AKLER, BROWNING, FRIMET & LANDZBERG LLP
Principle #1: 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 and procedures aimed at properly protecting personal information;
- Appointed its Chief Privacy Officer to oversee privacy issues at the firm.
- If you have any questions about the firm’s privacy policies and practices, the firm’s Privacy Officer can be reached by email at firstname.lastname@example.org, by phone at 416-221-8614 and by letter Akler, Browning, Frimet & Landzberg LLP, Chartered Accountants, 5255 Yonge Street, Suite 700, Toronto, ON M2N 6P4.
Principle #2: 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. The types of information that may be collected for this engagement and the purposes for which it is collected, are set out in under Principles 3 and 4 of this privacy statement.
Principle #3 – The firm obtains a client’s consent before collecting personal information from that client.
- The engagement letter to which this privacy statement is attached sets out your responsibility to obtain any consents required under applicable privacy legislation, for collection, use and disclosure to us of personal information. By signing the engagement letter, you are formally acknowledging this responsibility.
Such personal information could include:
- Home addresses
- Home telephone numbers
- Personal identification numbers (e.g., social insurance numbers, credit card numbers)
- Financial information (credit ratings, payroll information, personal indebtedness)
- Personnel information (e.g., employment history),
- Information linked to the type of client, for example:
- Information in medical records (with respect to organizations such as hospitals or medical practices)
- Information related to race, religion, sexual preference, receipt of welfare or subsidized housing (with respect to various types of not-for-profit and government entities)
- Source data in claims and in-force databases (with respect to insurance companies)
- Tenant information (with respect to residential leasing companies).
Principle #4 – The firm collects only that personal information required to perform its professional service and operate its business, and such information is collected by fair and lawful means.
Principle #5 – The firm uses or discloses personal information only for purposes for which it has consent, 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.
- The personal information collected from a client during the course of a professional service 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;
- Provided to members of the organization’s board of directors, and others in the company that might not otherwise have access to the information, in the course of communicating aspects the results of our engagement, and
- Provided to external professional practice inspectors (e.g., representatives of 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 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.
Principle #6 – The firm endeavors 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.
- Individual clients are encouraged to contact the firm’s engagement partner in charge of providing service to them to update their personal information.
Principle #7 – 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.
Principle #8 – The firm is open about the procedures it uses to manage personal information.
- Officer (see contact information under principal 1).
Principle #9 – 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 service 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 reason why access must be denied and any recourse the client may have, except where prohibited by law.
- The firm has policies and procedures to receive, investigate, and respond to clients’ complaints and questions relating to privacy.
CONSENT NOTIFICATION IN CONNECTION WITH
PROFESSIONAL SERVICES – TAX AND FINANCIAL PLANNING
Types of Information We Collect
Akler, Browning, Frimet & Landzberg LLP collects certain personal information about you – but only when that information is provided by you or is obtained by us with your authorization. We use that information to prepare your personal income tax returns and to provide various tax and financial planning services to you at your request. As well, we may input on your income tax return other family (spouse, children, parents) information unless otherwise advised.
Example of sources from which we collect information include:
- Interviews and phone calls with you
- Letters or e-mails from you
- Tax return or financial planning organizers
- Financial history questionnaires
Parties to Whom We Disclose Information
Akler, Browning, Frimet & Landzberg LLP as a general rule, does not disclose personal information about our clients or former clients to anyone. Our policy is to disclose personal information about our clients, only with their express authorization. However, to the extent permitted by law and any applicable state code of Professional Conduct, certain non-public information about you may be disclosed in the following situations:
- To comply with a validly issued and enforceable subpoena or summons.
- In the course of a review of our firm’s practices under the authorization of a state or national licensing board, or as necessary to properly respond to an inquiry or complaint from such a licensing board or organization.
- In the event of a prospective purchase, sale, or merger, provided that we take appropriate precautions (for example, through a written confidentiality agreement) so the prospective purchaser or merger partner does not disclose information obtained in the course of the review.
- As a part of any actual or threatened legal proceedings or alternative dispute resolution proceedings either initiated by or against us, provided we disclose only the information necessary to file, pursue, or defend against the lawsuit and take reasonable precautions to ensure that the information disclosed does not become a matter of public record.
- To provide information to affiliates of the firm and non-affiliated third parties who perform services or functions for us in conjunction with our services to you, but only if we have a contractual agreement with the other party that prohibits them from disclosing or using the information other than for the purposes for which it was disclosed. (Examples of such disclosures include using an outside service bureau to process tax returns or engaging a records-retention agency to store prior year records).
Use of Personal Information
We use the information collected under this Policy to perform services within the scope of our engagement. We also use it to enable us to provide you through various channels with information that we believe will be of interest to you. This includes such matters as:
- New services we provide,
- Conferences and other professional development courses we hold,
- Notice of changes in the law or accounting practices that may be of interest to you, and
- Other professional or business developments.
If you do not wish to receive such information, you may opt out by advising your Audit and Accounting contact and we will discontinue sending you information other than in regard to your account.
Confidentiality and Security of Personal Information
Except as otherwise described in this notice, we restrict access to non-public personal information about you to employees of our firm and other parties who must use that information to provide services to you. Their right to further disclose and use the information is limited by the policies of our firm, applicable law, our Code of Professional Conduct, and non-disclosure agreements where appropriate. We also maintain physical, electronic and procedural safeguards in compliance with applicable laws and regulations to guard your personal information from unauthorized access, alteration, or premature destruction.