Privacy Policy

Introduction

The Campanella Group collects, uses and discloses personal information in the possession of, or under the control of its clients to the extent required to fulfill its professional responsibilities and operate its business. The firm is committed to maintaining the privacy of personal information provided by its clients and protecting all personal information in its possession or control. This Privacy Policy sets out the eleven principles and procedures that the firm follows in meeting its privacy commitments to its clients and complying with the requirements of federal and provincial privacy legislation.

Principle #1 – ACCOUNTABILITY

The firm is accountable for all personal information in its possession or control. This includes any personal information that the firm receives directly from clients who are individuals, or indirectly, through clients that are organizations (e.g., corporations, government entities, not-for-profit organizations).

The firm has:

• established and put into effect policies and procedures aimed at properly protecting personal information;
• educated its partners and employees regarding its privacy policy and their role and responsibilities in keeping personal information private; and
• appointed its Chief Privacy Officer to oversee privacy issues at the firm.

If you have any questions about the firm’s privacy policies and practices, the firm’s Privacy Officer can be reached by email at info@campanellagroup.com, by phone at 647-699-5718 or by letter addressed to 1670 North Service Rd E #101, Oakville, ON L6H 7G3, Attention: Privacy Officer.

The firm identifies the purposes for which it collects personal information from clients before it is collected.

The firm 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 under Principles 3 and 4 of this privacy statement.

Principle #2 – IDENTIFYING PURPOSES

The firm identifies the purposes for which it collects personal information from clients before it is collected.

The firm 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 under Principles 3 and 4 of this privacy statement.

We collect Your IP address for the purposes of system administration, including diagnosis of problems with the firm’s server and administration of the firm’s website. All information collected will be done in a fair and lawful manner.

Our website does use cookies. A “cookie” is information that our website places on your hard disk so that it can remember information about you the next time you visit our website (so that we can provide you with personalized services), measure traffic patterns (so that we can learn which browsers are commonly used), and estimate audience size (so that we can know which visitors have seen particular parts of the website). You can still navigate through our website without the use of cookies, but your access and the functionality of the website may be limited.

Principle #3 – ANTI-SPAM POLICY

Anti-Spam Policy

• Our Anti-Spam Policy permits us to send you email and other electronic messages only if we have your Express or Implied consent.
• You may withdraw your consent to receive any emails and other electronic messages from us at any time.
• If you provided your express consent to us to receive our emails and other electronic messages, you agreed that we may send email and other electronic messages to you for any of the reasons listed below under “How We Use Your Information”.
• All emails and electronic messages sent to you will be compliant with Canada’s Anti-spam legislation and will include: our name, mailing address, telephone number, our website address, a link where you can unsubscribe from our messages, the email address of a person you can contact about our messages, and, as applicable, the name or business name of the person sending the messages on our behalf and a statement indicating who the sender is and on whose behalf the message is sent.

How we use your information

If we have your consent to contact you with electronic messages, we may send you electronic messages in order to:

• Provide you with information you have requested from us
• To share industry news and information with you
• Offer you services
• To solicit you to purchase services, including through Controlled Electronic Messages
• To gather information from you to improve our services
• To communicate with you in general

Principle #4 – CONSENT

The firm obtains a client’s consent before collecting personal information from that client.

The Terms and Conditions of every professional services engagement are documented in each Engagement Letter. These Terms and Conditions include an explanation about how The Campanella Group may use and disclose your personal information. By signing the engagement letter, you will be providing your consent to the collection, use and disclosure described in the Terms and Conditions.

Such personal information could include:

• home addresses
• home telephone numbers
• personal identification numbers (e.g., social insurance numbers, credit card numbers)
• financial information (credit ratings, payroll information, personal indebtedness)
• personal information (e.g., employment history, references to criminal records)
• information linked to the type of client, for example:
• information in medical records (with respect to organizations such as hospitals or medical practices)
• information related to race, religion, sexual preference, receipt of welfare or subsidized housing (with respect to various types of not-for-profit and government entities)
• source data in claims and in-force databases (with respect to insurance companies)
• tenant information (with respect to residential leasing companies)
• personal information of customers, employees and others having dealings with the company

Employment candidates will also be advised of the purposes for which their personal information is being collected and you will be provided an opportunity to consent to the collection, use and disclosure as described.

What happens if you choose not to give us your consent? What if you withdraw your consent at a later date?

You always have the option not to provide your consent to the collection, use and distribution of your personal information, or to withdraw your consent at a later stage. Where a client chooses not to provide us with permission to collect, use or disclose personal information, we may not have sufficient information to provide you with our services. Where a candidate for employment chooses not to provide us with permission to collect, use or disclose personal information we may not be able to employ you.

