Toronto Tax Consulting Privacy Policy

As of January 1, 2004, firms in Canada collecting, using or disclosing personal information in the course of public practice activities must comply with the federal Personal Information Protection and Electronic Documents Act (“PIPEDA”). Personal information includes any information about an identifiable individual, but does include the name, title or business address or business telephone number of an individual. Toronto Tax Consulting is committed to maintaining and protecting the privacy of personal information provided by our clients through effective policies and procedures designed to safeguard confidential information. Our privacy policy is guided by the ten fundamental principles of PIPEDA, and our procedures comply with the requirements of federal and provincial privacy legislation.

1. Accountability

Toronto Tax Consulting is accountable for all personal information in our possession or control, including information received directly from the client, from a third party or indirectly through clients that are organizations. Our established and implemented policies and procedures such as data encryption, computer protection, office security systems and office protocol properly protect personal information and comply with privacy legislation.

If you would like to discuss our privacy policy, please contact our Privacy Officer in writing at 401 Bay Street Suite 1600 Toronto ON M5H 2Y4. Suggestions and complaints are seriously considered and Toronto Tax Consulting will take appropriate measures including the amendment of our policies and procedures when necessary.

2. Purpose for Collecting Personal Information

Toronto Tax Consulting believes in responsibly collecting and using personal information only for the purpose for which it was collected and in line with the professional services requested by the client. Such purposes include:

• To understand the client’s needs;
• To analyze the suitability of our services for the client’s needs;
• To establish, maintain and offer services meeting the client’s needs, as outlined in the client engagement letter; and
• To meet legal and regulatory requirements such as reporting and data retention.
Each service we provide is described in an engagement letter to our client.

3. Client Consent

Client consent for Toronto Tax Consulting to collect personal information is contained in the engagement letter. Consent may also be required when clients require additional services, in which case separate engagement letters outlining specific requirements will be provided for client consent. Consent may also be given by an authorized representative such as a legal guardian or a person with power of attorney. Client consent can be refused or withdrawn at any time, subject to certain exceptions related to legal and contractual restrictions and reasonable notice. Implications and consequences of such a refusal or withdrawal are outlined in the engagement letter.

4. Limiting Collection

Toronto Tax Consulting collects only that personal information required to perform professional services and operate our business as identified above, and such information is collected by fair and lawful means.

5. Limiting Use, Disclosure and Retention

Toronto Tax Consulting will use or disclose personal information only for the purpose(s) it was collected, unless the client consents to use or disclose for another purpose, or if the law requires it. As required by professional standards and rules of professional conduct and regulation, we document the work performed in records, commonly called tax planning or compliance files. Such files may include personal information obtained from our clients. All tax planning or compliance files and other files containing, for example, copies of personal tax returns are retained for the time period required by law and regulation, including Rules of Professional Conduct. Personal information shall be retained only as long as necessary for the fulfillment of those purposes, generally the standard period of seven years from the final closing of the client file or the date the last service was provided. Toronto Tax Consulting 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.

6. Accuracy

Toronto Tax Consulting endeavours to keep accurate, complete and up-to-date personal information in our possession and control, to the extent required to meet the purposes for which it was collected. Information will be updated annually or as necessary. We will take appropriate steps to verify the accuracy of personal information to be used in making significant decisions, and will also rely on clients for keeping certain personal information (such as contact information) current and complete. If necessary and upon client consent, Toronto Tax Consulting may also inform third parties to whom this personal information was previously disclosed for administrative purposes in order to ensure consistent and accurate records.

7. Safeguarding Personal Information

Toronto Tax Consulting protects the privacy and confidentiality of personal information by using security measures to safeguard from loss, theft, unauthorized access, disclosure, duplication, use or modification, appropriate to the sensitivity of the information. The highest level of protection is given to the most sensitive personal information. Safeguards include:

• Physical security: The office location where client information is stored is protected by a monitored security system. Further security measures include restricted access to rooms and cabinets and password protected computers storing electronic documents. Access is granted to authorized personnel only. Electronic files are backed up daily and swapped with offsite storage devices weekly. Data stored offsite is encrypted and password protected.

• Authentication: All computers are password protected. Electronic client information is accessible only by authorized personnel.

• Encryption: All electronic client information is stored with encryption, whether such information is within the office location or outside the office location.

8. Openness

Toronto Tax Consulting is transparent about the procedures and policies we use to manage personal information. Accessing up- to-date privacy information can be done through viewing our privacy policy on our website or by contacting our Privacy Officer (see contact information under principle 1).

9. Accessibility

Clients may request in writing access to their personal information.

Toronto Tax Consulting responds to client requests about their personal information on a timely basis, and will inform the client of the existence, use and disclosure of personal information, and, with certain exceptions, access shall be granted to it. Clients may verify the accuracy and completeness of their information, and may request that it be amended if appropriate. In certain situations, we may be unable to provide a client access to certain personal information. We will provide the reason why access must be denied, except where prohibited by law.

10. Challenging Compliance

Questions or complaints with respect to privacy and Toronto Tax Consulting’s privacy policy or practices shall be investigated on a timely basis (generally within 30 days). Upon a full investigation and potential justification of a complaint, Toronto Tax Consulting will take appropriate measures to resolve the issue including changing our policies and procedures in order to ensure that such issues can be avoided in the future. If you would like to make an inquiry, suggestion or complaint regarding Toronto Tax Consulting’s personal information practices, please contact our Privacy Officer in writing at 401 Bay Street Suite 1600 Toronto ON M5H 2Y4.