PRIVACY POLICY

SM CPA Professional Corporation recognizes the importance of privacy and the sensitivity of personal information. As accountants, we have a professional obligation to maintain the confidentiality of all personal information that we receive within an client & accountant relationship. This Privacy Policy outlines how SM CPA Professional Corporation will collect, use and disclose personal information while protecting clients’ privacy rights pursuant to the Personal Information and Electronic Documents Act (“PIPEDA”).

Why Does SM CPA Professional Corporation Require Personal Information?

SM CPA Professional Corporation provides financial services to clients, such as personal, small business and corporate accounting, business advisory and taxation services. We require personal information from clients in order to provide clients with the professional services for which we are retained.

“Personal information” means any information about an identifiable individual (whether recorded or not). Examples of personal information are:

• name, address, business address, contact telephone numbers.
• email addresses, ID numbers, banking & credit card information.
• evaluations, comments, social status or legal actions, assessments & judgments
• employer, employee, personal and business financial information.

What Personal Information Does SM CPA Professional Corporation Collect?

SM CPA Professional Corporation collects personal information from clients in all areas of its practice.

In tax, accounting and business advisory services, we require personal and/or business information to provide services to our clients. We may also require clients’ names, addresses and dates of birth, Social Insurance Numbers, banking information and personal identification documentation to provide on clients’ behalf to the Canada Revenue Agency, banks, governmental, regulatory authorities (the “Authorities”) and/or to vendors such as Quickbooks Online to setup our clients for online bookkeeping and accounting services.

How Does SM CPA Professional Corporation Collect Personal Information?

SM CPA Professional Corporation collects personal information in accordance with PIPEDA. The collection, use and disclosure of clients’ personal information depends on the type of services SM CPA Professional Corporation is retained to provide. Generally all clients are required to provide us with the information and documentation that we are obligated to obtain by the Canada Revenue Agency in identifying our clients and being authorized to represent them or their business on their behalf. Such identification and verification documents are required to be retained by us for a period specified on the Canada Revenue Agency authorization forms i.e. personal authorization form no. T1013 and business authorization form no. RC59. We will from time to time require clients to renew and re-submit these forms as required by the Canada Revenue Agency.

The collection of personal information to represent a client does not constitute a responsibility of financial record keeping and safeguarding of personal, business accounting & taxation information. This is the responsibility of the client. The client is responsible to retain all the back-up, supporting documentation, proof of income, expenditures and other pertinent information i.e. receipts, statements, bills & invoices etc. required for accounting, business advisory, taxation services rendered and should be kept for a minimum of six years from the end of the last tax year to which they relate. SEE PUBLICATION IC78-10R5 Books and Records Retention/Destruction. Please also refer to Canada Revenue Agency websites for personal and business record keeping publications and bulletins. There are situations that alter this rule. If you have filed late returns, the six-year rule applies to date of filing, not the tax year. We generally recommend keeping the all records for 7 years and hereby notify all clients and prospective clients that there is no time limitation when Canada Revenue Agency is investigating, reviewing and/or auditing due to suspicion of fraud and/or tax evasion and Canada Revenue Agency can go as far back as they require and the six year limitation rule is not applicable under these circumstances.

We provide clients with the opportunity to advise us if they do not want us to use, disclose or collect their personal & business information and require specific service on ad-hoc basis.

Consent

Clients’ knowledge and consent are required before SM CPA Professional Corporation may collect, use or disclose clients’ personal information, except in situations otherwise permitted by law. Consent means that clients clearly understand what information is or may be collected, in what circumstances the information may be collected, and by what means. In most cases, we request that clients provide us with explicit oral or written consent, if we collect, use or disclose clients’ personal information. In limited situations, clients’ consent may be implied through conduct with us. If any of the personal information that we collect is sensitive, we will obtain additional written or oral consent from clients, before collecting, using or disclosing the personal information. Clients may withdraw their consent at any time upon reasonable notice, subject to legal or contractual restrictions. However, withdrawing consent may affect SM CPA Professional Corporation’s ability to continue to provide clients with professional services.

