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.
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.
Protection and Electronic Documents Act (“PIPEDA”) which came into law on January
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.
role in protecting personal information. Any questions about our privacy practices
can be directed to our Privacy Officer as follows:
Clark & Horner LLP
Dynamic Funds Tower
1 Adelaide St. East
Suite 2601, P.O. Box 181
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.
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:
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
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.
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
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
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.
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