Principle #5 – LIMITING COLLECTION

The firm collects only that personal information required to perform its professional services and to operate its business, and such information is collected by fair and lawful means.

The partners and staff involved in an engagement need access to some or all of the types of personal information, noted under principle 3 above, to obtain evidence to support the firm’s opinion on the company’s financial statements or to facilitate the completion of special projects as engaged by the client. Such personal information will be a significant component of various transactions and events affecting the financial statements that will be subjected to confirmation, testing, analyses, and such other procedures as the firm considers necessary to perform an audit in accordance with generally accepted auditing standards or a special project.

Principle #6 – LIMITING USE, DISCLOSURE & RETENTION

The firm uses or discloses personal information only for purposes for which it has consent, or as required by law.

We may also disclose personal information without consent:

• 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. It is important to note that accounting firms are not protected by client/solicitor privileges.
• to a government institution that has requested the information, identified its lawful authority, and indicates that disclosure is for the purpose of enforcing, carrying out an investigation, or gathering intelligence relating to any federal, provincial or foreign law; or suspects that the information relates to national security or the conduct of international affairs; or is for the purpose of administering any federal or provincial law.
• 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.

As required by professional standards, rules of professional conduct and regulation, the firm documents the work it performs in records, commonly called “working paper” files. Such files may include personal information obtained from a client. Working papers are safeguarded against inappropriate access, as discussed under Principle “8”.

We also use it to enable us to provide you through various channels with information that we believe are of interest to you. This includes such matters as:

• new services we provide,
• conferences and other professional development courses we hold,
• notice of changes in the law or accounting practices that may be of interest to you, and
• other professional or business developments.

If you do not wish to receive such information, you may opt out by sending an email to info@campanellagroup.com or by advising your Audit and Accounting contact and we will discontinue sending you information other than in regard to your account.

The firm retains personal information only as long as necessary to fulfill its purposes.

Working paper files and other files containing, for example, copies of personal tax returns are retained for the time period required by law and regulation or for the time period as specified in the firm’s retention of client information policy.

The firm regularly and systematically destroys, erases, or makes anonymous personal information no longer required to fulfill the identified collection purposes, and no longer required by laws and regulations.

The personal information collected from a client during the course of a professional service engagement may be:

shared with the firm’s personnel participating in such engagement;

• disclosed to partners and team members within the firm to the extent required to assess compliance with applicable professional standards and rules of professional conduct, and the firm’s policies, including providing quality control reviews of work performed;
• provided to members of the organization’s audit committee and board of directors, and others in the company that might not otherwise have access to the information, in the course of communicating aspects of the results of our audit; and
• provided to external professional practice inspectors (e.g., representatives of the Canadian Public Accountability Board, or a provincial institute of chartered accountants), who by law, professional regulation, or contract have the right of access to the firm’s files for inspection purposes.

Principle #7 – ACCURACY

The firm endeavours 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.
Individual clients are encouraged to contact the firm’s engagement partner in charge of providing service to them to update their personal information.

Principle #8 – SAFEGUARDS

The firm protects the privacy of personal information in its possession or control by using security safeguards appropriate to the sensitivity of the information.

Physical security (e.g., restricted access, locked rooms and filing cabinets) is maintained over personal information stored in hard copy form. Partners and employees are authorized to access personal information based on client assignment and quality control responsibilities.

Authentication is used to prevent unauthorized access to personal information stored electronically. Encryption is used to prevent unauthorized access to personal information received or sent over the Internet.

For files and other materials containing personal information entrusted to a third party service provider (e.g., a provider of paper based or electronic file storage), the firm obtains appropriate assurance to affirm that the level of protection of personal information by the third party is equivalent to that of the firm.

Principle #9 – OPENNESS

The firm is open about the procedures it uses to manage personal information.

Up-to-date information on the firm’s privacy policy can be obtained from the firm’s Privacy Officer (see contact information under principal 1).

Principle #10 – INDIVIDUAL ACCESS

The firm responds on a timely basis to requests from clients about their personal information which the firm possesses or controls.

Individual clients of the firm have the right to contact the engagement partner in charge of providing service to them and obtain access to their personal information. Similarly, authorized officers or employees of organizations that are clients of the firm have the right to contact the engagement partner in charge of providing service to them and obtain access to personal information provided by that client. In certain situations, however, the firm may not be able to give clients access to all their personal information. The firm will explain the reasons why access must be denied and any recourse the client may have, except where prohibited by law.

Principle #11 – CHALLENGING COMPLIANCE

Clients may challenge the firm’s compliance with its Privacy Policy.

The firm has policies and procedures to receive, investigate, and respond to clients’ complaints and questions relating to privacy.

To challenge the firm’s compliance with its Privacy Policy, clients are asked to provide an email message or letter to the firm’s Privacy Officer (see contact information under principal 1 above). The firm’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.