SF Partnership, LLP (“SF”) recognizes the importance of privacy and the sensitivity of personal information. As accountants we have a professional obligation to keep confidential all information we receive within an accountant-client relationship. We are committed to protecting any personal information we hold. This Privacy Policy outlines how we manage your personal information and safeguard your privacy.
Your Privacy Rights
From January 1, 2004, all businesses engaged in commercial activities must comply with the Personal Information Protection and Electronic Documents Act (“Act”) and the Canadian Standards Association Model Code for the Protection of Personal Information, which it incorporates. These obligations extend to accountants and accounting firms, including SF. The Act gives you rights concerning the privacy of your personal information.
SF is responsible and accountable for the personal information we collect and hold. To meet our obligations to our clients, we have developed this policy, and informed our accountants and support staff about our policies and practices.
Why does SF Need Personal Information?
SF provides accounting services and products to a wide range of clients. In doing so, it produces direct marketing materials concerning its services and developments in the law. We will not as a condition of providing you with accounting services and products, require you to consent to the collection, use or disclosure of personal information beyond which is necessary.
What Personal Information Do We Collect?
Personal information is any information that identifies you, or by which your identity could be deduced. Examples of the information we collect include:
• Name
• Address
• Phone Number
Financial Information to Determine Credit Worthiness
If we did not collect and use your personal information we could not provide you with accounting services.
How Do We Collect Your Personal Information?
We collect information only by lawful and fair means and not in an unreasonably intrusive way. Wherever possible we collect your personal information directly from you, at the start of an engagement and in the course of our representation.
Sometimes we may obtain information about you from other sources, for example:
• Your insurance company
• Your real estate agent in a property transaction
• From a Government agency or registry
• Your employer, if we are acting for you, at its request;
• Your lawyer
Consent
In most cases, we shall ask you to specifically consent, if we collect, use, or disclose your personal information. Normally, we ask for your consent in writing, but in some circumstances, we may accept your oral consent in writing. Sometimes, your consent may be implied through your conduct with us.
Use of Your Information
We use your personal information to provide accounting advice and services to you, to administer our client time and billing databases and to include you in any direct marketing activities.
SF does not disclose your personal information to any third party to enable them to market their products and services. For example, we do not provide our client mailing lists to law firms.
Disclosure of Your Personal Information
Under certain circumstances, SF will disclose your personal information. These circumstances include:
• When we are required or authorized by law to do so, for example if a court issues a subpoena;
• When you have consented to the disclosure;
• When the accounting services we are providing to you requires us to give your information to third parties (for example, Canada Customs and Revenue Agency (“CCRA”) in a dispute negotiation) your consent will be implied, unless you tell us otherwise;
• Where it is necessary to establish or collect fees;
• If we engage a third party to provide administrative services to us (like computer back-up services or archival file storage) and the third party is bound by our privacy policy;
· If we retain other law firms or accounting firms on your behalf;
If the information is already publicly know.
Updating Your Information
Since we use your personal information to provide accounting services to you, it is important that the information be accurate and up-to-date.
If during the course of the retainer, any of your information changes, please inform us so that we can make any necessary changes.
Is My Personal Information Secure?
SF takes all reasonable precautions to ensure that your personal information is kept safe form loss, unauthorized access, modification or disclosure. Among the steps taken to protect your information are:
• Premises security;
• Restricted file access to personal information;
• Deploying technological safeguards like security software and firewalls to prevent hacking or unauthorized computer access;
Internal password and security policies.
Access To Your Personal Information
You may ask for access to any personal information we hold about you. Summary information is available upon request. More detailed requests, which require archive or other retrieval costs, may be subject to our normal professional and disbursement fees.
Correcting Errors
If SF holds information about you and you can establish that it is not accurate, complete and up-to-date, SF will take reasonable steps to correct it.
Can I Be Denied Access To My Personal Information?
Your rights to access your personal information are not absolute.
We may deny access when:
• Denial of access is required or authorized by law (for example, when a record containing personal information about you is subject to claim a legal professional privilege by one of our clients);
• Information relates to existing or anticipated legal proceedings against you;
• When granting you access would have an unreasonable impact on other people’s privacy;
• When to do so would prejudice negotiations with you;
To protect our firm’s rights and property.
If we deny your request for access to, or refuse a request to correct information, we shall explain why.
SF does not use your Social Insurance Number (“SIN”) as a way of identifying or organizing the information we hold about you.
Can I Request Anonymity?
Whenever it is legal and practicable, we may offer the opportunity to deal with general inquiries without providing your name (for example, by accessing general information on our web site). The Proceeds of Crime (Money Laundering) and Terrorist Financing Act requires us to confirm the identity of all new clients. If may also require us to disclose information in relation to certain large cash transactions.
Credit Bureaus
To help us make credit decisions about clients, prevent fraud, check the identity of new clients and prevent money-laundering, we may on occasion request information about you from the files of consumer reporting agencies.
Communicating With Us It is important to remember that whatever you transmit or disclose online can be collected and used by others or unlawfully intercepted by third parties. No data transmission over the Internet can be guaranteed to be 100% secure. While we strive to protect your personal information, we cannot warrant the security of any information you transmit to us over the Internet.
Changes To This Privacy Policy
Since SF regularly reviews all of its policies and procedures, we may change our Privacy Policy from time to time.
Requests For Access
If you have any questions, or wish to access, add, amend or remove your personal information, or if you no longer wish to receive any information about our services, please inform us in writing at:
Privacy officer
SF Partnership, LLP
400-4950 Yonge Street
Toronto, ON
M2N 6P6
If for any reason you are not satisfied with the results of our investigations in response to your complaint, you may file a complaint with the Officer of Federal Privacy Commissioner at:
112 Kent Street
Ottawa, ON
K1A 1H3
1-800-282-1376
Employment Inquires
If you apply to SF for a job, we need to consider your personal information as part of our review process. We normally retain information from candidates after a decision has been made, unless you ask us not to retain the information. If we offer you a job, which you accept, the information will be retained in accordance with our Privacy Procedure for employee records.
Web Site
On our web site, like most other commercial web sites, we may monitor traffic patterns, site usage and related site information in order to optimize our web service. We may provide aggregated information to third parties, but these statistics do not include any identifiable personal information.
Should you have any questions, please do not hesitate to contact us.
Yours truly,
SF Partnership, LLP
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