Best Roest & Co. LLP (“the Firm”) is committed to upholding the confidentiality of our clients’ and employees’ personal information with the highest of standards. As custodians of your personal information we strive to ensure the use and disclosure of your information is limited to the manner you have consented to. It is in under this principle that we have developed our Privacy Policy which serves as our guide and ensures that we are complying the Personal Information Protection and Electronic Documents Act (PIPEDA).

1. Accountability

The firm is responsible for the personal information you provide and will comply by the 10 principles listed herein. We will ensure that the personal information held by the Firm or transferred to a third party for administration or processing purposes is protected at all times. Personal information includes any factual or subjective information, recorded or not, about an identifiable individual. This includes information in any form, such as:

• age, name, ID numbers, income;
• opinions, evaluations, comments, social status, or disciplinary actions; and
• employee files, credit records, loan records, medical records, the existence of a dispute between a consumer and a merchant, intentions (for example, to acquire goods or services, or change jobs)

Personal information does not include the name, title or business address or telephone number of an employee of an organization.

The firm is committed to informing and training its staff on its privacy policy and procedures.

We have designated Brenda Best as our firm Privacy Partner

2. Identifying the Purpose

The purpose of collecting your personal information will be identified before or at the time it is collected and your consent will be obtained if there are any changes to the original purpose.

The Firm collects personal information to provide professional services such as providing assurance services, filing of tax returns, providing financial, tax and business advice; to provide such information to third parties at your request, such as banks and other financial institutions, government agencies and your legal representatives; and to comply with regulatory requirements amongst other purposes.

3. Obtain Consent

The collection of your personal information will only occur if the Firm has obtained your consent either before or at the time of collection the information. Your consent will also be required if there is any change in the use of personal information.

Your consent may be obtained orally or in writing, implied or expressed. The method by which consent is obtained is dependent on the nature of the information and the circumstances surrounding the collection.

4. Limit Collection

The firm will not collect personal information indiscriminately nor deceive or mislead you about the reasons for collecting personal information. We will only collect personal information which is required to provide you with the highest professional service and to administer invoicing and general correspondence. We will gather personal information directly from you and from bankers, lawyers or financial services with whom you have a relationship and have given consent to provide us with such information.

5. Limiting Use, Disclosure and Retention

Unless you have consented otherwise, your personal information will only be used or disclosed for the purposes for which it was collected. Your personal information will only be kept so long as it is required and guidelines are in place for retaining and destroying personal information. The length of retention of your information is dependent upon the period of our service to you and any legal or governmental requirements. The destruction of your private information, by shredding or deleting of electronic files, will be done in a manner protecting your privacy.

The Firm will not use or disclose your personal information in a manner outside the purposes for which it was collected, except when required by law.

In order to provide you with professional services, the Firm may use third parties and in doing so disclose your private information to them. This disclosure will occur only after we are satisfied that the third party service provider has the privacy policies similar to our own.

In addition, your personal information may be disclosed to external professional practice inspectors who, by law, professional regulation or contract have the right to access firm files for inspection purposes.

We may also disclose your personal information when you have requested us to do so, and when it is necessary for payment collection.

6. Accuracy

To minimize the possibility of using incorrect information we will keep your personal information as accurate and up to date as possible. Any changes of your personal information will be updated so long as it is necessary to fulfil the specified purposes for which it was originally collected.

7. Use of Appropriate Safeguards

The firm will protect your personal information against loss or theft and safeguard it from unauthorized access, disclosure, copying use or modification regardless of the format in which it is held.

The firm will use the following safeguards to protect your personal information:

• physical measures (locked filing cabinets, restricting access to offices, alarm systems)
• technological tools (passwords, encryption, firewalls)
• organizational controls (staff training, agreements)

8. Be Open

The Firm is open in regards to its privacy policy and will ensure that it is available upon request from our firm Privacy Partner and an up to date version of our policy is available online at http://www.bestroest.ca. To ensure the integrity of our security procedures and business method, we reserve the right to not disclose sensitive areas of our policy.

9. Give Individuals Access

At your request, the Firm will provide you with your personal information and explain how it has been used and to whom it has been disclosed. If you find any inaccuracies in your private information, we will amend the information upon your advice. Your information request will be responded to promptly but no later than 30 days after receipt of the request. If your information cannot be provided within 30 days, you will be notified of the reason for this delay.

The firm may charge a fee to provide you with your private information, however, any such charge will only take effect after you have been provided with an approximation of the charge.

In situations where the Firm is not able to provide you with your personal information, we will notify you and provide an explanation for the denial and delineate any recourse you may have. An information request may be denied for various reasons including but not limited to solicitor/client privilege, prohibition by laws or regulations, the inadvertent disclosure of personal information of another individual, etc.

10. Providing Recourse

All complaints related to the privacy of your information are taken seriously and investigated. Any complaint or question related to our privacy policy can be addressed to our firm Privacy Partner.

our complaint or question will be addressed within 30 days of receipt. If your concern cannot be resolved, you can contact the office of the Privacy Commissioner of Canada.