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Privacy
Policy
(Last updated on: February 29, 2008)
Introduction:
Our collection, use, retention, disclosure and destruction of our
customer’s personal information is in compliance with the principles set
forth in the Personal Information Protection and Electronic Documents
Act (“PIPEDA”). When used in this privacy policy, “personal
information” means information that can identify an individual and
information about an identifiable individual.
What
Information We Collect and Why:
We collect personal information from our clients to allow us to provide
such clients with the services they have retained us to provide. This
information will include personal information about our clients and
about other individuals with whom our clients conduct commercial
transactions, including a name, home address, home phone number,
personal e-mail address, financial information, social insurance number,
medical information, tax history and other tax information, marital
status, age, date of birth, country of residence, country of birth, net
worth, credit history, liabilities, assets and so forth.
Consent
for Collection, Use, and Disclosure:
If we need to collect information about individuals other than our
clients, we shall do so in accordance with the provisions of PIPEDA. We
will make reasonable efforts to ensure that the personal information we
collect, use, and distribute is accurate and complete and will provide
individuals with the opportunity to correct their personal information
in our possession or under our control as outlined below.
By
engaging our firm to provide services, we consider an individual to have
given our firm consent to the collection, use, and distribution of the
individual's personal information as reasonably required for the
delivery of such services. We will continue to collect, use, and
disclose personal information for such purposes until we receive written
instructions to stop doing so. Should such consent be withdrawn, we may
suspend or discontinue delivery of services to the extent we no longer
have access to required personal information.
We may
also collect, use, or disclose personal information about an individual
without that individual's consent and/or knowledge as permitted or
required under PIPEDA.
Our firm
will maintain the strictest confidence with respect to any client's or
former client's personal information. Accordingly, client’s personal
information (and any other client confidential information) will not,
without such client’s consent, be disclosed to any individuals in our
firm beyond those who are engaged in providing services to the client.
This policy applies to anyone outside the firm, except as required by
law or under the Institute of Chartered Accountants of Ontario's Rules
of Professional Conduct.
Our client
files are accessible by all staff electronically and in hard copy. Our
firm has an enforced policy acknowledged and agreed by all staff not to
access or use client information other than in the course of providing
professional services to or for that client.
In
accordance with professional regulations, our client files must
periodically be reviewed by provincial practice inspectors and by other
firm personnel to ensure that we have adhered to professional and firm
standards. File reviewers are required to maintain confidentiality of
client information.
Our firm
is a registrant with the Canadian Public Accountability Board ("CPAB").
Registration with these bodies is required in order to, after March 30,
2004, issue audit opinions for publicly listed companies in Canada CPAB
requires under their terms of registration to have access to our client
files and engagement personnel in the conduct of their practice review
and oversight mandates. Accordingly file information where requested by
CPAB will be made available for review and staff and partners of our
firm will provide information and where required, give testimony or
evidence relating to engagement information and knowledge.
Such
information would otherwise be restricted from disclosure under
professional rules of confidentiality or under privacy legislation and
firm policy. Information obtained from our files and personnel by CPAB
may be referred or disclosed to other regulatory bodies and professional
bodies which may in turn be used by them in investigations, disciplinary
actions and where appropriate, legal or securities related proceedings.
Security and Retention:
In recognition of our professional and legal obligations to protect our
client’s personal information (as well as our client’s confidential
information); we have made arrangements to protect against unauthorized
access, collection, use, disclosure, copying, modification, disposal, or
destruction of personal information.
We will
retain client personal information for a reasonable time period as
required by our Rules of Professional Conduct, applicable laws and the
terms of our professional liability insurance policy. When no longer
required, client personal information will be disposed of in a secure
manner.
Request
for Action and Correction:
Individuals have the right to ask, in writing, for access to their own
personal information in the custody or under the control of our firm as
permitted under PIPEDA. We will respond to requests as accurately and
completely as reasonably possible in the time allowed by PIPEDA. We are
entitled to refuse access in certain situation such as when:
• The
personal information is protected by solicitor-client privilege with
respect to another client.
•
Disclosure of the personal information would reveal confidential
information that could, in a reasonable person's opinion, harm the
competitive position of our firm or any of our other clients and/or
suppliers.
• The
personal information was collected for an investigation or legal
proceeding that has not concluded, including any appeals (excluding CPAB
requirements stated above).
• The
information was collected by a mediator or arbitrator in conducting a
mediation or arbitration where the mediator or arbitrator was appointed
under a collective agreement, a law, or by a court.
•
Disclosure could reasonably be expected to threaten the safety or
physical or mental health of another individual.
•
Disclosure could reasonably be expected to cause immediate or grave harm
to the safety or to the physical or mental health of the individual who
made the request.
•
Disclosure would reveal personal information about another individual.
•
Disclosure would identify the individual who has provided personal
information about another individual and that individual does not
consent to disclosure of his or her identity.
PIPEDA
also allows individuals to request in writing for our firm to correct
errors or omissions. We will correct any factual error or omissions and
inform where we feel it is appropriate, other organizations to which we
have disclosed the incorrect information. If we determine there is no
factual error or omission, we will annotate the record with the record
that a correction was requested but not made.
For more information, to file a complaint, to make
enquiries, or to opt out of all or parts of this Policy, please contact
Collins Barrow Toronto’s Privacy Officer:
COLLINS BARROW TORONTO PRIVACY OFFICER
Address: 20
Eglinton Avenue West
Suite 2100
P.O. Box 2014
Toronto, ON M4R 1K8
Telephone:
416-480-1060
Fax:
416-480-2646
E-mail:
privacy@dmct.com
Website:
www.dmct.com | 
