Privacy Policy

GPS Monitoring Services
Recovery Science Corporation
Service Provider to Ontario Ministry of the Solicitor General
Effective Date: 10 February 2026

1. Introduction

Recovery Science Corporation (“we,” “our,” or “us”) provides GPS monitoring services under contract to the Ontario Ministry of the Solicitor General (“the Ministry”). We are committed to protecting the privacy and security of personal information in accordance with the Freedom of Information and Protection of Privacy Act (“FIPPA”).

This Privacy Policy explains how we collect, use, disclose, retain, and safeguard personal information in the course of providing GPS monitoring services for law enforcement and correctional purposes.

2. Scope and Application

This Privacy Policy applies to all personal information collected, used, and disclosed by Recovery Science Corporation in the provision of GPS monitoring services on behalf of the Ministry of the Solicitor General.

As a service provider to the Government of Ontario, we act under the authority of the Ministry. The Ministry remains the institution responsible for the personal information under FIPPA. All personal information we collect and use is subject to FIPPA and the access and privacy rights provided under that Act.

3. Definitions

Personal Information means recorded information about an identifiable individual, including but not limited to name, identification numbers, contact information, location data, photographs, and any other information that can be used to identify an individual.

FIPPA means the Freedom of Information and Protection of Privacy Act, R.S.O. 1990, c. F.31, which governs the collection, use, and disclosure of personal information by Ontario government institutions and their service providers.

GPS Monitoring means the electronic monitoring of an individual’s location through Global Positioning System technology as required by a legal authority.

Monitored Individual means a person who is subject to GPS monitoring pursuant to a court order, parole certificate, or temporary absence permit.

Law Enforcement means activities related to policing, investigations, proceedings that lead to or could lead to a penalty or sanction, or activities related to the administration of justice, as defined in FIPPA.

4. Our Role as Service Provider

Recovery Science Corporation operates as a service provider to the Ministry of the Solicitor General under FIPPA. In this capacity:

  • The Ministry remains the government institution responsible for the personal information;
  • We collect, use, and disclose personal information only as authorized under FIPPA and our service agreement with the Ministry;
  • We process personal information for law enforcement purposes as permitted by FIPPA;
  • We comply with all FIPPA requirements and contractual obligations regarding privacy and data protection; and
  • We do not use personal information for any purpose other than providing GPS monitoring services as contracted

5. Legal Authority for Collection

We collect personal information under the following legal authorities:

5.1 Statutory and Judicial Authority

  • Our collection of personal information is authorized by the document imposing the GPS monitoring requirement on the Monitored Individual as a condition of their liberty, including, as the case may be:
  • a court order requiring GPS monitoring as a condition of judicial interim release (bail) under the Criminal Code of Canada;
  • a court order requiring GPS monitoring as a condition of a conditional sentence order under the Criminal Code of Canada;
  • a parole certificate issued by the Ontario Parole Board requiring GPS monitoring under the Ministry of Correctional Services Act; or
  • a temporary absence permit issued by an Ontario correctional institution requiring GPS monitoring under the Ministry of Correctional Services Act.

5.2 Law Enforcement Purpose under FIPPA

Our collection of personal information is also authorized under section 39(1)(g) of FIPPA for the purpose of law enforcement, which section 2(1) of FIPPA defines as:

(a)  policing;
(b)  investigations or inspections that lead or could lead to proceedings in a court or tribunal if a penalty or sanction could be imposed in those proceedings; or
(c)  the conduct of proceedings referred to in clause (b).

6. Information We Collect

We collect personal information necessary to provide GPS monitoring services in fulfillment of our contractual obligations to the Ministry and to carry out the purposes of the authority imposing the monitoring requirement on the Monitored Individual. The types of information collected include:

6.1 Identifying Information

  • Full legal name;
  • Date of birth;
  • Photographic and/or video images;
  • Physical descriptors;
  • Identification numbers (e.g., correctional file numbers, case numbers); and
  • Identification documents used to verify identity

6.2 Contact Information

  • Residential address;
  • Telephone numbers;
  • Email addresses (if provided); and
  • Alternative contact information.

6.3 Legal Documentation

  • Court orders (bail orders, conditional sentence orders);
  • Parole certificates;
  • Temporary absence permits;
  • Terms and conditions of release or monitoring; and
  • Information about charges, convictions, or correctional status (as relevant to monitoring requirements)

6.4 GPS Monitoring Data

  • location data;
  • Historical location data and movement patterns;
  • Equipment status information (battery level, AC plug-in and unplug events, signal strength);
  • Tamper alerts and equipment integrity data;
  • Zone and schedule violations and boundary breach notifications; and
  • Date and time stamps for all location and equipment data

6.5 Case Management Information

  • Information provided by probation and parole officers, correctional staff, or court officials;
  • Communications with monitored individuals, sureties, or legal representatives
  • Compliance records and violation reports;
  • Service delivery notes and incident documentation; and
  • Information received from law enforcement or correctional authorities

6.6 Surety and Third-Party Information

In bail cases, we may collect limited personal information about sureties, including contact information, communications and images submitted by the surety to verify compliance with a surety-accompaniment requirement, and other communications regarding the monitored individual’s compliance with conditions.

