Rethink CPA Professional Corporation is committed to protecting the privacy rights of our clients and personnel.
This Privacy Policy explains how we collect, use and disclose the personal information we require in the course of fulfilling our professional responsibilities and operating our business. This Privacy Policy applies to all affiliates of Rethink CPA Professional Corporation in Canada (collectively referred to in this Privacy Policy as “Rethink CPA”, “we”, “our” or “us”).
This Privacy Policy has been developed to clearly define our ongoing commitment to protecting the privacy rights of our clients and Rethink CPA personnel. Certain of the practices discussed in this Privacy Policy reflect requirements set out in Canadian federal and/or provincial privacy legislation. Our policy is to at all times adhere to the requirements of applicable law and professional responsibilities, including the following 10 principals which reflect the standards prescribed by the Personal Information Protection and Electronic Documents Act (Canada).
For purposes of this Privacy Policy, the term “personal information” means information about an identifiable individual, as more specifically defined by applicable privacy legislation.
Principle 1 – Accountability
Rethink CPA is accountable for all personal information in our possession or control. This includes any personal information that we receive directly, for example, from individual clients, Rethink CPA personnel and when you use our website www.rethinkcpa.ca. This also includes any personal information that we may receive indirectly, for example, through corporate and government clients. We have established policies and procedures aimed at protecting the personal information of our clients and personnel. We have appointed a Privacy Officer to oversee privacy issues for Rethink CPA. We have also educated Rethink CPA personnel about our Privacy Policy and their role in protecting the personal information of our clients and personnel. If you have questions about our privacy practices, you may contact our Privacy Officer at info@rethinkcpa.ca or at (905) 731-8108.
Please be aware that our website www.rethinkcpa.ca may contain embedded content and links to other sites that are not governed by this Privacy Policy. We encourage users to review the privacy policy of these external sites before disclosing any personal information.
Principle 2 – Identifying Purposes
Client Personal Information
In most instances, we will collect, use or disclose personal information about clients only for the purpose of providing professional services.
Client personal information may also be collected, used or disclosed internally and to our affiliates for the purpose of compliance with our policies and processes, in the performance of quality reviews, or in order to allow us to offer services or products that may be of interest to clients.
We may also collect, use or disclose personal information about clients and prospective clients for the purpose of sending news and information updates or invitations to events hosted or sponsored by Rethink CPA.
In accordance with professional standards, if a client is an assurance client, personal information may be shared with the Rethink CPA assurance engagement team and other Rethink CPA personnel so that it may be used in the assurance engagement.
You can withdraw your consent to the use and disclosure of your personal information for marketing purposes by contacting our Privacy Officer.
Rethink CPA Personnel Personal Information
We collect, use and disclose personal information about Rethink CPA personnel in order to pay them, to comply with laws, regulations and professional standards, to provide them with benefits, to administer performance management tools, and generally to establish, manage or terminate the employment relationship.
We may also collect, use or disclose employee personal information to develop business metrics and analytics, and to evaluate the effectiveness of our human resource policies and programs.
We also collect, use and disclose personal information from individuals seeking employment with Rethink CPA for the purpose of evaluating their application.
At the time that we collect personal information, we will inform our personnel of the reasons why we require such information, what use will be made of it, and with whom it may be shared, except where we are permitted or required by law to collect, use or disclose personal information without providing such notice.
Principle 3 – Consent
Client Personal Information
The terms and conditions of every Rethink CPA professional services engagement are documented in an Engagement Letter. These terms and conditions include a discussion about how we may collect, use and disclose client personal information. By signing the Engagement Letter, the client is providing their consent to the collection, use and disclosure of personal information described in the terms and conditions.
Rethink CPA Personnel Personal Information
Forms and applications used to provide human resources-related services to Rethink CPA personnel will describe the purposes for which their personal information is required and to whom it will be disclosed.
Employment candidates will also be advised of the purposes for which their personal information is being collected, used and disclosed.
Clients always have the option not to provide their consent to the collection, use and disclosure of their personal information, or to withdraw their consent at a later stage, subject to contractual and legal restrictions and reasonable notice. Where a client chooses not to provide us with permission to collect, use or disclose their personal information, we may not be able to provide, or continue to provide, the client with our services.
Where an employee or candidate for employment chooses not to provide us with permission to collect, use or disclose their personal information, we may not be able to employ them, continue to employ them or to provide them with benefits.