Individuals who are not clients of SM CPA Professional Corporation and contact SM CPA Professional Corporation through email, website quick email form, telephone or any other form of communication hereby consent to SM CPA Professional Corporation to collect and use information in accordance to their client’s consent & use of personal information terms therein and until notified by the individual in writing to stop receiving information from SM CPA Professional Corporation.

Use of Personal Information

SM CPA Professional Corporation uses clients’ personal information to provide accounting, business advisory and taxation services to clients, to administer client time and billing databases, and to include clients in the firm’s direct marketing activities. If clients advise us that they no longer wish to receive information about our services, or about new developments in Canada Revenue Agency policies & procedures, accounting regulations and taxation law, we will not send any further material. SM CPA Professional Corporation will not disclose clients’ personal information to any third party to enable them to market their products and services.

Disclosure of Personal Information

Under the following circumstances, SM CPA Professional Corporation will disclose clients’ personal information:

• when it is required or authorized by law to do so;
• when clients have consented to the disclosure;
• when the accounting, business advisory and taxation services we are providing to clients require us to give client’s personal information to third parties;
• where it is necessary to establish or collect fees;
• if we engage a third party to provide administrative services to us and the third party is bound by our privacy policy (ie. computer back-up services or archival file storage);
• if we retain other professional services i.e. law firms or specialized accounting firms in SM CPA Professional Corporation’s or other jurisdictions on a client’s behalf; and
• if the information is already publicly known.

Updating Personal Information

As we use clients’ personal information to provide accounting, business advisory and taxation services to clients, it is important that the information be accurate and up-to-date. If during the course of our servicing our clients, any personal information changes, we request that clients inform us so that we can make any necessary changes and update our files.

Is Clients’ Personal Information Secure?

SM CPA Professional Corporation takes all reasonable precautions to ensure that clients’ personal information is kept safe from loss, unauthorized access, modification or disclosure. The steps taken to ensure clients’ personal information is protected are as follows:

• restricted file access to personal information;
• deploying technological safeguards like security software and firewalls to
  prevent hacking or unauthorized computer access; and
• internal password and security policies.

Access to Personal Information

Clients can challenge the accuracy and completeness of their personal information and request that it be amended. A summary of clients’ information is available on request. More detailed requests which require archive or other retrieval costs may be subject to our professional and disbursement fees. Please make your request in writing to SM CPA Professional Corporation, 2000 Argentia Rd Plaza 3, Suite 400 Mississauga Ontario L5N 1V9 stating as specifically as possible what personal information you are requesting. We will respond to such requests within 30 days from the receipt of the request or will advise clients  if we cannot respond within that time.

If SM CPA Professional Corporation holds personal information about clients that is not accurate, complete and up-to-date, we will take reasonable steps to correct it once we are advised that it is incorrect.
Clients’ rights to access personal information held by us are not absolute. We may deny clients access when:

• denial of access is required or authorized by law;
• information relates to existing or anticipated legal proceedings against
  clients;
• when granting clients’ access would have an unreasonable impact on other people’s privacy;
• when to do so would prejudice negotiations with clients;
• to protect our firm’s rights and property;
• where the request is frivolous or vexatious.

If we deny clients’ requests for access to personal information or refuse to correct personal information, we will explain the reasons for our refusal.

Communicating With Us

When communicating with us, clients should be aware that e-mail is not a 100% secure medium for information. If clients want to ensure the confidence of the personal information they send to us, they should use more secure mediums such as the telephone, letters or direct contact.

Changes to Our Privacy Policy

SM CPA Professional Corporation regularly reviews all of its policies and procedures and may change its Privacy Policy from time to time as considered necessary.

Questions

If you have any questions regarding our Privacy Policy, please contact SM CPA Professional Corporation at 416-821-3624 or info@smcpapc.ca