Personal Information Protection Policy
At Alexander Bookkeeping Company, we are committed to providing our clients with exceptional service. As providing this service involves the collection, use, and disclosure of some personal information about our clients, protections their personal information is one of our highest priorities.
While we have always respected our clients’ privacy and safeguarded their personal information, we have strengthened our commitment to protecting personal information because of Ontario’s Personal Information Protection and Electronic Documents Act (PIPEDA). PIPEDA is federal legislation passed in 2001 and fully implemented on January 1, 2004. The purpose of the Act is "to establish, in an era in which technology increasingly facilitates the circulation and exchange of information, rules to govern the collection, use and disclosure of personal information in a manner that recognizes the right of privacy of individuals with respect to their personal information and the need of organizations to collect, use or disclose personal information for purposes that a reasonable person would consider appropriate in the circumstances."
In accordance with PIPEDA, Alexander Bookkeeping Company ensures:
· The clear consent of an individual before we collect, use or disclose personal information about that individual
· We use the information only for the purposes for which we have consent
· We protect the information from unauthorized access and use
· We will always keep the information up to date and correctly filed so that decisions are based on correct information
· We destroy information when it is no longer needed for the original purpose and
· implement accountability mechanisms in our organization to ensure compliance with the above.
Scope of this policy
The Personal Information Protection and Electronic Documents Act (PIPEDA) applied to Alexander Bookkeeping Company
What is Personal Information? : Personal information refers to information about an identifiable person including:
social insurance number
Personal information does not include the name, title, business address or telephone number of an employee of an organization.
Policy 2 – Consent
2.1 We will obtain client consent to collect, use, ore disclose personal information (except where, as noted below, we are authorized to do so without consent)
2.2 Consent can be provided orally, in writing, or electronically and it will be implied where the purpose for collecting, using, or disclosing the personal information would be considered obvious and client voluntarily provides personal information for that purpose.
2.3 Subject to certain exceptions (e.g., the personal information is necessary to provide the service or product, or the withdrawal of consent would frustrate the performance of a legal obligation), clients can withhold or withdrawal their consent for Alexander Bookkeeping Company to use their personal information in certain ways. A client’s decision to withhold or withdraw their consent to certain uses of personal information may restrict tour ability to provide a service or product. If so, we will explain the situation to assist the client in making the decision.
2.4 We may collect, use, or disclose personal information without the client’s knowledge or consent in the following limited circumstances:
When the collection, use, or disclosure of personal information is permitted or required by law;
In am emergency that threatens an individual’s life, health, or personal security;
When the personal information is available from a public source (e.g., a telephone directory);
When we require legal advice from a lawyer;
For the purposes of collecting a debt;
To protect ourselves from fraud;
To investigate an anticipated breach of an agreement or a contravention of law.
Policy 3 – Using and Disclosing Personal Information
3.1 We will only use or disclose client personal information where necessary to fulfill the purposes identified at the time of collection or for a purpose reasonably related to those purposes such as:
To conduct client services to the best of Alexander Bookkeeping Company’s ability;
To contact our clients directly about products and services that may be of benefit
3.2 We will not use or disclose client personal information for any additional purpose s unless we consent to do so.
3.3 We will not sell client lists or personal information to other parties unless we have obtained consent to do so.
Policy 4 – Retaining Personal Information
4.1 If we use client personal information to make a decision that directly affects the client, we will retain that personal information for at least one year so that the client has a reasonable opportunity to request access to it.
4.2 Subject to policy 4.1, we will retain client personal information only as long as necessary to fulfill the identified purposes or a legal or business purpose.
Policy 5 – Ensuring Accuracy of Personal Information
5.1 We will make reasonable efforts to ensure that client personal information is accurate and compete where it may be used to make a decision about the client or disclosed to another organization.
5.2 Clients may request correction to their personal information in order to ensure its accuracy and completeness. A request to correct personal information must be made in writing and provide sufficient detail to identify the personal information and the correction being sought.
5.3 If the personal information is demonstrated to be inaccurate or incomplete, we will correct the information as required and send the corrected information to any organization to which we disclosed the personal information in the previous year. If the correction is not made, we will note the clients’ correction request in the file.
Policy 6- Securing Personal Information
6.1 We are committed to ensuring the security of client personal information in order to protect it from unauthorized access, collection, use, disclosure, copying, modification or disposal, or similar risks.
6.2 The following security measures will be followed to ensure that client personal information is appropriately protected:
The use of locked filling cabinets;
Physically securing offices where personal information is held;
The use of user IDs, passwords, encryption, and firewalls;
Restricting employee access to personal information as appropriate (i.e., only those that need to know will have access; contractually requiring any service providers to provide comparable security measures).
6.3 We will use appropriate security measures when destroying client’s personal information such as shredding documents, and properly deleting electronically stored information.
6.4 We will continually review and update our security policies and controls as technology changes to ensure ongoing personal information security.
Policy 7 – Providing Clients Access to Personal Information
7.1 Clients have a right to access their personal information, subject to limited exceptions.
7.2 A request to access personal information must be made in writing and provide sufficient detail to identify the personal information being sought.
7.3 Upon request, we will also tell clients how we use their personal information and to whom it has been disclosed if applicable.
7.4We will make the requested information available within 30 business days or provide written notice of an extension where additional time id required to fulfill the request.
7.5 A minimal fee may be charges for providing access to personal information. Where a fee may apply, we will inform the client of the cost and request further direction form the client on whether we should proceed with the request.
7.6 If a request is refused in full or in part, we will notify a client in writing, providing the reasons for refusal and the recourse available to the client.
Policy 8 – Questions and Complaints: The Role of the Privacy Officer or Designated Individual
8.1 Marion Alexander is responsible for ensure Alexander Bookkeeping Company’s compliance with this policy and the Personal Information Protection and Electronic Documents Act.
8.2 Clients should direct any complaints, concerns, or questions regarding Alexander Bookkeeping Company’s compliance in writing to the Privacy Officer. If the Privacy Officer is unable to resolve the concern, the client may also write to the Information and Privacy Commissioner of Ontario.