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Privicy Policy

Privacy of personal information has always been an important principle to Daley & Company Chartered Accountants LLP and will continue to be. We abide carefully by the Rules of Conduct of the Institute of Chartered Accountants of BC, including the rules concerning client confidentiality. We are committed to collecting, using and disclosing personal information responsibly and only to the extent necessary for the services we provide. We also try to be open and transparent as to how we handle personal information. This document describes our privacy policies.

What is Personal Information?

Personal information is information about an identifiable individual. Personal information includes information that relates to their personal characteristics (e.g., gender, age, income, home address or phone number, ethnic background, family status), their health (e.g., health history, health conditions, health services received by them) or their activities and views (e.g., religion, politics, opinions expressed by an individual, an opinion or evaluation of an individual). Personal information is to be contrasted with business information (e.g., an individual’s business address and telephone number), which is not protected by privacy legislation.

Who We Are

Our organization, the accounting office of Daley & Company, includes at the time of writing 30 staff members. We occasionally use consultants and agencies that may, in the course of their duties, have limited access to personal information we hold. These include computer consultants, office security and maintenance, temporary workers to cover holidays, credit card companies, website managers, cleaners, our landlord and other accountants. We restrict their access to any personal information we hold as much as is reasonably possible. We also have their assurance that they follow appropriate privacy principles.

We Collect Personal Information: Primary Purposes
About Clients

Like all accountants, we collect, use and disclose personal information in order to serve our clients. For our clients, the primary purpose for collecting personal information is to provide accounting, taxation, and other business advice and services. Where our client is an individual, we collect information about the client, their financial situation, and then assist them in filing their income tax return or in other matters where they require assistance.
It would be rare for us to collect any personal information without the client’s express consent, but this might occur in a case of urgency (e.g., the client is unavailable).

About Members of the General Public
A primary purpose for collecting personal information about members of the general public is to provide notice of special events (e.g., a seminar or conference) or to make them aware of accounting services in general or our firm in particular. For example, while we try to collect work contact information where possible, we might collect home addresses, fax numbers and email addresses. We try to obtain consent before collecting any such personal information, but where this is not, for any reason, possible, we will upon request immediately remove any personal information from our distribution list.

About Contract Staff

For people who are contracted to do work for us (e.g., temporary workers), our primary purpose for collecting personal information is to ensure we can contact them in the future (e.g., for new assignments) and for necessary work-related communication (e.g., sending out paycheques, year-end tax receipts, tax filings). Examples of the type of personal information we collect for those purposes include home addresses and telephone numbers. It is rare for us to collect such information without prior consent, but it might happen in the case of a health emergency (e.g., an outbreak of a contagious disease) or to investigate a possible breach of law (e.g., if a theft were to occur in the office).

We Collect Personal Information: Related and Secondary Purposes

Like most organizations, we also collect, use and disclose information for purposes related to or secondary to our primary purposes. The most common examples of our related and secondary purposes are as follows:

• To invoice clients for goods or services that are not paid for at the time, to process credit card payments or to collect unpaid accounts.
• To advise clients and others of new developments in tax law (e.g., a newsletter sent to a home address or home email of a client).
• Our firm reviews client and other files for the purpose of ensuring that we provide high quality services, including assessing the performance of our partners and staff. In addition, external consultants may on our behalf do audits and continuing quality improvement reviews of our firm, including reviewing client files and interviewing our staff.
• Accountants are regulated by the Institute of Chartered Accountants of BC who may inspect our records and interview our staff as a part of its regulatory activities in the public interest. Also, like all organizations, various government agencies (e.g., Canada Revenue Agency, Information and Privacy Commissioner, Human Rights Commission, etc.) have the authority to review our files and interview our staff as a part of their mandates. In these circumstances, we may consult with lawyers, who will investigate the matter and report back to us.
• Clients or other individuals we deal with may have questions about the services they received. We also provide ongoing services for many of our clients over a period of months or years for which previous records are helpful. We retain our client information for a minimum of ten years after the last contact to enable us to respond to those questions and provide these services (the Institute of Chartered Accountants also requires us to retain our client records).
• If Daley & Company or its assets were to be sold, the purchaser would want to conduct a “due diligence” review of the firm’s records to ensure that it is a viable business that has been honestly portrayed to the purchaser. This due diligence may involve some review of our accounting and service files. The purchaser would not be able to remove or record personal information. Before being provided access to the files, the purchaser must provide a written promise to keep all personal information confidential. Only reputable purchasers who have already agreed to buy the organization’s business or its assets would be provided access to personal information, and only for the purpose of completing their due diligence search prior to closing the purchase.

You can choose not to be part of some of these related or secondary purposes (e.g. by paying for your services in advance). We do not, however, have much choice about some of these related or secondary purposes (e.g., external regulation).

