If dissatisfied with the outcome of the company’s investigation the complaint may request a review of the disposition by the Registrar
  • The request must be made in writing within 30 days of receipt of the disposition.
  • Requests for review must be submitted to

            Complaints Coordinator, Security Programs
            Solicitor General and Ministry of Public Security
            10th Floor, 10365-97 Street
            Edmonton AB T5J 3W7
            Fax: 780-427-4670




Any allegations of criminal misconduct must be reported to the police service of jurisdiction for investigation.  Complaints that contain allegations of excessive force are considered to be criminal allegations



In allegations of criminal misconduct the company may consider the obligation to reach a conclusion within 90 days, as per section 25(4) of the Act, fulfilled if the company has:

  • Notified the police service of the allegation, and
  • Provided written notification to the complainant, and
  • Provided written notification to the Registrar that this action has occurred.


A concurrent internal investigation may proceed provided company employees interact/cooperate with the police service and take such steps that are necessary to avoid contaminating the criminal investigation.  If a concurrent investigation is conducted it must be completed within 90 days as per section 25(4) of the Act and the outcome report as per section 1.0 of this policy.




The Act recognizes that some complaints will be made under circumstances in which an investigation is not required. 



Under the following conditions, the company may choose not to investigate a complaint.

  • Employer utilizes an informal resolution process (see 3.4.a below).
  • Employee no longer works for the employer.
  • Contact with complainant after submission of initial complaint can not be made (documentation showing this is the case should be kept in case of request for review by the Registrar).
  • Anonymous complaints.
  • Frivolous:  a complaint intended merely to harass or embarrass.
  • Vexatious:  a complaint that has no basis in fact or reason, with its purpose to bother, annoy, and embarrass the individual or business licensee.
  • Bad Faith:  filing a complaint with intentional dishonesty or with intent to mislead.
  • Having regard of all the circumstances, no investigation, in the option of the employer or Registrar, is deemed necessary.


Notification that investigation will not proceed
The employer must notify the complainant within 90 days of receipt of the complaint that the matter will not be investigated, except where an informal resolution process is undertaken, the complainant cannot be contacted or the complaint is anonymous.

3.2.1 The letter must advise the complainant of their right to request a review of the outcome by the Registrar.  The letter must indicate the following:


  • If dissatisfied with the outcome of the company’s investigation the complaint may request a review of the disposition by the Registrar
  • The request must be made in writing within 30 days of receipt of the disposition.
  • Requests for review must be submitted to:

Complaints Coordinator, Security Programs
Solicitor General and Ministry of Public Security
10th Floor, 10365-97 Street
Edmonton AB T5J 3W7
Fax: 780-427-4670



Anonymous complaints

Anonymous complaints do not allow the employer or the Registrar to discharge required legal responsibilities and therefore they are not considered a complaint under the Act.

If the nature of an anonymous complaint is serious, the employer shall review the matter and consider what, if any further action should or can be taken. In the event some element of substance to the allegation is uncovered, the employer must:


3.3.1   Within 90 days,

  • Investigate and dispose of the complaint, and
  • Notify the Registrar in writing (use Public Complaint Outcome Form PS3749), of the disposition of the complaint with reasons.


Informal resolutions of complaints

Successful informal resolution allows an investigation to be discontinued.  If, in the employer’s opinion and having regard to all of the circumstances, no investigation is necessary, the employer may discontinue the investigation.

  1. An informal complaint proceeding can be initiated by contacting Patrick Lam with Prime Investigations Ltd. at the main office number of 403-217-2137 between 8:00 am and 5:00 pm of regular business days or by e-mail at

  2. Upon successful resolution of complaint, document outcome and obtain the complainant’s signature, where possible, to show that a matter has been informally resolved.
    This would preclude the complainant from claiming duress or that they did not agree with the outcome.  Without clear documentation, complaints that are informally resolved by the employer may, in some circumstances, be eligible for review by the Registrar and subsequently the Director of Law Enforcement, Province of Alberta.