Principle 4 – Limiting Collection
We will limit the collection of personal information to that which is reasonably required to provide our services and to operate our business. We will only collect personal information by fair and lawful means.
Principle 5 – Limited Use, Disclosure and Retention
Use and Disclosure of Personal Information
We will not use or disclose personal information for purposes other than those for which it was collected, except with the consent of the individual or as required or permitted by law.
For example, we may use and disclose personal information without consent:
- for the purpose of acting in respect of an emergency that threatens the life, health or security of an individual, including steps taken under our pandemic policies;
- to comply with a subpoena, a warrant or an order made by a court or other body with appropriate jurisdiction or to comply with rules of conduct required by regulatory bodies;
- to a government institution that has requested the information, identified its lawful authority, and has indicated that disclosure is for the purpose of enforcing, administering, carrying out an investigation, or gathering intelligence relating to any federal, provincial or foreign law, or to national security or the conduct of international affairs; and
- to an investigative body or government institution on our initiative when we believe the information concerns a breach of an agreement, or a contravention of a federal, provincial, or foreign law, or we suspect the information relates to national security or the conduct of international affairs.
Retention of Personal Information
In compliance with professional standards, we keep a record of the work performed by Rethink CPA personnel. This record, or “working papers”, may include personal information. Working papers are safeguarded against inappropriate access, as discussed in Principle 7 below.
We retain personal information about current and past Rethink CPA personnel in accordance with employment laws and standards.
Personal information collected from individuals seeking employment with Rethink CPA will be retained for 12 months so that we may contact the applicant about other positions that may also be of interest.
Principle 6 – Accuracy
We will endeavour to ensure that personal information will be as accurate, complete, and up-to-date as is necessary to fulfil the purposes for which it is to be used. We will not routinely update personal information, unless this is necessary to fulfil the purposes for which the information was collected.
In order to provide clients with a professional level of service and Rethink CPA personnel with appropriate benefits, individuals are encouraged to advise us of any changes to their personal information.
Clients are encouraged to contact their engagement partner to update their personal information.
Rethink CPA personnel and employment candidates should contact our human resources team should they need to update their personal information.
Principle 7 – Safeguards
Rethink CPA will take reasonable measures to protect against loss, misuse and alteration of the personal information under our control. Personal information is stored in secure physical environments that are not available to the public (e.g. restricted access premises, locked rooms and filing cabinets). To prevent unauthorized electronic access to personal information, any information that is stored in electronic form is protected in a secure electronic environment (e.g. passwords and encryption).
We are responsible for personal information that we transfer to third party service providers for reasons such as administrative services, where the third parties do not make any independent use of the personal information. We will use contractual or other means to require such parties to commit to protecting personal information to a level comparable to that provided by Rethink CPA. These third-party service providers are prohibited from using personal information except for the specific purpose(s) for which we supply it to them.
Principle 8 – Openness
The current version of our privacy policy is available in its entirety at www.rethinkcpa.ca or by contacting our Privacy Officer at info@rethinkcpa.ca or at (905) 731-8108.
Principle 9 – Individual Access
Upon request, Rethink CPA will advise individuals of what personal information we have in our possession or control about them, what it is being used for, and to whom and why it has been disclosed, except where access is not permitted or required by law.
Personal information files are maintained in our offices or on our servers (or those of our service providers) and are accessible by authorized personnel, agents and mandataries who require access in connection with their job responsibilities.
Clients have the right to review and obtain a copy of their personal information on record in our individual offices by contacting the Privacy Officer.
Rethink CPA personnel have the right to review and obtain copies of their personal information on record by contacting our human resources team.
The right to access personal information is subject to certain legal restrictions and we will take reasonable steps to verify an individual’s identity before providing access.
Principle 10 – Challenging Compliance
All inquiries about this Privacy Policy should be directed to our Privacy Officer. We will inform individuals who make inquiries or lodge complaints about our complaint procedures. We will investigate and attempt to resolve all complaints. If a complaint is found to be justified, we will take appropriate measures, including, if necessary, amending our policies and practices.
Protecting the privacy of our clients and personnel is important to us. If you have any questions or concerns about your privacy and our role in protecting it, please contact our Privacy Officer at info@rethinkcpa.ca or at (905) 731-8108.
Last Revised: December 2020
