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Privacy Principles A word about your privacy We respect and protect your privacy. The private information you share with us stays with us. However, we do provide or collect your personal information as is required by legislation to those to whom you have authorized us to release information. This would include various departments within Canada Customs and Revenue Agency, financial institutions or legal professionals you have asked us to deal with on your behalf. If you have privacy questions or concerns regarding your personal information, please contact our Privacy Officer by mail at: Allied House, 210 Oxford Street East, London, ON N6A 1T6. Introduction Allied Group is committed to keeping personal information accurate, confidential, secure and private. The Allied Group Privacy Principles are an embodiment of our commitment and apply to Allied Associates LLP Chartered Accountants, Allied Accounting & Tax Services Limited, Allied Financial Services Limited, and Allied Farm Services Limited. These Principles are based on the Personal Information Protection and Electronic Documents Act (PIPEDA). They describe how Allied Group subscribes to the principles of PIPEDA. A copy of the PIPEDA is available at www.privcom.gc.ca. These Principles describe how Allied Group will protect the privacy of personal information in its possession or control. The Principles do not apply to information about clients who carry on business as corporations, partnerships, or other forms of association. Allied Group does, however, protect the confidentiality of such information in accordance with the law and Allied Group’s own privacy policies. The Principles do apply to information about clients carrying on business as sole proprietorships. Changes to our Privacy Principles In order to keep our Principles up to date, we reserve the right to change them from time to time. Any changes will be effective 30 days following Allied Group providing you with notice. Notice of changes to our Privacy Principles may be distributed through client mailings, newsletters and/or posted on our web site. Accountability Allied Group is accountable for all personal information in its possession or control, including any personal information transferred to third parties for processing. We have established policies and procedures to comply with PIPEDA and have designated one or more persons accountable for compliance. Senior management will have ultimate accountability for protecting personal information. They have delegated the day-to-day management of procedures involving personal information to one or more persons. Allied Group’s Privacy Officer is responsible for overall personal information protection and compliance with PIPEDA. Each of our employees, partners, and contractors is responsible for maintaining the confidentiality and security of all personal information to which they have access. Our employees are trained to know and respect our Privacy Principles and compliance with our Principles and procedures for protecting personal information is a condition of their employment. The Allied Group has established procedures to protect the privacy of personal information; has established procedures to receive and respond to questions and complaints; gives public access to these Privacy Principles; and has trained Allied Group’s staff to understand and follow Allied Group’s procedures. Purposes of collecting information Allied Group believes that the responsible use of personal information collected is critical to its business objectives and reputation. We will identify the purposes of collecting personal information before or when consent is provided. It is the individual’s right to refuse permission for Allied Group to use personal information for any such other purpose. Personal information collected will be used to help identify new clients; determine the suitability of services for an individual or the eligibility of an individual for services; set up and manage services that meet the individual client’s needs; provide on-going services; and meet legal and regulatory requirements. Allied Group will be diligent in explaining purposes which are not as obvious as others. Obtaining consent Allied Group will obtain consent before or when it collects, uses or discloses personal information, and will make a reasonable effort to explain to individuals in plain language how personal information will be used or disclosed. We may collect, use or disclose personal information without the individual’s knowledge and consent, only in limited circumstances as permitted by law. Subject to certain legal or contractual restrictions and reasonable notice, an individual may refuse or withdraw consent at any time. Refusing or withdrawing consent for Allied Group to collect, use or disclose personal information could mean that Allied Group cannot provide the client with a service of value to the individual. Limiting collection Allied Group will collect personal information only for the purposes it has identified to the individual or as permitted by law using fair and lawful procedures. This collection will be limited to the minimum amount of information required for delivering a service or product as authorized under this Act or other regulatory Acts. Limiting use, disclosure & retention Allied Group will use or disclose personal information only for the reasons it was collected, unless consent is given to use or disclose it for another reason. We may disclose personal information without consent when required or permitted by law. Examples of such disclosures could include court or government orders, debt collection or demands from other parties who have a legal right to personal information, disclosure to legal representatives of Allied Group. In any of these circumstances however, Allied Group will protect the interests of its clients by making sure that any requests for disclosure comply with the laws under which they were