G&G PRIVACY POLICY
G&G Partnership, LLP (“G&G”) believes that it is important for you to know how we treat your personal information. Our Privacy Policy will explain why we collect personal information (information about the identifiable individual) about our clients and other individuals who interact with us and how we handle that information on our website and offline.
G&G takes the privacy and confidentiality of our clients, partners and 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 this Policy reflect requirements set out in both federal and provincial privacy legislations. G&G’s policy is to at all times adhere to the requirements of the law and our professional responsibilities, and to be responsive to our clients, partners and employees who expect us to respect their privacy and protect their personal information.
Personal information is information about an identifiable individual. It includes information such as age, income, opinions, home location and family. It does not include the name, title, business address or telephone number of an employee of an organization such as G&G or our corporate clients.
Types of Information We Collect
As you are aware, we may gather personal information from you in person, at our office, over the telephone, or by corresponding with you via mail or on the internet through the G&G website. In general, you can visit the G&G website without telling us who you are or revealing any personal information about yourself, unless you voluntarily choose to provide it.
The type of information we may collect about you depends on whether or not you are a client of G&G. The information we may collect includes your name, contact information, correspondence with us, comments/questions about our organization, and financial information required to perform our services for you. For current or prospective clients, we may collect additional information such as your date of birth, gender, languages spoken, language preference, place of residence, social insurance number, marital status and dependants. For clients engaged as a proprietor, partner or shareholder of a duly authorized incorporated company we may collect further information such as your firm name, names of partners, preferred areas of business and corporate information pertaining to its business number.
How We Use Your Personal Information
Typically, the personal information collected about you is used by G&G to confirm your identity, to communicate with you, to respond to your inquiries/comments, to fulfill the legal and legitimate business requirements of G&G and generally to provide you with the services you have requested. Each Engagement Letter includes an explanation of why G&G requires the information, what use will be made of it and with whom it may be shared in order to provide professional services.
For current and prospective clients, the personal information you provide is also used by G&G to prepare your personal income tax returns and allow us to discuss your affairs with Canada Revenue Agency, and any other institution or individual that you authorize us to contact and, to process financial transactions including payment of our fees and services.
We may also use your personal information to provide you with tailored information that we believe will be of interest to you (“targeted communications”). You may opt-in to such where an opt-in is offered or you can call 416-441-9292 extension 230 or by email at admin@ggca.com at any time to provide or withdraw your consent to such use and disclosure.
G&G may, from time to time, use personal information without consent for the purpose of acting in respect of an emergency that threatens the life, health or security of an individual, or as otherwise permitted by law including for the purpose of an investigation. We may also disclose personal information without consent as permitted or required by applicable federal and provincial privacy laws, including:
- 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 or 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.
- G&G is accountable for all personal information in our possession or control. We have established policies and procedures aimed at protecting your personal information.
How Will We Ask for Consent
The Terms and Conditions of every G&G professional services engagement are documented in each Engagement Letter. These Terms and Conditions include a discussion about how G&G may use and disclose your personal information. By signing the Engagement Letter, the client will be providing its consent to the collection, use and disclosure described in the Terms and Conditions.
What Happens if You Choose Not to Give Consent
G&G clients always have the option not to provide their consent to the collection, use and distribution of their personal information, or to withdraw their 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 continue providing the client with our services.
Sharing of Personal Information
G&G will not share your information with any individual, organization, or government without your written approval.
Retention of Personal Information
In compliance with professional standards, we keep a record of the work performed by G&G partners and employees. This record, or “working papers”, may include personal information and will be retained until such working papers are no longer reasonably required for legal, administrative, audit or regulatory purposes. G&G will destroy, erase or render anonymous personal information no longer required for the stated purposes or for any legal or legitimate business requirement.
Security Safeguards
G&G will protect 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 personal information under our control. Personal information is stored in secure 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, any information that is stored in electronic form is protected in a secure electronic and physical environment.
We are responsible for all personal information transferred to third parties for processing. We require third party processors to respect the confidentiality of personal information and all legal requirements under applicable Canadian federal and provincial privacy legislation, and to agree to contractual requirements that are consistent with this Privacy Policy. These third party processors are prohibited from using personal information, except for the specific purpose(s) for which we supply it to them.
G&G has developed a secure client portal, which is hosted in Canada. We encourage our clients to use this client portal to ensure that confidential information remains confidential. We cannot guarantee that confidential information transmitted by e-mail will remain confidential. If confidential information is transmitted to G&G via e-mail rather than secure portal, we recommend that these items are password protected and the password be provided to the partner or staff who the communication is intended for in a separate correspondence or by telephone.
Employee Access
All individual G&G employees who work with user’s personal or business data maintain strict confidentiality of all information. Furthermore, all employees must sign a confidentiality agreement binding them to uphold G&G privacy and confidentiality rules.
How You Can Protect Your Information
There are a number of measures you can take to protect yourself against fraud and uninvited intrusion. For example, you should take precautions in handling your social insurance number. Your social insurance number is necessary for us to identify you and authenticate your request to access your personal information. You should not share your social insurance number with others unless you clearly understand the purpose of their request and you know with whom you are dealing.
Access and Correction of Personal Information
If you wish to request access to, or correction of, your personal information in G&G records, please make your request in writing to G&G Privacy Officer, by email at admin@ggca.com. Some information may not be accessed in certain circumstances, for example if it contains personal information of other persons or for other legal reasons.
Should you identify any incorrect or out-of-date information, please notify us so that we can make the required changes where appropriate.
Links to Other Sites
The G&G website may contain links to other internet sites owned and operated by third parties. While we try to link only sites that share our high standards and respect for privacy, we are not responsible for the content or the privacy practice employed by other sites. You should review the privacy policies applicable to the other sites before you provide any personal information to those sites.
Changes to This Privacy Policy
G&G reserves the right to change its Privacy Policy from time to time. If G&G makes a material change, this Privacy Policy will be updated accordingly. We recommend that you review this Privacy Policy on our website periodically so that you are aware of any changes. Your continued use of our site following the posting of any changes to this Privacy Policy shall constitute your acceptance of these changes.
Inquiries, Questions or Complaints
If you have any inquiries, requests or complaints regarding G&G privacy practices, please contact G&G Privacy Officer by phone at 416-441-9292 extension 230 or by e-mail at admin@ggca.com.
Published January 1, 2016