1. Introduction

Global Background & Waiver Services Inc. (“Global Background,” “GBWS,” “we,” “our” or “us”) provides fingerprinting, criminal record check facilitation, background-screening assistance, FBI Identity History Summary assistance, record suspension (pardon) services, criminal rehabilitation, temporary resident permit and U.S. entry waiver application assistance, and related services from our office in Mississauga, Ontario.

These services involve sensitive information such as identity documents, fingerprints, criminal record details, court documents and immigration records. This Privacy Policy explains what we collect, why, who sees it, how long we keep it, and how you can exercise your rights.

We handle personal information in line with the federal Personal Information Protection and Electronic Documents Act (PIPEDA) and its fair information principles, and with other privacy laws that apply to a particular client. For example, if you live in Quebec, Quebec’s private-sector privacy law may also apply (see the Commission d’accès à l’information).

By using our website, contacting us, booking an appointment or requesting a service, you confirm you have had the opportunity to read this policy. Where the law requires your consent, we obtain it as described in section 5.

2. Personal Information We Collect

What we collect depends on the service you request.

Identification and contact details: full legal name and other names relevant to your application; date and place of birth; home and mailing address; phone and email; the identification details needed to verify you (passport, driver’s licence or similar); and appointment and booking details.

Fingerprints and background-check information: fingerprint impressions or digital images where the service requires them; signed consent forms and declarations; the type and purpose of the check; application identifiers and processing status; and the information needed to communicate with the receiving authority.

Criminal, court and immigration information: criminal history and records; court documents, charges, convictions and sentences; record suspension, criminal rehabilitation, temporary resident permit and U.S. waiver applications; immigration status and application history; and employment or travel details relevant to your file. We collect this only where reasonably necessary for the service you requested.

Website and technical information: IP address, device and browser type, pages viewed, referring site, approximate location and cookie data (see section 8).

Communications and payment records: emails, calls, contact-form messages, invoices and payment records. We do not store full payment card numbers; card payments are handled by our payment processor.

3. How We Collect It

We collect personal information:
  • directly from you, by form, phone, email, booking tool or in person;
  • from the identification and supporting records you provide;
  • through the fingerprinting and identity-verification steps of your service;
  • from an authorized representative, employer or referring organization, where you have authorized it;
  • from the RCMP, FBI, police services or other authorities, where the service and your authorization allow; and
  • through our website, booking tools and communications systems.

4. Why We Use and Disclose It

We use personal information only for purposes a reasonable person would consider appropriate, and only those we have explained to you:
  1. verifying your identity and working out what your service requires;
  2. capturing, preparing and submitting fingerprints and applications through authorized channels;
  3. facilitating criminal record checks, FBI Identity History Summary requests and other background checks;
  4. preparing and administering record suspension, criminal rehabilitation, temporary resident permit, immigration or waiver files you have asked us to handle;
  5. communicating with you about appointments, documents, status and requirements;
  6. processing payments and keeping accounting records;
  7. responding to enquiries, complaints and requests;
  8. meeting legal, regulatory and contractual obligations;
  9. protecting our systems, premises and operations from fraud and misuse;
  10. maintaining and improving our website and services; and
  11. sending marketing messages, only with your consent (see section 5).
We will not use your information for an unrelated purpose without first obtaining any consent the law requires.

5. Consent

Consent to the service. We obtain consent through signed or electronic forms and written authorizations, depending on the service and the sensitivity of the information. Fingerprint-based checks and government applications usually need specific consent forms. Without the consent a service requires, we may be unable to complete it.

Consent to electronic messages. When you give us your email address or phone number, you agree that we may contact you about your booking, file and our services, including by email, phone and text message. You may withdraw this consent at any time using the unsubscribe link in any email, by replying STOP to a text message, or by contacting our Privacy Officer. Marketing and promotional messages are sent only with your express or otherwise valid consent, and in line with Canada’s Anti-Spam Legislation (CASL). Service messages about an active file may continue after you opt out of marketing. See the CRTC’s CASL guidance.

Withdrawing consent. You may withdraw consent subject to legal and contractual limits. Withdrawal may not be possible once a submission has been sent to an authority, or where the law requires us to keep information. We will explain the effect of your withdrawal.

6. Fingerprints and Government Processing

Fingerprinting and background-check services involve sending personal information to a designated processing authority, such as the RCMP or the FBI. Those authorities have their own legal powers, retention rules and privacy practices, which we do not control. Please read their published notices for how they handle your information.

GBWS’s own handling is separate. After your submission is confirmed, we keep fingerprint images and scans for no longer than [30 days] and then securely delete them, unless the law requires otherwise or you ask us to keep them for a resubmission. We keep a record of the submission (reference number, date and result status), but not a reusable copy of your fingerprints.