issued. Each member firm of Allied Group may share minimal personal information (name, address, telephone number) in their possession or control, within the Allied Group in order to make individuals aware of other services available from Allied Group. Each member firm of the Allied Group secures and protects their clients’ personal and financial information from each other. This information is not shared with other member firms of the Allied Group unless signed consent is obtained from the client. For example, Allied Financial Services Limited does not have access to information contained in client files of Allied Associates LLP, unless explicit consent has been obtained from the client to release this information. Allied Group will destroy, erase or make anonymous any personal information no longer needed for identifying purposes or no longer required by law or legislative requirements. Maintaining accurate information Allied Group will make reasonable efforts to keep personal information in its possession and control accurate and current if the information is used on an on-going basis. We will rely on individuals to keep certain personal information relating to them accurate, complete and current. If an individual demonstrates that personal information relating to them is inaccurate, incomplete, out of date or irrelevant, we will revise or delete the personal information. Safeguarding personal information Allied Group will safeguard personal information in its possession or control from loss or theft and from unauthorized access, disclosure, duplication use or modification. The safeguards we employ to protect personal information will vary depending on the sensitivity, amount, format and storage of the personal information. Most personal information collected is stored electronically, and in recent paper records stored in client files. These files remain on site in our London head office and are only removed from the premises when client appointments are required to provide a service. On site security measures will include physical security, such as secure locks on filing cabinets, file rooms and restricted access; organizational security such as controlled clearance for building access, and controlled and limited access to relevant information; and electronic security such as passwords, personal identification numbers and encryption. Allied Group will inform employees regularly about our policies and procedures for protecting personal information and will emphasize the importance of complying with them. As a condition of employment, employees will be required to conform to our personal information policies and procedures. Personnel who have access to your personal information have been trained to maintain the confidentiality of such information. We will use care when disposing of or destroying personal information in order to prevent unauthorized access to information. Openness Allied Group will be open about the procedures used to manage personal information. By publishing these Principles, individuals have access to information about procedures used to maintain and protect their personal information. These Privacy Principles are available in paper format and on our web site at www.alliedgroup.ca We may make information about our procedures available in a variety of ways, depending on the nature of the services individuals are using and the sensitivity of the personal information. For information pertaining to privacy on line, please refer to our web site for the Allied Group Online Privacy Statement. Individual access An individual has the right to know, on request, what personal information about the individual Allied Group has in its possession or control, what the information is being used for, and to whom it has been disclosed. We have established procedures for responding to requests for access to personal information. Individuals must be specific about the personal information that may be in our possession or control. In some cases, Allied Group may not provide access to personal information that is in its possession or control. This may occur when providing access to personal information would be likely to reveal personal information about a third party; disclosing the information would reveal confidential commercial information; the personal information is protected by solicitor-client privilege; and/or the information is the result of arbitration or other formal dispute resolution process. We will not record in individual files when personal information was disclosed to third parties for routine purposes, such as reporting to Canada Customs and Revenue Agency. Recourse Individuals may challenge Allied Group’s compliance with these Privacy Principles if they feel there has been a misuse of their personal information. We have policies and procedures in place to receive, investigate and respond to individuals’ complaints and questions relating to privacy. Individuals are advised to direct their complaints in writing to the Privacy Officer. Allied Group will investigate all complaints and respond within 30 days of receipt of the complaint. If it finds a complaint is justified, we will attempt to resolve it. If necessary, we will modify our principles and procedures to ensure that other individuals will not experience the same problem. If individuals are not satisfied with the way Allied Group has responded to their complaint regarding their personal information, they should contact: The Office of the Privacy Commissioner of Canada, 112 Kent Street, Ottawa, ON K1A 1H3 or call toll free 1-800-282-1376
ALLIED GROUP Allied Accounting & Tax Services Limited Allied Associates LLP, Chartered Accountants Allied Financial Services Limited Allied Farm Services Limited
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Allied Associates LLP, Chartered Accountants
Allied Accounting & Tax Services Limited 1490 Richmond Street, Suite 200 | London, ON N6G 0J4 | Canada |
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