Protecting Personal Information

We understand the importance of protecting personal information. For that reason, we have taken the following steps:

• Paper information is either under supervision or secured in a locked or restricted area at all times.
• Electronic hardware is either under supervision or secured in a locked or restricted area at all times. In addition, passwords are used on computers. All of our cell phones are digital, which signals are more difficult to intercept (however, we still are careful on cell phones because sometimes they switch over to an analog service).
• Paper information is transmitted through sealed, addressed envelopes or boxes by reputable companies.
• Electronic information is transmitted either through a direct line or is encrypted.
  
• Staff are trained to collect, use and disclose personal information only as necessary to fulfill their duties and in accordance with our privacy policy.
• External consultants and agencies with access to personal information must provide us with appropriate privacy assurances.

Retention and Destruction of Personal Information

We need to retain personal information for some time to ensure that we can answer any questions you might have about the services provided and for our own accountability to external regulatory bodies. However, we do not want to keep personal information longer than necessary in order to protect your privacy.

We keep our client files for at least ten years. Our client and contact directories are much more difficult to systematically destroy, so we remove such information when we can if it does not appear that we will be contacting you again. However, if you ask, we will remove such contact information right away. We keep any personal information relating to our general correspondence with people who are not our clients for about two years.

We destroy paper files containing personal information by shredding. We destroy electronic information by deleting it and, when the hardware is discarded, we ensure that the hard drive is physically destroyed.

Consent

IF YOU CONTINUE TO USE OUR SERVICES AND/OR SUBMIT YOUR PERSONAL INFORMATION TO DALEY & COMPANY CHARTERED ACCOUNTANTS LLP, YOU CONSENT TO THE PURPOSES AND USES OUTLINED ABOVE FOR WHICH DALEY & COMPANY CHARTERED ACCOUNTANTS LLP COLLECTS AND/OR SHARES YOUR PERSONAL INFORMATION.

You Can Look at Your Information

With some exceptions, you have the right to see what personal information we hold about you. Often all you have to do is ask. We can help you identify what records we might have about you. We will also try to help you understand any information you do not understand (e.g., short forms, technical language, etc.). We will need to confirm your identity, if we do not know you, before providing you with this access. We reserve the right to charge a nominal fee for such requests.

If there is a problem, we may ask you to put your request in writing. If we cannot give you access, we will tell you within 30 days if at all possible and tell you the reason, as best we can, as to why we cannot give you access.

If you believe there is a mistake in the information, you have the right to ask for it to be corrected. This applies to factual information and not to any professional opinions we may have formed. We may ask you to provide documentation that our files are wrong. Where we agree that we made a mistake, we will make the correction and notify anyone to whom we sent this information. If we do not agree that we have made a mistake, we will still agree to include in our file a brief statement from you on the point and we will forward that statement to anyone else who received the earlier information

Do You Have a Question?

Our Information Officer, Michael Parker, can be reached at:

Michael Parker, CA
Daley & Company Chartered Accountants LLP
Suite 900, 235 First Avenue
Kamloops, BC V2C 3J4
Phone: (250) 374-5577
Fax: (250) 374-5573
Email: mike@daleyllp.ca

He will attempt to answer any questions or concerns you might have.

If you wish to make a formal complaint about our privacy practices, you may make it in writing to our Information Officer. He will acknowledge receipt of your complaint, ensure that it is investigated promptly and that you are provided with a formal decision and reasons in writing.

This policy disclosure is made under the Personal Information Protection and Electronic Documents Act. It is a complex Act and provides some additional exceptions to the privacy principles that are too detailed to set out here. There are some rare exceptions to the commitments set out above.

If you have not received a satisfactory response to your privacy concerns after contacting our Privacy Officer, you may direct your question or complaint to any of the following:

Industry Associations

Institute of Chartered Accountants of British Columbia – http://www.ica.bc.ca/kb.php3
Canadian Institute of Chartered Accountants - http://www.cica.ca/

For more general inquiries or complaints, the Information and Privacy Commissioners for British Columbia and Canada oversee the administration of the privacy legislation in the private sector. The Commissioners also act as ombudsmen for privacy disputes. The Information and Privacy Commissioners can be reached at:

Federal:
Privacy Commissioner for Canada
112 Kent Street
Ottawa, ON K1A 1H3
Phone: (613) 995-8210
Toll-free: 1-800-282-1376
Fax: (613) 947-6850
TTY: (613) 992-9190
www.privcom.gc.ca

British Columbia
Office of the Information and Privacy Commissioner
Fourth Floor, 1675 Douglas Street,
Victoria, British Columbia, Canada V8V 1X4
Telephone: (250) 387-5629
Facsimile: (250) 387-1696
Toll free access within British Columbia 1-800-663-7867

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