7. How We Use Personal Information

We use personal information solely for the purposes of providing GPS monitoring services to the Ministry of the Solicitor General and for law enforcement purposes authorized under FIPPA. Specific uses include:

  • Monitoring the real-time and historical location of individuals subject to GPS monitoring;
  • Verifying compliance with court-ordered conditions, parole requirements, or temporary absence conditions;
  • Detecting and documenting violations of monitored conditions;
  • Generating alerts and notifications regarding zone violations, equipment tampering, or other compliance issues;
  • Providing reports and information to the Ministry, courts, law enforcement, probation and parole officers, and correctional institutions;
  • Communicating with monitored individuals, sureties, and authorized contacts regarding monitoring requirements and equipment;
  • Maintaining monitoring equipment and ensuring system functionality;
  • Supporting investigations and legal proceedings;
  • Maintaining records as required by law and our contractual obligations; and
  • Fulfilling all obligations under our service agreement with the Ministry.

8. Disclosure of Personal Information

Personal information is disclosed only as authorized under FIPPA, our service agreement with the Ministry, and as required by law.

8.1 Disclosure to Government Institutions

We disclose personal information to the following government institutions and agencies as necessary for law enforcement purposes:

  • Ministry of the Solicitor General;
  • Ontario correctional institutions;
  • Probation and parole officers; and
  • Other Ontario government ministries or agencies as authorized under FIPPA

8.2 Disclosure to Law Enforcement

Pursuant to section 42(1)(g) of FIPPA for the purpose of law enforcement, we disclose personal, including real-time and historical location data, to law enforcement agencies, including police services (municipal, provincial, and federal) and correctional authorities, for their use in:

  • Verifying compliance or investigating suspected non-compliance with release conditions;
  • Responding to emergencies or threats to public safety or to the administration of justice; and/or
  • Ongoing criminal investigations or proceedings.

8.3 Disclosure to Courts and Crown Attorneys

We disclose personal information to courts and Crown Attorneys as necessary for:

  • Bail compliance proceedings;
  • Breach hearings;
  • Sentencing proceedings;
  • Other judicial proceedings where monitoring information is relevant; and
  • Responding to court orders or subpoenas.

8.4 Disclosure to Service Providers

We may disclose personal information to third-party service providers who assist in the provision of GPS monitoring services, including:

  • Technology platform and cloud service providers;
  • GPS equipment manufacturers and maintenance providers;
  • Data storage and backup service providers; and
  • IT infrastructure and security providers.

All service providers are contractually required to:

  • Comply with FIPPA and applicable privacy laws;
  • Use personal information only for authorized purposes;
  • Implement appropriate security safeguards; and
  • Return or securely destroy personal information upon termination of services.

8.5 Other Disclosures

We may also disclose personal information:

  • As required or authorized by law;
  • With the consent of the individual;
  • For compelling circumstances affecting the health or safety of an individual, as permitted under section 42(1)(h) of FIPPA; and
  • As otherwise permitted under FIPPA.

9. Data Location and Storage

9.1 Storage Location

All personal information, including GPS location data, is stored in Canada in accordance with our contractual obligations to the Ministry. We use secure data centres and cloud infrastructure located within Canadian jurisdiction.

9.2 Third-Party Service Providers

We engage third-party technology and cloud service providers to support our GPS monitoring operations. All such providers are contractually required to:

  • Store data within Canada or as otherwise approved by the Ministry;
  • Comply with FIPPA and applicable Canadian privacy laws;
  • Implement security measures consistent with or exceeding our standards; and
  • Provide notification regarding any foreign access requests or legal obligations that may affect Canadian data.

10. Data Retention and Disposition

Personal information is retained in accordance with:

  • Government-approved retention schedules;
  • Our contractual obligations to the Ministry; and
  • Applicable legal and regulatory requirements.

GPS monitoring data, case files, and related personal information are retained for the duration of the monitoring period and for such additional period as required by law, court order, or Ministry direction. Upon expiry of the retention period, or upon termination of our service agreement with the Ministry, we return or securely dispose of all personal information as directed by the Ministry, unless otherwise required by law.

Secure disposal methods include physical destruction of hardware, cryptographic erasure, and certified data destruction in accordance with industry standards and government requirements.

11. Security Safeguards

We implement comprehensive administrative, technical, and physical security measures to protect personal information against unauthorized access, collection, use, disclosure, copying, modification, disposal, or destruction. These measures are proportionate to the sensitivity of GPS monitoring data and law enforcement information and are designed to meet our obligations under FIPPA and our service agreement with the Ministry.

