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Shimmerman Penn LLP – Privacy Policy

Shimmerman Penn, LLP (SPLLP) respects the privacy rights of our clients, as well as our partners, principals and employees and has always been committed to protecting all personal information in our possession or control. We have adopted the following Privacy Policy to guide how we collect, use and disclose the personal information we acquire in the course of fulfilling our professional responsibilities and operating our business.

While SPLLP has always taken the privacy and confidentiality of our clients, our partners, our principals and our employees very seriously, we have developed this Privacy Policy to clearly define our ongoing commitment to protecting privacy rights. Certain of the practices discussed in the Policy reflect requirements set out in both federal and provincial privacy legislation that came into effect on January 1, 2004. Our goal is to respond to the requirements of the law, and to be responsive to our clients, as well as partners, principals and employees who expect us to demonstrate our commitment to respecting their privacy and protecting their personal information.

Principle 1 – We are accountable for the personal information in our possession.

SPLLP is accountable for all personal information in our possession or control. This includes any personal information that we receive directly, for example, from individual clients, partners, principals and employees, as well as individuals’ personal information that we may receive indirectly, for example, through corporate and government clients. We have established policies and procedures aimed at protecting personal information. We have appointed a Privacy Officer to oversee privacy issues for SPLLP. The Privacy Officers are Amir Fathollahzadeh and Amanda Duvall. We have also educated our partners, principals and employees about our Privacy Policy and their role in protecting your personal information. If you have questions about our privacy practices, you are free to contact our Privacy Officer at 416-964-7200.

Principle 2 – SPLLP will inform you why we are collecting your personal information when the information is collected.

Client Information

In most instances, SPLLP will collect, use or disclose personal information only to provide professional services to you. Each engagement letter includes an explanation of why we require information, what use will be made of it and with whom it may by shared in order to provide our professional services.

Your personal information may be disclosed internally and with other affiliates of SPLLP for the purpose of determining compliance with applicable professional standards, SPLLP internal policies, or in the performance of quality reviews. Personal Information may also be shared internally and with affiliates of SPLLP in order to allow us to offer services or products that may be of interest to you.

In accordance with professional standards, if you are an audit or assurance client, personal information may be shared with the SPLLP audit or assurance engagement team and other SPLLP personnel so that it may be used in the audit or assurance engagement.

Employee Information

We also collect personal information from our partners, principals and employees in order to pay them, comply with laws, provide them with benefits, administer performance management tools and to improve on programs, policies and employee relations. In certain cases, we may also aggregate partner, principal and employee personal information to provide business metrics and evaluate the effectiveness of our human resource programs. In these circumstances, the information is not identifiable with any individual.

We also collect personal information from individuals seeking employment with SPLLP.  When we collect personal information, we inform you of the reasons why we require such information, what use will be made of it and with whom it may be shared.

Principle 3 – SPLLP will collect, use or disclose personal information about you only with your informed consent. You can request to see what information we have collected about you and/or request for it to be updated or deleted at any time.

How Will We Ask for Consent?

Client Personal Information
The Terms and Conditions of every professional services engagement are documented in each Engagement Letter. These Terms and Conditions include a discussion about how SPLLP 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.

Partner, Principal and Employee Information
Forms and applications used to provide human resources-related services to partners, principals and employees will describe the purposes for which personal information is required and with whom it will be shared, and will allow for you to consent to the collection, use and disclosure as described.
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 client chooses to withdraw their consent, they should do so in writing and direct their request to the Privacy Officer. Where a partner, principal, employee or 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 or to provide you with benefits.

Principle 4 – SPLLP limits the amount and type of personal information we collect.

We will limit, where possible, the collection of client and employee personal information to that which is required to provide our services or operate our business.

Principle 5 – SPLLP will use and disclose your personal information only for the purposes for which we have your consent. We will keep personal information only as long as necessary to accomplish these purposes.

Use of Personal Information

If we intend to use your personal information for a purpose not previously identified to you, we will obtain your prior consent. However, we may use personal information without consent where for the purpose of acting in respect of an emergency that threatens the life, health or security of an individual. 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
  • 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.

Retention of Personal Information

In compliance with professional standards, we keep a record of the work performed by us. This record or “working papers” may include personal information. Working papers are safeguarded against inappropriate access, as discussed under Principle “7”.