7. Disclosure and Cross-Border Processing

We do not sell personal information. We disclose it only as follows:
  • Government and law-enforcement authorities: the RCMP, Canadian Criminal Real Time Identification Services, the FBI, police services, the Parole Board of Canada, Immigration, Refugees and Citizenship Canada, U.S. Customs and Border Protection and courts, as your service requires.
  • People you authorize: an employer, lawyer, representative or other recipient you have designated in writing.
  • Service providers: website hosting, appointment booking, IT support, email and messaging, payment processing, document management and data security providers. They may use your information only to provide services to us, and we require appropriate protections.
  • Legal requirements: where a law, court order or lawful request requires it, or to establish or defend legal claims.
Where your data is held. Our website, booking and file systems are hosted in [Canada, confirm]. Some services, such as FBI requests and U.S. waivers, involve sending information to the United States, and some providers (for example email or analytics) may process data outside Canada. Information processed outside Canada may be accessed by authorities there under local law. We use contracts and safeguards appropriate to the sensitivity of the data, and we will tell you in advance if your service involves a material cross-border transfer.

8. Cookies and Analytics

Our website uses cookies and similar technologies for essential functions (such as the booking form), to remember preferences, and to understand how the site is used. We currently use [Google Analytics 4; confirm all tools in use]. These tools collect technical data such as IP address, browser, pages visited and interactions. Optional analytics and advertising cookies are set only after you accept them in our cookie banner, and you can change your choice at any time. You can also block cookies in your browser settings; some features may then not work.

9. How We Protect Information

We use safeguards proportionate to the sensitivity of the information, including access limited to staff who need it, authentication and access controls, encrypted transmission and secure storage for electronic files, locked storage for any paper records, staff confidentiality training, and secure disposal. No system is completely secure, so we cannot guarantee absolute security, but we take reasonable steps to protect information in our care.

10. Retention and Disposal

Type of record

How long we keep it

Fingerprint images and scans

[30 days] after confirmed submission (see section 6)

Identity document copies and supporting documents

Until your file is complete, then deleted within [90 days]

Client file and correspondence

[2 years] after the file is closed, or [12 months] after your last response if the file becomes inactive

Invoices and payment records

6 years, as required for tax and accounting records

Website and analytics data

As set in our analytics tool, no longer than [26 months]

When information is no longer needed, we securely destroy, erase or anonymize it. We may keep information longer where needed to resolve a dispute or meet a legal obligation.

11. Accuracy, Access and Correction

You are responsible for giving us accurate information and telling us when it changes. We take reasonable steps to keep information accurate and complete for its purpose.

12. Your Privacy Rights

Subject to legal exceptions, you may ask to:
  • know what personal information we hold about you and how it has been used and disclosed;
  • see and receive a copy of it;
  • have inaccurate or incomplete information corrected;
  • withdraw consent for certain uses or disclosures;
  • ask us to delete information we no longer need; and
  • ask questions or raise a concern about our privacy practices.
We may need to verify your identity first. We respond to access requests within 30 days, as PIPEDA requires, or tell you if we need an extension and why. Some information may be withheld where the law allows (for example, third-party privacy or legal privilege), and we will explain why. Records held by the RCMP, FBI or another authority must be requested from that authority under its own access process.

13. Privacy Incidents and Complaints

If you believe your information has been lost, accessed or disclosed without authorization, contact our Privacy Officer right away. We will contain and assess the incident, reduce harm, and keep a record of it. Where a breach creates a real risk of significant harm, we will report it to the Office of the Privacy Commissioner of Canada and notify affected individuals as required (see the OPC guidance on breach reporting). If you are not satisfied with our response, you may complain to the Office of the Privacy Commissioner of Canada.

14. Third-Party Websites

Our website links to third-party sites, government portals, booking and payment providers. They have their own privacy practices, which we do not control. Please read their policies before giving them your information.

15. Children’s Information

Some services involve applications for or about minors. We collect a minor’s information only with the consent of a parent or legal guardian where required, and only for the service requested. We do not knowingly collect children’s information through the website for any other purpose.

16. Contact Our Privacy Officer

Privacy Officer, Global Background & Waiver Services Inc.
30-6981 Millcreek Drive, Mississauga, Ontario L5N 6B8, Canada
Phone: 647-450-6000
Email: privacy@globalbackground.ca
Please do not email fingerprints, passport copies, criminal record documents or other sensitive files. Use the secure upload method we give you for your file, or bring documents to your appointment.

17. Changes to This Policy

We may update this policy as our services, technology or legal requirements change. The new version is posted on this page with a new “Last Updated” date. If a change materially affects how we use your information, we will give notice or seek consent where the law requires it.

Further information

This policy explains our privacy practices in plain language. It does not replace a specific consent form, service agreement or legal notice for an individual application.