The firm is accountable for personal information in its possession or control
- The firm is accountable for all personal information in its possession or control. This includes any personal information that the firm received directly from clients who are individuals, or indirectly, through clients that are organizations (e.g., corporations, government entities, not-for-profit organizations).
- The firm has:
- established and put into effect policies aimed at properly protecting personal information;
- appointed its Chief Privacy Officer to oversee privacy issues at the firm.
The firm identifies the purposes for which it collects personal information from clients before it is collected.
- The firm collects personal information from clients and uses and discloses such information, only to provide the professional services that the client has requested. Each service the firm provides is described in an engagement letter with the client.
- The personal information collected from a client during the course of professional services engagement may be:
- shared with the firm’s personnel participating in such engagement;
- disclosed to partners and employees within the firm to the extent required to assess compliance with applicable professional standards and rules of professional conduct, and the firm’s policies, including providing quality control reviews of work performed;
- disclosed to members of the board of directors, and others in the company that might not otherwise have access to the information, in the course of communicating aspects of the results of our engagement; and
- provided to external professional practice inspectors (e.g. representatives of the Canadian Public Accountability Board, or a provincial institute of chartered accountants), who by law, professional regulation, or contract have the right of access to the firm’s files for inspection purposes.
The firm obtains a client’s consent before collecting personal information from that client.
- Before the firm undertakes a professional services engagement, it requires the prospective client to sign an engagement letter or contract. By signing the engagement letter or contract, the client provides its agreement that proper consents to the collection, use and disclosure of personal information as set out in the letter have been or will be obtained (the consent of the individual is the responsibility of the client not the firm).
The firm collects only that personal information required to perform its professional services and operate its business, and such information is collected by fair and lawful means.
The firm uses or discloses personal information only for purposes for which it has consent, or as required by law. The firm retains personal information only as long as necessary to fulfill those purposes.
- As required by professional standards, rules of professional conduct and regulation, the firm documents the work it performs in records, commonly called working paper files. Such files may include personal information obtained from a client.
- Working paper files and other files containing, for example, copies of personal tax returns are retained for the time period required by law and regulation, including Rules of Professional Conduct.
- The firm regularly and systematically destroys, erases, or makes anonymous personal information no longer required to fulfill the identified collection purposes, and no longer required by laws and regulations.
The firm endeavours to keep accurate, complete, and up-to-date, personal information in its possession or control, to the extent required to meet the purposes for which it was collected.
- Certain customer and other information is used in the course of an engagement and needs to be accurate to be relied upon, as a result, updating the information is encouraged on an annual basis.
The firm protects the privacy of personal information in its possession or control by using security safeguards appropriate to the sensitivity of the information.
- Physical security is maintained over personal information stored in hard copy form. Partners and employees are authorized to access personal information based on client assignment and quality control responsibilities.
- Authentication is used to prevent unauthorized access to personal information stored electronically.
- For files and other materials containing personal information entrusted to a third party service provider (e.g., a provider of paper based or electronic file storage), the firm obtains appropriate assurance to affirm that the level of protection of personal information by the third party is equivalent to that of the firm.
The firm responds on a timely basis to requests from clients about their personal information which the firm possesses or controls.
- Individual clients of the firm have the right to contact the engagement partner in charge of providing services to them and obtain access to their personal information. Similarly, authorized officers or employees of organizations that are clients of the firm have the right to contact the engagement partner in charge of providing service to them and obtain access to personal information provided by that client. In certain situations, however, the firm may not be able to give clients access to all their personal information. The firm will explain the reasons why access must be denied and any recourse the client may have, except where prohibited by law.