SPLLP retains personal information about current and past partners, principals and employees in accordance with employment laws and standards.

Personal information collected from individuals seeking employment with SPLLP will be retained by SPLLP indefinitely so that SPLLP may contact you about other positions that may also be of interest to you.

Principle 6 – SPLLP will endeavor to keep accurate the personal information in our possession or control.

In order to provide you with a professional level of service and with appropriate benefits, the personal information that we collect about you must be accurate, complete and current. From time to time, you may be asked to update your personal information. You are encouraged to advise us of any changes to your personal information that may be relevant to the services we are providing to you.

Clients are encouraged to contact their engagement partner to update their personal information.

Employees and candidates should contact the personnel partner should they need to update their personal information.

Principle 7 – SPLLP protects your personal information with safeguards appropriate to the sensitivity of the information.

We protect your personal information by using physically secure facilities, industry standard security tools and practices, and clearly defined internal policies and practices. Security measures are in place to protect the loss, misuse and alteration of the information under our control. Personal information collected is stored in secure operating environments that are not available to the public (e.g. restricted access premises, locked rooms and filing cabinets). To prevent unauthorized electronic access to personal information, we maintain information collected in a secure environment.

Principle 8 – SPLLP will be open about the procedures used to manage your personal information.
The most up-to-date version of our privacy policy is available in its entirety at www.spllp.com or by contacting our Privacy Officer at 416-964-7200.

Principle 9 – At your request, SPLLP will advise you of what personal information we have in our possession or control about you, what it is being used for, and to whom and why it has been disclosed. You can request to have your information updated or deleted at any time.

As a client you have the right to review and obtain a copy of your personal information on record in our office by contacting your engagement partner.

As a partner, principal or employee, you also have the right to review and obtain copies of your personal information on record by contacting the personnel partner.

In most instances, you will receive a response to your request within 30 days. If you have any concerns about the access provided to you, you are encouraged to contact our Privacy Officer at 416-964-7200.

Principle 10 – You may challenge SPLLP’s compliance with this Privacy Policy.

SPLLP will respond to individual complaints and questions relating to privacy. We will investigate and attempt to resolve all complaints.  To challenge compliance with this Policy, please forward your concerns in writing to our Privacy Officer. The Privacy Officer will ensure that a complete investigation of your complaint has been undertaken and will report their findings to you in most instances within 30 days.

Principal 11 – Collecting cookies on our website

We use Google Analytics to track visitors to our site. Google Analytics sets cookies on the spllp.com domain, although both services use cookies to track visitors.

The cookies themselves are stored on the user's device by the web browser. They are included in any web requests made by the browser to the domain for which they are set. In Google Analytics's case, it picks up those cookies and dispatches tracking events to Google which then cross-references against other means that they use for tracking that particular user.

For more information about Google analytics' use of cookies, visit their site here.

spllp.com also uses ShareThis to facilitate social media sharing of our content. ShareThis does not store cookies. For more information on their policy, click here.

 
Online Privacy Statement

As part of our commitment to privacy, Shimmerman Penn (SPLLP) have adopted the Online Privacy Statement.

We only use your personally identifiable information to respond to your requests and to provide you with information about SPLLP’s services, unless we obtain your permission to use your personal information for other purposes. If we intend to use your personal information to inform you about other SPLLP services, we will notify you and give you an opportunity to receive such communications.

If you visit our site to read or download information such as newsletters or articles, we do not track personal information. We may collect information which is statistical only and not personally identifiable. We use this information about the number of visitors and their use of the site in aggregate form to make our site more useful and attractive to you.

The personal information you provide to us will be retained only for as long as necessary to fulfill the purposes for which the information was collected, or as required by law. We do not share personal information with third parties except as necessary to carry out our business or as required by law or other legal processes, and we never sell your personal information. Furthermore, personal data collected by SPLLP may be transferred to our affiliates where it is necessary to meet the purpose for which you have submitted the information.

In addition, SPLLP has technological and operational security policies and procedures in place to protect your personally identifiable information from loss, misuse, alteration or unintentional destruction. Our personnel who have access to the data have been trained to maintain the confidentiality of such information. SPLLP recognizes its responsibility for protecting the online privacy of your personal information. If you have questions or comments about our administration of your personal information, please contact our Privacy Officer at 416-964-7200.