Our security safeguards include administrative controls such as privacy and security policies, employee confidentiality agreements, training programs, and incident response procedures. Technical safeguards include measures to protect data in transit and at rest, access controls, network security, and system monitoring. Physical safeguards include secure facilities with controlled access and secure disposal procedures for records and equipment.

We require third-party service providers, including our GPS monitoring equipment supplier, cloud service providers, and application vendors, to implement security measures consistent with our obligations under FIPPA and our contractual requirements.

Our security measures meet or exceed the requirements specified in our service agreement with the Ministry and are regularly reviewed and updated to address evolving threats and technological changes.

12. Privacy Breach Management

We maintain comprehensive procedures for preventing, detecting, and responding to privacy breaches involving personal information.

12.1 Breach Prevention and Detection

We maintain ongoing measures to prevent and detect privacy breaches, including security monitoring, regular assessments, employee training, and procedures to identify and respond to potential security incidents.

12.2 Breach Response

In the event of a privacy breach:

  • We immediately notify the Ministry of the Solicitor General as required by our service agreement;
  • We implement immediate containment measures to prevent further unauthorized access or disclosure;
  • We conduct a thorough investigation to determine the scope and cause of the breach;
  • We cooperate fully with the Ministry’s breach investigation and response;
  • We assist with notification to affected individuals as directed by the Ministry;
  • We report to the Information and Privacy Commissioner of Ontario as required;
  • We implement remediation measures to prevent recurrence; and
  • We document all breach-related activities and provide reports to the Ministry.

13. Individual Rights and Access to Information

13.1 Rights Under FIPPA

Individuals have rights under FIPPA with respect to personal information held by government institutions, including:

  • The right to request access to their personal information;
  • The right to request correction of inaccurate or incomplete personal information; and
  • The right to be informed about the collection, use, and disclosure of their personal information.

13.2 How to Make an Access Request

Requests for access to personal information must be directed to the Ministry of the Solicitor General, as the government institution responsible for the information:

Ministry of the Solicitor General

Freedom of Information and Privacy Coordinator
25 Grosvenor Street, Toronto, Ontario M7A 1Y6
FOI.SOLGEN@ontario.ca
705-494-3080

If you contact Recovery Science Corporation regarding access to your personal information, we will redirect your request to the Ministry’s Freedom of Information and Privacy Office.

13.3 Limitations on Access

Access to personal information may be limited or refused under FIPPA where disclosure could:

  • Interfere with law enforcement activities or investigations (section 14 of FIPPA);
  • Reveal investigative techniques or procedures;
  • Endanger the safety of any person;
  • Facilitate the commission of an offence;
  • Prejudice the administration of justice; and
  • Otherwise be exempted under FIPPA.

The Ministry will make determinations regarding access and any applicable exemptions in accordance with FIPPA.

14. Accountability and Governance

Recovery Science Corporation has designated a Privacy Officer responsible for overseeing compliance with this Privacy Policy, FIPPA, and our contractual obligations to the Ministry. Our Privacy Officer:

  • Oversees privacy compliance programs and procedures;
  • Conducts privacy impact assessments for new systems or processes;
  • Manages privacy inquiries and complaints;
  • Provides privacy and security training to employees;
  • Maintains liaison with the Ministry and privacy regulators;
  • Monitors compliance with privacy policies and contractual obligations; and
  • Reports to senior management on privacy matters.

15. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in:

  • Our privacy practices
  • Technology or operational procedures
  • Legal or regulatory requirements
  • Our contractual obligations to the Ministry

Material changes will be communicated through:

  • Posting the updated Privacy Policy on our website
  • Notification to the Ministry of the Solicitor General
  • Other appropriate means as required by our service agreement

16. Contact Information

16.1 Privacy Officer

For questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact:
Recovery Science Corporation
Attention: Privacy Officer
Address: #311, 5-450 Holland Street West, Bradford ON L3Z 0J4
Email: privacy@recoveryscience.ca
Phone: 1-877-595-2573

16.2 Access Requests

For requests to access or correct personal information, please contact the Ministry of the Solicitor General’s Freedom of Information and Privacy Office at the contact information provided in Section 13.2.

17. Filing a Complaint

If you have concerns about how your personal information is being handled under this Privacy Policy or believe that FIPPA has not been complied with, you may file a complaint with:

Information and Privacy Commissioner of Ontario

2 Bloor Street East, Suite 1400
Toronto, Ontario M4W 1A8
Toll-free: 1-800-387-0073
TTY: 416-325-7539
Website: www.ipc.on.ca
Email: info@ipc.on.ca

This Privacy Policy is subject to the provisions of FIPPA and our service agreement with the Ministry of the Solicitor General. In the event of any conflict, FIPPA and the service agreement prevail.