bmm accounting services ltd.
The BMM Accounting Services Ltd.’s Privacy Code
Introduction
At BMM Accounting Services Ltd., respecting privacy is an important part of our commitment to our Clients. That is why we have developed The BMM Accounting Services Ltd. Privacy Code. The BMM Accounting Services Ltd. Privacy Code is a statement of principles and guidelines regarding the minimum requirements for the protection of personal information provided to BMM Accounting Services Ltd. by its clients.
A Client is an individual who purchases or otherwise acquires or uses any of BMM Accounting Services Ltd. services or otherwise provides personal information to BMM Accounting Services Ltd. in the course of its commercial activities.
The objective of The BMM Accounting Services Ltd. Privacy Code is to promote responsible and transparent personal information management practices in a manner consistent with the provisions of the Personal Information Protection and Electronic Documents Act (Canada).
The BMM Accounting Services Ltd. Privacy Code applies to personal information in any form (oral, written or electronic) that is collected, used, or disclosed by in the course of commercial activities.
BMM Accounting Services Ltd. will continue to review The BMM Accounting Services Ltd. Privacy Code to make sure that it is relevant and remains current with changing industry standards, technologies and laws.
Principle 1 — Accountability
BMM Accounting Services Ltd. is responsible for personal information under its control and shall designate one or more persons who are accountable for BMM Accounting Services Ltd’s compliance with the following principles.
1.1 Responsibility for compliance with the provisions of The BMM Accounting Servies Ltd. Privacy Code rests with the BMM Accounting Servies Ltd. Privacy Officer who can be reached at 604.946.2995 or via bmm@bmmaccounting.ca. Other individuals within BMM Accounting Servies Ltd. may be delegated to act on behalf of The BMM Accounting Servies Ltd. Privacy Officer or to take responsibility for the day-to-day collection and/or processing of personal information.
1.2 BMM Accounting Servies Ltd. shall make known, upon request, the title of the person or persons designated to oversee BMM Accounting Servies Ltd.’s compliance with The BMM Accounting Servies Ltd. Privacy Code.
1.3 BMM Accounting Servies Ltd. is responsible for personal information in its possession or control. BMM Accounting Servies Ltd. shall use contractual or other means to provide a comparable level of protection while information is being processed or used by a third party.
1.4 BMM Accounting Servies Ltd. shall implement policies and procedures to give effect to The BMM Accounting Servies Ltd. Privacy Code, including:
(a) implementing procedures to protect personal information and to oversee BMM Accounting Servies Ltd.’s compliance with The BMM Accounting Servies Ltd. Privacy Code;
(b) implementing procedures to receive and respond to complaints or inquiries;
(c) training and communicating to staff about BMM Accounting Servies Ltd.’s policies and procedures; and
(d) developing information materials to explain BMM Accounting Servies Ltd.’s policies and procedures.
Principle 2 — Identifying Purposes for Collection of Personal Information
BMM Accounting Servies Ltd. shall identify the purposes for which personal information is collected at or before the time the information is collected.
2.1. BMM Accounting Servies Ltd. collects personal information only for the the purpose of completing engagements which require the knowledge of Client's personal information.
2.2. BMM Accounting Servies Ltd. shall specify orally, electronically or in writing the identified purposes to the Client at or before the time personal information is collected. Upon request, persons collecting personal information shall explain these identified purposes or refer the individual to a designated person within BMM Accounting Servies Ltd. who can explain the purposes.
2.3. When personal information that has been collected is to be used or disclosed for a purpose not previously identified, the new purpose shall be identified prior to use. Unless the new purpose is permitted or required by law, the consent of the Client will be acquired before the information will be used or disclosed for the new purpose.
Principle 3 — Obtaining Consent for Collection, Use or Disclosure of Personal Information
The knowledge and consent of a Client are required for the collection, use, or disclosure of personal information, except where inappropriate. In certain circumstances personal information can be collected, used, or disclosed without the knowledge and consent of the individual.
3.1. In obtaining consent, BMM Accounting Servies Ltd. shall use reasonable efforts to ensure that a Client is advised of the identified purposes for which personal information will be used or disclosed. The identified purposes shall be stated in a manner that can be reasonably understood by the Client or employee.
3.2. Generally, BMM Accounting Servies Ltd. shall seek consent to use and disclose personal information at the same time it collects the information. However, BMM Accounting Servies Ltd. may seek consent to use and/or disclose personal information after it has been collected, but before it is used and/or disclosed for a new purpose.
