The following is an outline of the ten underlying Principles in the Personal Information Protection and Electronics Documents Act (PIPEDA).
Principle #1 Accountability
- The firm is accountable for all personal information in its possession or control. This includes any personal information that the firm received directly from clients who are individuals, or indirectly, through clients that are organizations such as corporations, government entities or not-for-profit organizations.
- The firm has:
- Established and put into effect policies and procedures aimed at properly protecting personal information;
Principle #2 Identifying Purposes
- The firm collects personal information from our clients and uses and discloses such information, only to provide the professional services that our clients have requested.
Principle #3 Consent
- We will not collect, use or disclose your personal information without your consent.
- Such personal information could include:
- Home and business addresses;
- Home and business telephone numbers;
- Personal identification numbers (e.g. social insurance number, credit card numbers);
- Financial information (credit ratings, payroll information, personal indebtedness)
- Personnel information;
- Other personal information.
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.
Principle #5 Limited Use, Disclosure and Retention
- The firm uses or discloses personal information only for purposes for which it has consent, or as required by law. The firm retains personal information only as long as necessary to fulfill those purposes.
- As required by professional standards, rules of professional conduct and regulations, 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 paper files and other files containing, for example, copies of personal or corporate tax returns are retained for the time period required by law and regulation or indefinitely for active clients.
- 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 employees 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 organization 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 regulations, or contract, have the right of access to the firm's files for inspection purposes.
- 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.
Principle #6 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 #7 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.Restricted access 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 #8 Openness
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.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 #10 Challenging Compliance