Privacy Policy 

Last Updated January 6, 2026.

P.A. Miller Surveying Ltd. (“PAM”) is committed to protecting your privacy. This policy describes how we handle and safeguard your personal information as defined under the Federal Personal Information Protection and Electronic Documents Act (PIPEDA) and in compliance with the laws and regulations of Ontario. PIPEDA applies to all private-sector organizations across Canada that collect, use or disclose personal information in the course of a commercial activity. Please note that we DO NOT handle any personal information that crosses international boundaries.

Definition of Personal Information

Under PIPEDA, personal information includes any factual or subjective information, recorded or not, about an identifiable individual. This includes information in any form, such as:
• age, name, ID numbers, income, ethnic origin, or blood type
• opinions, evaluations, comments, social status, or disciplinary actions
• employee files, credit records, loan records, medical records, existence of a dispute between a consumer and a merchant, intentions (for example, to acquire goods or services, or change jobs)

Expressly excluded from the legal definition of personal Information, however, are the name, title, business address and telephone number of an employee of an organization. For further clarity, personal Information does NOT include information that would generally be expected to appear on someone’s business card.

Types of Personal Information

PAM may collect personal Information such as your name, home address, telephone number, personal e-mail address, billing and account information, information about legal issues and other information incidental to providing legal survey advice and our other services.

Consent to Our Collection of Your Personal Information

In most cases, we obtain your consent to our collection, use or disclosure of your Personal Information by your submission of such personal Information to us. If you retain us, we will assume that we have your implied consent to our collection, use and legally authorized disclosure of your personal Information; however, at times we may ask for your express consent, either verbally or in writing. Generally, we will collect your personal information directly from you at the start of, or during the course of, your retainer with us. If you provide us or our service providers and agents with personal information of another individual, you represent that you have all necessary authority and/or have obtained all necessary consents from such person to enable us to collect, use and disclose such personal information for the purposes set forth in this Privacy Policy.

Sometimes we may obtain personal information about you from other sources, such as government registry (e.g. Land Registry Office parcel registered) or other professionals who serve you.

We will not collect, use or disclose personal information without consent of the individual to whom the information relates unless we are permitted or required to do so by applicable law. It may not be necessary to obtain consent of the individual in particular circumstances, such as where consent has been obtained by the individual providing us with the information (as described above), obtaining consent would be impossible or impractical (e.g. that of a deceased individual), or where obtaining consent would substantially interfere with or frustrate the reason for collection.

Collection & Retention

When collecting personal Information, we will endeavor to limit our collection to what is reasonably necessary for the purposes of collection. We will limit our use and/or disclosure of personal Information to the purposes for which it was collected, as the individual may otherwise consent, or as otherwise may be permitted or required by law.

We are mandated under Section 6 of Regulation 216/10 of the Surveyors Act of Ontario to “retain properly indexed records of all professional services provided to the public, including projects, and all pertinent information necessary to reconstruct the details of the projects.” Section 6 (2) of the regulation is as follows:
(2) the professional member shall retain and maintain records in a secure manner and in accordance with,
(a) the Surveys Act for records prepared for cadastral surveys; and
(b) the Limitations Act, 2002 for all other records.

This among other things includes personal information that is embedded in title search documents, contractual information, correspondence with clients and related parties in support of the project and site photographs.
For long term storage of projects files, we only retain in the file what is required under the above requirements in both hardcopy format and digital format.

Usage of Clients Personal Information by PAM

If you contract with us for our services, we collect and use your personal information to provide these services to you (e.g. Survey Reports, Plans of Survey, etc.), to keep our client database updated to facilitate professional purposes in association with our lawful and ethical code of conduct as mandated by the Association of Ontario Land Surveyors (“AOLS”) and submit invoices for services rendered. Without limiting the foregoing, in the provision of these services, we may disclose your personal information to third parties such as a professional Title Searcher, and other as detailed under the heading Disclosure of Personal Information by PAM.

Usage of Others Personal Information by PAM

We also collect personal Information about prospective and current employees, contractors and partners that is reasonably required to establish, manage or terminate an employment, contractual or partnership relationship. If you are a current or former employee or partner of PAM, we may maintain your personal Information and your contact details and employment status and history. We will disclose personal Information to regulatory, self-regulatory and governmental authorities who exercise oversight and monitoring activities relating to our practice in certain instances where the disclosure or collection of personal information is required to be shared with any such bodies in accordance with governing regulations and laws.

Disclosure of Personal Information by PAM

We will not collect or disclose your personal information to third parties except in accordance with this policy unless required by law. There are certain circumstances where we may disclose your personal information such as:
– we have contracted with a 3rd party to scan the contents of project files as part of our archival process, and in this instance, we will only do so if permitted by law and we will be certain to use contractual obligations or other means to ensure the 3rd party provider is bound by obligations regarding privacy which are consistent with this policy;
– we at times retain other professionals, including without limitation, other Ontario Land Surveyors, professional engineers, professional researchers to provide services on your behalf;
– we have contracted with a 3rd party IT company to maintain our data server, keep firewalls UpToDate and backup our data in accordance with their privacy policy and ours;
– a legal obligation to disclose such information (e.g. to the AOLS or government that has lawful authority).

Privacy Safety Measures

PAM uses various safeguards to ensure that your personal information is protected against theft, misuse, loss, unauthorized access, disclosure and copying. These safety measures include: the physical security of our offices, passwords for access to all PC terminals, up-to-date security software and firewalls to prevent unauthorized access and staff training to limit exposure to cyber threats. Our 3rd party IT professional encrypts our backup data and any access to this data by them requires complex passwords and multifactor (MFA) authentication. Access to this backup data is restricted on their end. Our firm also has in place a cyber security insurance policy.

Compliance Inquires

PAM will investigate any non-compliance inquiries received and respond within the period prescribed by applicable law. If a complaint is found to be justified PAM will take action to resolve the issue in accordance with applicable law. If you are not satisfied with our response, you may contact the Office of the Privacy Commissioner of Canada (OPC) (Toll-free 1-800-282-1376).