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LANCASTER
& DAVID
Chartered
Accountants
PRIVACY POLICY
Introduction
At Lancaster & David, Chartered Accountants,
our clients privacy is, and always has been, very important to us. We are dedicated to providing our
clients with superior service while protecting their privacy and
safeguarding their personal information.
Lancaster & David, Chartered Accountants
(the “firm”), collects, uses and discloses personal information in the
possession, or under the control, of its clients to the extent required
to fulfill its professional responsibilities and operate its business.
The firm is committed to maintaining the privacy of personal information
provided by its clients and protecting all personal information in its
possession or control. This Privacy Policy sets out the principles and
procedures that the firm follows in meeting its privacy commitments to
its clients and complying with the requirements of federal and provincial
privacy legislation.
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;
·
educated
its partners and employees regarding its privacy policy and their role
and responsibilities in keeping personal information private; and
·
appointed
Michael J. David as 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, Michael J. David,
can be reached by email at mike@lancasteranddavid.ca, by phone at
604.717.5520 and by letter at Suite
510, 701 West
Georgia Street, PO Box 10133, Pacific
Centre, Vancouver, BC V7Y 1C6.
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 the
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 sets out the client’s 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, the client is 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, references to criminal
records)
- 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)
Principle #4 – The firm collects only that
personal information required to perform its professional services and
operate its business, and such information is collected by fair and
lawful means.
·
Collecting
personal information is essential to our being able to provide the professional
services that best meet the needs of both the client and/or authorized
third parties. While the personal
information we collect may come directly from the client, it may also be
provided by other third parties (such as employers, insurance brokers,
financial institutions, medical professionals, legal professionals, other
professional advisors, etc.)
Principle #5 – The firm uses or discloses
personal information only for purposes for which it has consent, or 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 or for a specified time period.
·
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 audit committee and board of directors,
and others in the company that might not otherwise have access to
the information, in the course of communicating aspects of the
results of our audit; and
- provided to
external professional practice inspectors (e.g., representatives of
the Canadian Public Accountability Board, or 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 endeavours 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 (e.g., restricted access, locked rooms and filing cabinets) 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.
·
Up-to-date information
on the firm’s privacy policy can be obtained from the firm’s Privacy
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 reasons why access must
be denied and any recourse the client may have, except where prohibited
by law.
Principle #10 – Clients may challenge the firm’s
compliance with its Privacy Policy.
·
The firm
has policies and procedures to receive, investigate, and respond to
clients’ complaints and questions relating to privacy.
·
To
challenge the firm’s compliance with its Privacy Policy, clients are
asked to provide an email message or letter to the firm’s Privacy Officer
(see contact information under principal 1 above). The firm’s Privacy
Officer will ensure that a complete investigation of a client complaint
is undertaken and will report the results of this investigation to the
client, in most cases, within 30 days.
©Copyright 2008
(Lancaster & David, Chartered Accountants) All Rights
Reserved
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