Our Privacy Policy

Introduction
On January 1, 2004, the Government of Canada passed new legislation known as the Privacy Information Protection and Electronic Documents Act (PIPEDA). This legislation requires all companies and firms that provide business services and collect personal information to adopt privacy policies and inform you of these policies and your rights under PIPEDA.

David M. den Boer, CA collects, uses and discloses personal information in the possession, or under the control, of its clients to the extent required to fulfill its professional responsibilities and operate its business. My firm is committed to maintaining the privacy of personal information provided by its clients and protecting all personal information in its possession or control. This Privacy Policy sets out the principles and procedures that the firm follows in meeting its privacy commitments to its clients and complying with the requirements of federal and provincial privacy legislation.

Accountable
My firm is accountable for all personal information in its possession or control. This includes any personal information received directly from clients who are individuals, or indirectly, through clients that are organizations (e.g., corporations, government entities, not-for-profit organizations).

We have:
- established and put into effect policies and procedures aimed at properly protecting personal information
- educated our employee(s) regarding our privacy policy and their role and responsibilities in keeping personal information private

Collection and Use
My firm collects personal information from clients using and disclosing such information only to provide the professional services that the client has requested. Each service provided is described in a letter to the client. The letter includes a description of the personal information required, why it is required, the uses that will be made of the information, and with whom it may be shared in the course of providing professional services.

The personal information collected from a client during the course of a professional service engagement may be:

- shared with the personnel participating in such engagement
- disclosed to individuals within the firm to the extent required to assess compliance with applicable professional standards and rules of professional conduct, and policies, including providing quality control reviews of work performed
- disclosed to members of the organization's audit committee and board of directors, and others in the company that might not otherwise have access to the information, in the course of communicating aspects of the results of our engagement
- provided to external professional practice inspectors (e.g., representatives of the Canadian Public Accountability Board, or a provincial institute of chartered accountants), who by law, professional regulation, or contract have the right of access to our files for inspection purposes

My firm collects only that personal information required to perform its professional services and to operate its business, and such information is collected by fair and lawful means.

Agreement with Client
Before I undertake a professional services engagement, I require the prospective client to sign an engagement letter or contract. The engagement letter or contract includes a description of the personal information required, why it is required, the uses that will be made of the information, and with whom it may be shared in the course of providing my professional services. By signing the engagement letter or contract, the client provides its agreement that proper consents to the collection, use and disclosure of personal information as set out in the letter have been or will be obtained (the consent of the individual is the responsibility of the client not the accountant).

Disclosure and Retention
My firm uses or discloses personal information only for purposes for which it has consent, or as required by law. This personal information is retained only as long as necessary to fulfill those purposes.

As required by professional standards, rules of professional conduct and regulation, we document the work we perform in records, commonly called working paper files. Such files may include personal information obtained from a client.

Working paper 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.

We regularly and systematically destroy, erase, or make anonymous personal information no longer required to fulfill the identified collection purposes, and no longer required by laws and regulations.

Accuracy
We endeavour to keep accurate, complete, and up-to-date, personal information in our possession or control, to the extent required to meet the purposes for which it was collected.

Certain customer and other information is used to form an opinion and needs to be accurate to be relied upon, as a result, updating the information is encouraged on an annual basis.

Security
My firm protects the privacy of personal information in its possession or control by using security safeguards appropriate to the sensitivity of the information.

Physical security is maintained over personal information stored in hard copy form.

Authentication is used to prevent unauthorized access to personal information stored electronically. Encryption is used to prevent unauthorized access to personal information received or sent over the Internet.

For files and other materials containing personal information entrusted to a third party service provider (e.g., a provider of paper based or electronic file storage), we obtain appropriate assurance to affirm that the level of protection of personal information by the third party is equivalent to that of our firm.

My firm is open about the procedures used to manage personal information.
Up-to-date information on our privacy policy can be obtained upon request or from our web site.

Response and Compliance
My firm responds on a timely basis to requests from clients about personal information we possess or control.

Individual clients of my firm have the right to contact us to obtain access to their personal information. Similarly, authorized officers or employees of organizations that are our clients have the right to contact us to obtain access to personal information provided by that client. In certain situations, however, we may not be able to give clients access to all their personal information. We will explain the reasons why access must be denied and any recourse the client may have, except where prohibited by law.

Clients may challenge my firm's compliance with its Privacy Policy.
We have policies and procedures to receive, investigate, and respond to clients' complaints and questions relating to privacy.

To challenge compliance with this Privacy Policy, clients are asked to provide an email message or letter to my firm. I will ensure that a complete investigation of a client complaint is undertaken and will report the results of this investigation to the client within 30 days.

If you have any questions about privacy policies and practices, contact

David M. den Boer, CA
241 Bonaventure Drive, Hamilton ON L9C 4R1
phone: 905.389.2670 - fax: 905.389.4642
email: davedaviddenboer.ca