1 Introduction & Regulatory Framework
Imani Immigration Services Ltd. ("we", "us", or "our"), operated under the professional direction of Elnaz Imani, RCIC #R526618, respects the privacy rights of all clients, prospective clients, and website visitors.
As a professional immigration law practice located in Newmarket, Ontario, Canada, our data handling practices are strictly governed by Canadian privacy legislation, including the Personal Information Protection and Electronic Documents Act (PIPEDA), as well as the professional regulatory requirements established by the College of Immigration and Citizenship Consultants (CICC).
2 CICC Professional Duty of Confidentiality
Section 28 — Code of Professional Conduct for College of Immigration Consultants
Pursuant to Section 28 of the CICC Code of Professional Conduct, a Regulated Canadian Immigration Consultant (RCIC) owes a strict duty of confidentiality to every client and prospective client. An RCIC shall keep confidential all information concerning the business and affairs of a client acquired in the course of the professional relationship and shall not disclose such information unless expressly authorized by the client or required by law.
This duty of confidentiality begins at the moment of initial contact or consultation (whether in-person, by phone, or electronically) and continues indefinitely, surviving the completion or termination of our legal services contract.
3 Information We Collect
To assess your eligibility, provide accurate legal advice, and represent your applications before Canadian immigration authorities, we collect personal and sensitive information, which may include:
3.1 Sensitive Personal Information
Certain categories of information we collect — including medical examination results, police clearance certificates, and information relevant to criminal or medical inadmissibility — are treated as sensitive personal information and receive heightened safeguards:
Explicit Consent Required
We obtain your explicit, informed consent before collecting or using medical, criminal, or biometric information, separate from general consent to our services.
Restricted Internal Access
Sensitive information is accessible only to Elnaz Imani, RCIC, and authorized staff directly involved in preparing your application. It is not shared internally beyond what is necessary for your file.
Enhanced Security Measures
Sensitive documents are stored with additional access controls beyond our standard file security, and are transmitted only through secure, encrypted channels.
4 Purpose & Use of Personal Data
We collect and process your personal information exclusively for lawful legal representation and professional services, including:
IRCC Application Representation
Preparing and submitting visa, PR, citizenship, and permit applications to Immigration, Refugees and Citizenship Canada (IRCC).
Provincial & Federal Bodies
Communicating on your behalf with the Ontario Immigrant Nominee Program (OINP), ESDC (for LMIA applications), CBSA, and IRB.
Notary & Commissioning
Executing statutory declarations, affidavits, and certifying true copies under Ontario Commissioner of Oaths authority.
Practice Administration
Scheduling consultations, processing client payments, delivering legal updates, and issuing retainer documentation.
5 Third-Party Disclosures & Authorizations
We do NOT sell, rent, trade, or share your personal information with third-party marketing companies. Disclosure of your personal information occurs strictly in the following authorized scenarios:
5.1 Cross-Border Data Storage & Transfer
Some of our technology infrastructure operates on servers located outside Canada. We distinguish between two categories of data handling:
Client File Data
Personal and case information you provide as a client or prospective client is processed and stored using infrastructure that prioritizes Canadian data residency wherever available. Where a service provider operates servers outside Canada — such as in the United States (e.g., for scheduling, email, or cloud storage) — we select providers that maintain comparable security safeguards and, where applicable, contractual data protection commitments.
Public Content & News Updates
Our website's immigration news and updates section uses automated tools, including AI language processing services that may operate on servers outside Canada, to summarize publicly available government and third-party immigration news. These tools only ever process publicly available news content — never client files, personal information, or case data.
If you have questions about where your specific information is stored, contact our Privacy Officer (Section 10).
6 Mandatory 7-Year Statutory Record Retention
CICC Regulation — Retainer & File Storage Mandate
Pursuant to Section 31 of the CICC Code of Professional Conduct, an RCIC must retain all client files, accounting records, retainer agreements, and client communications for a minimum period of seven (7) years following the closing of the file or completion of representation.
Upon expiration of the 7-year statutory retention period, physical records are securely destroyed via cross-cut shredding, and digital records are permanently deleted from secure servers in compliance with PIPEDA standards.
7 Cookies & Website Analytics
Our website (elnazimani.com) uses the following categories of cookies and tracking technologies:
| Category | Purpose | Examples |
|---|---|---|
| Essential | Required for core site functionality, including consultation scheduling | Session cookies, security tokens |
| Analytics | Understand anonymized website traffic patterns and page performance | Cloudflare Web Analytics |
You may configure your browser to decline non-essential cookies at any time. Declining essential cookies may limit consultation scheduling functionality.
7.1 Children's & Dependants' Information
As part of sponsorship and family-class applications, we may collect personal information about dependent children, including minors. This information is:
- Collected only with the consent of the child's parent or legal guardian, as part of an active retainer for sponsorship or family-class representation
- Used exclusively for the immigration application(s) for which it was provided
- Subject to the same confidentiality and security protections as all other client information
A parent or legal guardian may contact our Privacy Officer to review or request correction of a dependant's information at any time, subject to the retention requirements described in Section 6.
8 Your Rights Under PIPEDA
Under Canadian federal privacy legislation (PIPEDA), you possess the following rights regarding your personal information:
- Right of Access: You have the right to request access to the personal information we hold about you.
- Right of Rectification: You may request corrections to any inaccurate, outdated, or incomplete personal data.
- Right to Withdraw Consent: You may withdraw your consent for data processing at any time, subject to legal, statutory, or retainer requirements (note: withdrawal of consent during an active IRCC application may necessitate termination of legal representation).
- Right to Request Deletion: You may request deletion of your personal information. Requests will be honored except where retention is required by law or professional regulation — for example, the 7-year client file retention mandated by CICC (Section 6).
9 Data Breach Response
In the event of a breach of security safeguards involving your personal information that poses a real risk of significant harm, we will:
- Notify the Office of the Privacy Commissioner of Canada (OPC), as required under PIPEDA's Breach of Security Safeguards Regulations
- Notify affected individuals as soon as feasible, describing the nature of the breach and steps taken in response
- Maintain a record of all breaches, regardless of risk level, for a minimum of 24 months, as required by law
If you believe your data has been compromised
Contact us immediately at contact@elnazimani.com or by phone at (647) 685-3875 so we can investigate and respond promptly.
10 Contact Our Privacy Officer & Regulatory Bodies
If you have questions, concerns, or requests regarding this Privacy Policy or our data management practices, please contact our Privacy Officer:
Practice Privacy Officer
Elnaz Imani, RCIC #R526618
Imani Immigration Services Ltd.
16775 Yonge St, Unit 216C, Newmarket, ON L3Y 8J4
Phone: (647) 685-3875
Email: contact@elnazimani.com
Professional Regulatory Body
College of Immigration and Citizenship Consultants (CICC)
5500 Explorer Drive, Suite 400, Mississauga, ON L4W 5C4
Website: college-ic.ca
Toll-Free: 1-877-836-7095
Office of the Privacy Commissioner
Office of the Privacy Commissioner of Canada
30 Victoria Street, Gatineau, QC K1A 1H3
Website: priv.gc.ca
Toll-Free: 1-800-282-1376
Contact the OPC if a privacy complaint cannot be resolved directly with us.