1. 1
Form P1006revisedMay 1st, 2014
MMPR SecurityServicesLtd.
PolicyonPublicComplaints
MMPR Security Services Ltd.
When Minutes Matter…
Public Complaints Policy
Document Status: Draft / Final Status upon approval from Solicitor General
Date Issued: May 1st, 2014
Lead Author: Kevin Oulette – Director
Approved by: MMPR Security Services Ltd.
Date for Review: May 1st, 2015
Record of Policy Review: Kevin Oulette - Director
Date Policy
was Issued
Date of Review Reason for Review Lead
Reviewer
Additional Comments
May 1st, 2014
Solicitor General
Approval
First Draft – Opening Document
Kevin
Oulette
Submitted
for approval
2. 2
Form P1006revisedMay 1st, 2014
MMPR SecurityServicesLtd.
PolicyonPublicComplaints
Table of Contents – Public Complaint Policy
1.0 Public Complaints Requiring Investigation………………………………….....Page 3
2.0 Public Complaints Policy…………........................................................Page 4
3.0 Criminal Matters…………………………………………………………………………….Page 4
4.0 Complaints not requiring investigation …………………………………….Page 4 &5
5.0 Notificationthat investigationwill not proceed ……………………………..Page5
6.0 Anonymous complaints ………………………………………………………………….Page5
7.0 Informal resolutions of complaints …………………………………………………Page5
Complaints Coordinator, Fax: 780-427-4670
Security Programs Justice and Solicitor General
9th Floor, 10365-97 Street Edmonton AB T5J 3W7
Fax: 780-427-4670
3. 3
Form P1006revisedMay 1st, 2014
MMPR SecurityServicesLtd.
PolicyonPublicComplaints
Functions and Delegations As per sections 24, 25, 26 and 27 of the Security Services and
InvestigatorsAct(the Act),if apubliccomplaintisreceivedaboutanemployee licensedunderthe Act, the
following process will be followed:
Thispolicyonlyappliestoindividualsdirectlyemployedbythecompanyanddoesnotapplytothe licensed
employeesof contractserviceproviders. Forthe purposesof thissection,Registrarreferstothe Registrar,
Security Services and Investigators Act, Alberta Justice and Solicitor General.
1.0 PUBLIC COMPLAINTS REQUIRING INVESTIGATION
Complaintsagainstindividual licenseesmustbe madeinwritingtothe licensee’s employerwithin90days
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 necessarysteps to have the complaint recorded in writing on behalf of the complainant.
“The complainant must sign the written complaint”
1.1 Within30 daysof receivingthe complaintthe employermustacknowledge receipt,in writing,to
the complainant (as per section 26 of the Security Services and Investigators Ministerial
Regulation).
1.2 In acknowledgingthe complaint,the employermustnotifythe licensedemployeewhois subject
of the complaint. The employer may delay notification to the employee under the following
circumstances. Inthe case where itis uncertainasto the appropriatenessof informingalicensee
about a complaint, the Registrar, should be consulted.
a. The complainant may be placed in danger.
b. The complainant may face other inappropriate action by the licensed employee should
the licensed employee be informed.
c. The notificationmayimpedethe gatheringof evidenceduringaninternal investigation.
d. 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.
e. Anyothersituationidentifiedbythe employerorRegistrarinwhichitmaybe appropriate
to delay informing the licensed employee about the complaint.
1.3 The employer must, within 90 days,
a. Investigate and dispose of the complaint (unless 3.0 below applies), and
b. Notify the complainant,the licensed employee whois the subject of the complaint, and
the Registrar(use PublicComplaintOutcome FormPS3749),in writing,of the disposition
of the complaint with reasons.
1.4 All allegations or concerns will be handled by Kevin Oulette, the Director/owner of
MMPR Security Services Ltd.
4. 4
Form P1006revisedMay 1st, 2014
MMPR SecurityServicesLtd.
