INTRODUCTION

Privacy is important to Segal GCSE LLP. This Privacy Policy informs you of the ways we ensure privacy and confidentiality of personal information.

PERSONAL INFORMATION PROTECTION AND ELECTRONIC DOCUMENTS ACT (PIPEDA)

The Personal Information Protection and Electronic Documents Act (PIPEDA) governs how all private sector organizations in Ontario handle personal information of clients, candidates, employees, and others. Personal information is defined as information that can identify an individual and information about an identifiable individual.

GENERAL DATA PROTECTION REGULATION (GDPR)

For any of our clients or partners with operations in Europe, we ensure we abide by the General Data Protection Regulation with respect to the transfer of data inside and outside of Europe.

WHAT INFORMATION WE COLLECT AND WHY

We need our clients to provide us with all the relevant facts and information related to our engagement. This information will include personal information about our clients and about other individuals with whom our clients conduct commercial transactions.

CONSENT FOR COLLECTION, USE, AND DISCLOSURE

Unless permitted by law, either before or when we collect personal information, we will obtain consent, explain how we intend to use the information, and will obtain consent if we wish to use personal information for any other purpose. We will limit the personal information we collect to what we need for the purposes for which we collected the information, and we will use the information only for those purposes. We do not sell any information about our clients or other individuals about whom we have obtained personal or other information. We only disclose personal information to others:

• When we have consent;
• When, on a confidential basis, the other person is our supplier or agent who assists us to represent our clients; or
• When we are required or permitted to do so by law or by the Chartered Professional Accountants of Ontario (“CPAO”) of the CPA Code of Professional Conduct.

PROTECTION OF INFORMATION

Our client files are accessible by all staff electronically and in hard copy. Every member of our firm has been trained on and is committed to our privacy policies and procedures to safeguard personal information.

In accordance with professional regulations, our client files must periodically be reviewed by provincial practice inspectors and by other firm personnel to ensure that we have adhered to professional and firm standards. File reviewers are required to maintain confidentiality of client information.

Our firm is a registrant with the Canadian Public Accountability Board (“CPAB”). Registration with these bodies is required in order to, after March 30, issue audit opinions for publicly listed companies in Canada CPAB requires under their terms of registration to have access to our client files and engagement personnel in the conduct of their practice review and oversight mandates. Accordingly, file information where requested by CPAB will be made available for review and staff and partners of our firm will provide information and where required, give testimony or evidence relating to engagement information and knowledge.

Such information would otherwise be restricted from disclosure under professional rules of confidentiality or under privacy legislation and firm policy. Information obtained from our files and personnel by CPAB may be referred or disclosed to other regulatory bodies and professional bodies which may in turn be used by them in investigations, disciplinary actions and where appropriate, legal or securities related proceedings.

SECURITY AND RETENTION

In recognition of our professional and legal obligations to protect our confidential client information, we have made arrangements to protect against unauthorized access, collection, use, disclosure, copying, modification, disposal, or destruction of personal information.

We will retain client personal information for a reasonable time period as required by the CPAO’s, CPA Code of Professional Conduct and the terms of our professional liability insurance policy. When no longer required, client personal information will be disposed of in a secured manner.

Our website is not secure. This is because we do not collect, use or disclose personal information through our website. We expressly warn and require individuals not to disclose personal information through our website. If an individual chooses to disclose personal information through our website, that individual does so at his/her own risk.

Our website may present links to other websites. Segal GCSE LLP is not responsible for how other parties, through the operation of these other websites, collect, use or disclose personal information. The use and/or privacy protection provided by the operator of a linked website is in no way subject to our firm’s privacy policies or practices.

REQUEST FOR ACTION AND CORRECTION

Individuals have the right to ask, in writing, for access to their own personal information in the custody or under the controls of our firm as permitted under PIPEDA. We will respond to any such requests in accordance with our obligations under PIPEDA. If we are not able to provide access to personal information we have about an individual, we will explain the reason why.

• The personal information is protected by solicitor-client privilege.
• Disclosure of the personal information would reveal confidential commercial information that could, in a reasonable person’s opinion, harm the competitive position of our firm.
• The personal information was collected for an investigation or legal proceeding that has not concluded, including any appeals (excluding CPAB requirements stated above).
• The information was collected by a mediator or arbitrator in conducting a mediation or arbitration where the mediator or arbitrator was appointed under a collective agreement, a law, or by a court.
• Disclosure could reasonably be expected to threaten the safety or physical or mental health of another individual.
• Disclosure could reasonably be expected to cause immediate or grave harm to the safety or to the physical or mental health of the individual who made the request.
• Disclosure would reveal personal information about another individual.
• Disclosure would identify the individual who has provided personal information about another individual and that individual does not consent to disclosure of his or her identity.

PIPEDA also allows individuals to request in writing for our firm to correct errors or omissions. While we will make every reasonable effort to keep personal information accurate, we will correct any factual error or omissions and, where we feel it is appropriate, inform other organizations to which we have disclosed the incorrect information. If we determine there is no factual error or omission, we will annotate the record with the record that a correction was requested but not made.

ACCOUNTABILITY

Segal GCSE LLP is responsible for the personal information under our control and has designated a Privacy Officer who is accountable for compliance with our Global Privacy Policy. We also require that comparable protection of personal information is in place with any third parties used by us to process such information. Questions can be directed to Segal GCSE LLP’s Privacy Officer as indicated below:

Privacy Officer
Segal GCSE LLP, Chartered Professional Accountants
10 York Mills Rd., Suite 700, Box 202
Toronto, Ontario M2P 2G4
Phone: 416 391 4499
Email: privacy@segalgcse.com
Website: www.segalgcse.com

Updated: September 2023