Privacy Policy

Privacy Policy

An organization entrusted with personal information about its clients and employees has a responsibility to protect the privacy of that information. Clark & Horner LLP takes this responsibility very seriously. Clark & Horner LLP is committed to maintaining the privacy of personal information provided by its clients and protecting all personal information in its possession or control.

Clark & Horner LLP has established a Privacy Policy to protect the privacy rights of its clients, employees and others. This policy relates to the collection, use and disclosure of personal information by the firm, its partners and employees. Our privacy policy is based on the ten principles articulated in the Personal Information Protection and Electronic Documents Act (“PIPEDA”) which came into law on January 1, 2004.

Principle 1 – Accountability

Clark & Horner LLP is accountable for all personal information in our possession or control. This includes any personal information that we receive directly from individual clients or indirectly, for example, through corporate clients. We have established policies and procedures aimed at protecting personal information. We have appointed a Privacy Officer to oversee privacy issues for Clark & Horner LLP. We have also educated our partners and employees about our Privacy Policy and their role in protecting personal information. Any questions about our privacy practices can be directed to our Privacy Officer as follows:

Privacy Officer
Clark & Horner LLP
1 Adelaide St. East
Suite 2601, P.O. Box 181
Toronto, ON
M5C 2V9
416-861-0431
email: privacy@clarkandhorner.com

Principle 2 – Identifying Purposes

Clark & Horner LLP will identify the purposes for which personal information is collected at or before the time it is collected. The purposes for which information is collected, used or disclosed by Clark & Horner LLP must be those that a reasonable person would consider appropriate in the circumstances.

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Principle 3 – Consent

Clark & Horner LLP will obtain the consent of the individual for the collection, use or disclosure of personal information, except where not required to do so by law. Clark & Horner LLP will ensure the individual is advised of the purposes for which the personal information is used or disclosed. The form and manner of obtaining consent may vary from express written consent to implied consent, depending on the circumstances and the type of information.

Individuals may withdraw their consent at any time, subject to legal or contractual restrictions, by providing reasonable notice to Clark & Horner LLP. The firm will inform the individual of the implications, if any, of such withdrawal.

Principle 4 – Limiting Collection

The firm collects only that personal information required to perform its professional services and operate its business, and such information is collected by fair and lawful means, and for purposes that a reasonable person would consider appropriate in the circumstances.

Principle 5 – Limiting Use, Disclosure and Retention

Clark & Horner LLP 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 by law.

The firm uses the information collected under this Policy to perform services within the scope of our engagement and to inform our clients through various communication channels about new services or to provide information that may be of interest, such as changes in the law, changes in accounting practices, or professional and business developments. Any clients wishing not to receive such information may opt out by providing notice to our Privacy Officer.

Clark & Horner LLP does not disclose the personal information of our clients to any third party to enable them to market their products or services. Under certain circumstances, our clients’ personal information will be disclosed, for example:

• If a third party is engaged to provide services to us;

• Where it is necessary to establish or collect payment;

• If the information is already publicly known.

Whenever our clients’ personal information is disclosed to third parties for the purposes the third parties providing services to us, these parties are required to maintain levels of confidentiality and security that are equivalent to our own practices.

The firm retains personal information only as long as necessary to fulfill those purposes. Personal information that is no longer required is discarded or destroyed using methods that protect the privacy of our clients.

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Principle 6 – Accuracy

Clark & Horner LLP 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. The firm will not routinely update personal information, unless this is necessary to fulfill the purposes for which the information was collected. If personal information changes, relevant details should be provided to the firm.

Principle 7 – Use Appropriate Safeguards

Clark & Horner LLP protects the privacy of personal information in its possession or control by using security safeguards appropriate to the sensitivity of the information.

Principle 8 – Openness

The firm will make readily available to individuals specific information about its policies and practices relating to the management of personal information. All enquiries about this Privacy Policy or the firm’s personal information management practices are to be referred to the Privacy Officer.

Principle 9 – Individual Access

The firm responds on a timely basis to requests from clients about their personal information which the firm possesses or controls. Upon request, Clark & Horner LLP will inform an individual of the existence, use and disclosure of his or her personal information and provide access to that information, except where access is not required by law.

Principle 10 – Challenging Compliance

Clark & Horner LLP will respond to individual complaints and questions relating to privacy. We will investigate and attempt to resolve all complaints.

To question compliance with this Policy, concerns should be forwarded in writing to our Privacy Officer. The Privacy Officer will ensure that a complete investigation of all complaints has been undertaken and findings reported, in most instances, within 30 days.