PolicyonPublicComplaints
2.0 Public Complaints Policy – Complaints against Individual Licensees
The letterof disposition mustadvisethe complainantof theirrighttorequesta review of the
outcome bythe Registrar.The lettermustindicate the following:
a. If dissatisfiedwiththe outcomeof the company’sinvestigationthe complaintmayrequest
a review of the disposition by the Registrar.
b. The request must be made in writing within 30 days of receipt of the disposition.
c. Requests for review must be submitted to:
Complaints Coordinator, Security Programs
Justice and Solicitor General
9th Floor, 10365-97 Street
Edmonton AB T5J 3W7
Fax: 780-427-4670
3.0 CRIMINAL MATTERS
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.
3.1 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:
a. Notified the police service of the allegation, and
b. Provided written notification to the complainant, and
c. Provided written notification to the Registrar that this action has occurred.
3.2 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 investigationis conducted it must be
completedwithin90 days as per section25(4) of the Act and the outcome report as per section
1.0 of this policy.
3.3 All allegations or concerns will be handled by Kevin Oulette/Director/owner of MMPR Security
Services Ltd.
Public Complaints Policy – Complaints against Individual Licensees
4.0 COMPLAINTS NOT REQUIRING INVESTIGATION
The Act recognizes that some complaints will be made under circumstancesin which an investigationis
not required.
4.1 Under the following conditions, the company may choose not to investigate a complaint
a. Employer utilizes an informal resolution process (see 3.4.1 below).
b. Employee no longer works for the employer.
c. Contact with complainant after submission of initial complaint cannot be made
(Documentation showingthisisthe case shouldbe keptin case of requestfor reviewby
the Registrar).
d. Anonymous complaints.
e. Frivolous: a complaint intended merely to harass or embarrass.
5. 5
Form P1006revisedMay 1st, 2014
MMPR SecurityServicesLtd.
PolicyonPublicComplaints
f. Vexatious: a complaint that has no basis in fact or reason, with its purpose to bother,
annoy, and embarrass the individual or business licensee.
g. Bad Faith: filing a complaint with intentional dishonesty or with intent to mislead.
h. Havingregard of all the circumstances,noinvestigation,inthe optionof the Employeror
Registrar, is deemed necessary.
5.0 Notification that investigation will not proceed
The employermustnotifythe complainantwithin90days of receiptof the complaintthatthe matterwill
not be investigated,exceptwhere aninformal resolutionprocessis undertaken,the complainantcannot
be contacted or the complaint is anonymous.
5.1 The lettermust advise the complainantof their rightto requesta review of the outcome by the
Registrar. The letter must indicate the following:
a. If dissatisfiedwiththe outcomeof the company’sinvestigationthe complaintmayrequest
a review of the disposition by the Registrar.
b. The request must be made in writing within 30 days of receipt of the disposition.
Requests for review must be submitted to:
Complaints Coordinator, Fax: 780-427-4670
Security Programs Justice and Solicitor General
9th Floor, 10365-97 Street Edmonton AB T5J 3W7
Fax: 780-427-4670
6.0 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
anonymouscomplaintisserious,the employershall review the matter andconsiderwhat,if any further
actionshouldorcan be taken.Inthe eventsome elementof substance tothe allegationisuncovered,the
employer must:
6.1 Within90days, Investigateanddisposeof the complaint,andNotifythe Registrarinwriting(use Public
Complaint Outcome Form PS3749), of the disposition of the complaint with reasons. Public Complaints
Policy – Complaints against Individual Licensees May 30, 2012 4
7.0 Informal resolutions of complaints
a. Successful informal resolution allows an investigation to be discontinued. If, in the employer’s
opinionandhavingregardto all of the circumstances,noinvestigationis necessary,the employer
may discontinue the investigation.
b. Upon successful resolution of complaint, document outcome and obtain the complainant’s
signature, where possible, to show that a matter has been informally resolved.
c. This would preclude the complainant from claiming duress or that they did not agree with the
outcome.Withoutcleardocumentation,complaintsthatare informallyresolvedbythe employer
may,in some circumstances,be eligible for review bythe Registrarandsubsequentlythe Director
of Law Enforcement, Province of Alberta.
d. Informal Complaints will be handled and documented by Kevin Oulette/director/owner
e. All allegations will be investigated to see if possible allegation has occurred.
6. 6
Form P1006revisedMay 1st, 2014
MMPR SecurityServicesLtd.
PolicyonPublicComplaints
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