Levy Pilotte, LLP (“LP”) respects the privacy rights of its clients. We have always taken very seriously our responsibility in handling confidential client information, including personal information, which is covered by the Canada's Personal Information Protection and Electronic Documents Act ("PIPEDA"). We have developed this Privacy Policy to clearly define our commitment to protect privacy rights. It clearly sets out the principles and procedures that LP follows in meeting its privacy commitments to its clients and complying with the requirements of federal and provincial privacy legislation.
Principle #1 -LP is accountable for personal information in its possession or control.
LP is accountable for all personal information in its possession or control. This includes any personal information that LP received directly from clients who are individuals, or indirectly through clients that are organizations (e.g. corporations, government entities, not-for-profit organizations).
LP has:
1. Established and put into effect policies and procedures aimed at properly protecting personal information;
2. Educated its partners and employees regarding its privacy policy and their roles and responsibilities in keeping personal information private; and
3. Appointed its Chief Privacy Officer to oversee privacy issues at LP.
If you have any questions about LP's privacy policies and practices, LP's Privacy Officer can be reached by email at
privacy@levypilotte.com , by phone, 514-487-1566 or by letter to:
Levy Pilotte, LLP
5250 Decarie Blvd., 7th floor
Montreal, QC
H3X 3Z6
Principle #2 -LP identifies the purposes for which it collects personal information from clients before it is collected.
LP collects personal information from clients and uses and discloses such information, only to provide the professional services that the client has requested. The types of information that may be collected for this engagement and the purposes for which it is collected, are set out in under Principles 3 and 4 of this privacy statement.
Principle #3 –LP obtains a client's consent before collecting personal information from that client.
LP collects personal information about you only when you voluntarily provide it. The engagement letter for professional service engagements sets out your responsibility to obtain any consent required under applicable privacy legislation, for collection, use and disclosure to us of personal information. By signing the engagement letter you are formally acknowledging this responsibility and you are consenting to the collection, use, and disclosure of personal information required, if any, as part of completing the engagement, in accordance with the terms and conditions of this Privacy Policy.
The form of consent we seek, including whether it is express or implied, will depend on the sensitivity of the personal information and the reasonable expectations you might have in the circumstances.
You may withdraw your consent at any time, at which point LP will inform you of the implications of withdrawing your consent.
The information we collect, which may include personal information, will include at least some of the following:
- Contact information (such as name, title,
business name, business and home addresses,
telephone numbers, etc.);
- Personal identification numbers (e.g. social insurance
number); and
- Personal financial information
Principle #4 -LP limits the amount and type of personal information it collects, and such information is collected by fair and lawful means.
LP limits the collection of personal information to that which is required to provide professional services and operate our business.
Principle #5 -LP uses or discloses personal information only for purposes for which it has consent or as required by law. LP retains personal information only as long as necessary to fulfill these purposes.
LP will only use the personal information provided when we have your consent. If we intend to use the information for a purpose not previously identified to you, we will obtain your consent.
However, we may use or disclose personal information without consent:
- In respect of an emergency which threatens life,
health or security of an individual, or to comply with
a subpoena, a warrant, a court order, or to comply
with the rules of professional conduct required by
regulatory bodies, or
- To a government department or agency that has
requested the information, identified its lawful
authority and indicated that disclosure is for
enforcing or administering federal or provincial
law.
As part of our relationship with you, we like to keep you informed of changes in accounting, tax, and other matters affecting you and/or your business, as well as services and products we offer. From time to time we will communicate this information to you in the form of newsletters and mailings, either by hard copy or email communication. Should you not wish to continue to receive this information please advise the Privacy Officer or your engagement partner. If you do not notify us, we will consider that you have consented to our continued communication with you as in the past.
LP will retain working paper files and other files, both of which may contain personal information, for as long as necessary to fulfill the intended purpose(s) and to comply with applicable laws and regulations.
Principle #6 -LP endeavors to keep accurate, complete, and up-to-date personal information in its possession or control, to the extent required to meet the purposes for which it was collected.
Clients are encouraged to contact LP's engagement partner in charge of providing service to them to update their personal information that may be relevant to the services LP is providing.
Principle #7 -LP protects the privacy of personal information in its possession or control by using security safeguards appropriate to the sensitivity of the information.
LP will take all commercially reasonable steps and generally accepted information security techniques to ensure that personal information is protected from loss and unauthorized access.
Partners, employees, or representatives of LP are authorized to access personal information only to the extent required for completion of client assignment and quality control responsibilities.
For files or other materials containing personal information entrusted to a third-party service provider, LP obtains appropriate assurance to affirm that the level of protection by the third party is equivalent to that of LP.
Principle #8 -LP is open about the procedures it uses to manage personal information.
Principle #9 -LP responds on a timely basis to requests from clients about their personal information that LP possesses or controls.
Individual clients of LP have the right to contact the engagement partner in charge of providing service to them in order to obtain access to their personal information. LP will respond to any questions and complaints relating to privacy. We will investigate and attempt to resolve the matter within 30 days. Questions and complaints should be forwarded to LP's Privacy Officer.
Principle #10 -Clients may challenge LP's compliance with its Privacy Policy.
LP has policies and procedures to receive, investigate, and respond to client's complaints and questions relating to privacy.
To challenge LP's compliance with its Privacy Policy, clients are asked to provide a written letter to LP's Privacy Officer. LP's Privacy Officer will ensure that a complete investigation of a client complaint is undertaken and will report the results of this investigation to the client, in most cases, within 30 days.
October 2004