This privacy policy explains how we collect, use and disclose personal information provided to us, either electronically or documents and discussions held in the course of operating our business. Personal information is defined in Canada’s Personal Information Protection and Electronic Documents Act (“PIPEDA”).
We take the privacy of our clients seriously. In the course of providing our services to you, we need to collect various information in order to make appropriate recommendations and comply with industry regulations. It is critical in our relationship with our clients and the standards of our profession that this information is protected and only made available to our clients unless our client consents to disclosure of certain information to third parties. Canada’s Personal Information Protection and Electronic Documents Act has identified 10 principals that we use in our privacy policy:
1. Accountability - we are accountable for the information provided to us, appointed individuals to deal with compliance with applicable privacy legislation, and have developed and implemented personal information policies and practices.
2. Identifying purposes – our policy is to inform clients of why information is needed, either before or when it is requested. You are not required to provide any personal information to us and are entitled to have an explanation as to the purpose for which it is being used. Should you decide not to provide certain requested information, it may not be possible to complete requested services.
3. Consent – In the course of our normal practice, we will request you consent before sharing personal information with a third party. If we have identified a new use for your personal information, we will seek your consent to use your information in this manner. There are certain circumstances which may occur that we use a client’s personal information without their consent, such as for certain legal or statutory requirements. There may be other unique situations that require that we disclose personal information without the individual’s knowledge or consent, such as the following: to our legal counsel, to comply with a subpoena, a warrant or an order made by a court or other body with appropriate jurisdiction, to the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) as required by the Proceeds of Crime (Money Laundering) and Terrorist Financing Act; to a government institution that has requested the information, identified its lawful authority to obtain the information, and indicates that disclosure is for the purpose of enforcing, carrying out an investigation, or gathering intelligence relating to any federal, provincial or foreign law; or suspects that the information relates to national security, the defense of Canada or the conduct of international affairs; or is for the purpose of administering any federal or provincial law; to a government institution or an individual’s next of kin or authorized representative when there are reasonable grounds to believe that the individual has been, is or may be the victim of financial abuse.
4. Limiting collection – we limit our collection of personal information to what is required to carry out our services and meet all statutory requirements.
5. Limiting use, disclosure, and retention – we use and disclose information only for the purpose for which it was collected, unless the individual consents, or the use or disclosure is authorized by privacy legislation. We generally keep personal tax information for a period of seven years unless it has relevance for a future time period in which case it may be kept for a longer time period as considered reasonable in the circumstances given its purpose or a legal requirement. After such time, it will be destroyed in accordance with our records maintenance procedures.
6. Accuracy – our policy is to keep information up to date as much as possible, and to update information prior to disclosing to third parties to prevent communication of incorrect information.
7. Safeguards - our responsibilities to our clients include the following: to protect personal information against loss or theft; Safeguard the information from unauthorized access, disclosure, copying, use or modification; and to protect personal information regardless of the format in which it is held. We utilize various safeguards including physical measures, technological tools, and organizational tools to meet these responsibilities.
8. Openness - we post a copy of our privacy policy on our website and provide a printed copy upon request to ensure they are readily available.
9. Individual access – Clients have the right to access to their information upon request, and to correct or amend any personal information if its accuracy and completeness is found to be deficient.
10. Challenging compliance - All enquiries about this Privacy Policy or the personal information management practices our firm should be referred to our Privacy Officer at 613-499-9889 will investigate all complaints. If a complaint is found to be justified, we will take appropriate measures, including, if necessary, amending our policies and practices.
We are deeply committed to protecting the personal information of our clients and appreciate the trust you place in us.
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