Symons, Wearn & Smith, LLP (“SWS”) has created this Privacy Policy in order to demonstrate its commitment to privacy. As of January 1st, 2004, SWS is required by law, under the Personal Information Protection and Electronic Documents Act, to make you aware of your rights regarding the handling of your personal information, and to obtain consent prior to using or disclosing such personal information. This policy explains how SWS collects, uses, discloses and safeguards the personal information provided to it either directly by you or by a third party.
By providing personal information to SWS or authorizing a third party to provide your personal information to SWS, you signify consent to SWS’ collection, use and disclosure of your personal information in accordance with this privacy policy.
What Kind of Personal Information is Collected?
For purposes of this privacy policy, “personal information” means any information that can identify an individual directly or through other reasonably available means. Personal information such as your name, age, home telephone number and address, date of birth, education, name of your current employer and financial information (i.e. personal and corporate financial holdings) may be collected by SWS. Personal information does not include an individual’s business address and business telephone number.
As part of SWS’ commitment to treat your personal information with respect, it operates in accordance with the following ten principles (the “Principles”):
Principle 1 – Accountability
SWS will maintain and protect the personal information under its control. SWS has designated an individual who is accountable for compliance with the Principles.
Principle 2 – Identifying Purposes
The purposes for which personal information is collected by SWS will be identified to you before or at the time the information is collected.
Principle 3 – Consent
Except where required or permitted by law, your informed consent is required for SWS’s collection, use or disclosure of your personal information.
Principle 4 – Limiting Collection
The personal information collected by SWS shall be limited to those details necessary for the purposes identified to you.
Principle 5 – Limiting Use, Disclosure and Retention
SWS will only use or disclose your personal information in accordance with purposes for which it was originally collected unless you have otherwise consented, or when it is required or permitted by law. SWS will retain your personal information only for so long as is required to fulfill the purpose for which it was collected or as required by law.
Principle 6 – Accuracy
SWS shall make every reasonable effort to ensure your personal information is maintained in an accurate, complete and up-to-date form.
Principle 7 – Safeguarding Personal Information
SWS shall utilize security safeguards appropriate to the sensitivity of the information and in accordance with industry standards to protect your personal information.
Principle 8 – Openness
If you have any questions regarding SWS privacy policy, we will discuss them with you.
Principle 9 – Individual Access
Upon your request, SWS shall inform you of: (i) the type of information it has collected; (ii) how it has used your personal information in the past, and how it may in the future; and (iii) whether or not it has disclosed your personal information to any third parties (and, if so, to whom). Individuals may verify the accuracy and completeness of their personal information, and may request that it be amended, if appropriate.
Principle 10 – Handling Complaints and Suggestions
Individuals may direct any questions or enquiries with the respect to the Principles or about SWS’ information handling practices by contacting the person indicated at the end of this document.
Why Does SWS Collect Your Information and How is it Used?
This information is gathered for, and may be used in:
- Preparation of personal income tax returns;
- Preparation of a rolodex to facilitate an efficient manner for communication with our clients;
- Developing mailing lists for the purpose of informing our clients of the latest developments in tax, accounting, business advisory and valuations; and
- When required by law.
SWS also uses the personal information you have provided to us to communicate with you and safeguard your interests. SWS will send you important notices, and respond to any special needs or enquiries you may have. SWS will only use personal information for the purposes that it has disclosed to you. If for any reason your information is required to fulfill a different purpose, SWS will obtain your consent before we proceed.
The choice to provide SWS with your personal information, either directly or through a third party, is always yours. However, your decision to withhold particular information may result in limiting our ability to provide services to you.
How is Your Information Collected?
SWS collects information about you when we perform services (i.e. personal income tax, corporate accounting) on your behalf. We collect this information from telephone calls, facsimiles, e-mails, letters from you or third parties and various correspondence provided to us.
SWS tries to ensure that every third party who discloses personal information to SWS has your consent to do so. However, if you believe that a third party has inappropriately disclosed your personal information to us, please contact that third party. If they do not adequately respond to your inquiries, please let us know immediately.
When Information May be Disclosed to Third Parties
SWS does not disclose any personal information to third parties, except as specifically provided for in this Privacy Policy. The only instance where SWS may disclose your personal information to a third party would be when required or permitted by law.
The type of information SWS is legally required to disclose may relate to criminal investigations or government tax reporting requirements. In some instances such as a legal proceeding or court order, SWS may also be required to disclose certain information to authorities. Only the information specifically requested will be disclosed and SWS will take precautions to satisfy ourselves that the authorities that are making the request have legitimate grounds to do so.
Our Employees and your Personal Information
In the course of daily operations, access to private, sensitive and confidential information is restricted to those authorized individuals who have a legitimate business purpose and reason for accessing it. For example, only those individuals working on your file will be authorized to access your information.
As a condition of their employment, all employees of SWS are required to abide by the privacy standards SWS has established. Employees are informed about the importance of privacy and they are required to agree not to disclose any personal information to unauthorized individuals or parties. Unauthorized access to and/or disclosure of personal information by an employee of SWS is strictly prohibited. All employees are expected to maintain the confidentiality of personal information at all times and failing to do so will result in appropriate disciplinary measures, which may include dismissal.
How SWS Safeguards Your Information
SWS uses industry standard technologies and maintains current security standards to ensure that you personal information is protected against unauthorized access, disclosure, inappropriate alteration or misuse. Paper based files are stored in locked rooms after normal business hours.
SWS manages its computer server environment appropriately and its firewall infrastructure is strictly adhered to. Our security practices are reviewed on a regular basis and SWS routinely employs current technologies to ensure that the confidentiality and privacy of your information is not compromised.
Accessing and Amending Your Information
To help SWS keep your personal information up-to-date, you are encouraged to amend inaccuracies and make corrections as often as necessary. Despite SWS’ efforts, errors sometimes do occur. Should you identify any incorrect or out-of-date information in your file(s), SWS will make the proper changes. Please note that before we are able to provide you with any information or correct any inaccuracies, we may ask you to verify your identity and to provide other details to help us to respond to your request. Where appropriate, SWS will communicate these changes to other parties who may have unintentionally received incorrect information from SWS.
Challenging Compliance
You are entitled to challenge or otherwise scrutinize SWS’ management of your personal information. Any concerns should be directed to the contact person identified below:
Privacy Officer
Christopher Martin, CA, CBV
| Telephone: | (519) 539-1278 |
| Facsimile: | (519) 539-9857 |
| E-mail: | chris@swsca.on.ca |
Updating this Privacy Policy
Any changes to SWS’ Privacy Policy and information handling practices will be acknowledged in this policy in a timely manner. SWS may add, modify or remove portions of this policy when it feels it is appropriate to do so. You may determine when this policy was last updated by referring to the modification date found at the bottom of this Privacy Policy.
Web Sites Governed by this Privacy Policy
The web site that is governed by the provisions and practices stated in this privacy policy is www.swsca.on.ca. SWS’ website may contain links to other third party sites that are not governed by this Privacy Policy. Although SWS endeavors to only link to sites with high privacy standards, its privacy policy will no longer apply once you leave SWS’s web site. Additionally, SWS is not responsible for the privacy practices employed by other third party web sites. Therefore, SWS suggest that you examine the privacy statements of those sites to learn how your information may be collected, used, shared and disclosed.
This Privacy Policy was last modified on March 30, 2004.