3.3. BMM Accounting Servies Ltd. may require a Client to consent to the collection, use and/or disclosure of personal information as a condition of the supply of a product or service only if such collection, use and/or disclosure is required to fulfill the explicitly specified, and legitimate identified purposes.
3.4. In determining the appropriate form of consent, BMM Accounting Servies Ltd. shall take into account the sensitivity of the personal information and the reasonable expectations of its Client.
3.5. The purchase or use of products and services by a Client may constitute implied consent for BMM Accounting Servies Ltd. to collect, use and disclose personal information for the identified purposes.
3.6. A Client may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice. Clients may contact BMM Accounting Servies Ltd. for more information regarding the implications of withdrawing consent.
3.7. BMM Accounting Servies Ltd. may collect or use personal information without knowledge or consent if it is clearly in the interests of the individual and consent cannot be obtained in a timely way, such as when the individual is seriously ill or mentally incapacitated.
3.8. BMM Accounting Servies Ltd. may collect, use or disclose personal information without knowledge or consent if seeking the consent of the individual might defeat the purpose of collecting, using or disclosing the information, such as in the investigation of a breach of an agreement or a contravention of a law.
3.9. BMM Accounting Servies Ltd. may collect, use or disclose personal information without knowledge or consent in the case of an emergency where the life, health or security of an individual is threatened.
3.10. BMM Accounting Servies Ltd. may use or disclose personal information without knowledge or consent to a lawyer representing BMM Accounting Servies Ltd., to collect a debt, to comply with a subpoena, warrant or other court order, or as may be otherwise required or authorized by law.
Principle 4 — Limiting Collection of Personal Information
BMM Accounting Servies Ltd.shall limit the collection of personal information to that which is necessary for the purposes identified by BMM Accounting Servies Ltd.. BMM Accounting Servies Ltd. shall collect personal information by fair and lawful means.
4.1. BMM Accounting Servies Ltd. collects personal information primarily from its Clients.
4.2. BMM Accounting Servies Ltd. may also collect personal information from other sources including credit bureaus, employers or personal references, or other third parties who represent that they have the right to disclose the information.
Principle 5 — Limiting Use, Disclosure, and Retention of Personal Information
BMM Accounting Servies Ltd.shall 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 or permitted by law. BMM Accounting Servies Ltd. shall retain personal information only as long as necessary for the fulfillment of those purposes.
5.1. BMM Accounting Servies Ltd. may disclose a Client’s personal information to any law enforcement agency operating under provincial or federal jurisdiction.
5.2. BMM Accounting Servies Ltd. may disclose personal information about its employees to any law enforcement agency operating under provincial or federal jurisdiction.
5.3. Only BMM Accounting Servies Ltd.]’s employees with a business need-to-know, or whose duties reasonably so require, are granted access to personal information about Clients.
5.4. BMM Accounting Servies Ltd. shall keep personal information only as long as it remains necessary or relevant for the identified purposes or as required by law. Depending on the circumstances, where personal information has been used to make a decision about a Client, BMM Accounting Servies Ltd .shall retain, for a period of time that is reasonably sufficient to allow for access by the Client, either the actual information or the rationale for making the decision.
5.5. BMM Accounting Servies Ltd. shall maintain reasonable and systematic controls, schedules and practices for information and records retention and destruction which apply to personal information that is no longer necessary or relevant for the identified purposes or required by law to be retained. Such information shall be destroyed, erased or made anonymous.
Principle 6 — Accuracy of Personal Information
Personal information shall be as accurate, complete, and up-to-date as is necessary for the purposes for which it is to be used.
6.1. Personal information used by BMM Accounting Servies Ltd. shall be sufficiently accurate, complete, and up-to-date to minimize the possibility that inappropriate information may be used to make a decision about a Client.
6.2. BMM Accounting Servies Ltd. shall update personal information about Clients as necessary to fulfill the identified purposes or upon notification by the individual.
Principle 7 — Security Safeguards
BMM Accounting Services Ltd. shall protect personal information by security safeguards appropriate to the sensitivity of the information.
7.1. BMM Accounting Servies Ltd. shall protect personal information against such risks as loss or theft, unauthorized access, disclosure, copying, use, modification or destruction, through appropriate security measures, regardless of the format in which it is held.
7.2. BMM Accounting Servies Ltd. shall protect personal information disclosed to third parties by contractual agreements stipulating the confidentiality of the information and the purposes for which it is to be used.
7.3. All of BMM Accounting Servies Ltd.’s employees with access to personal information shall be required to respect the confidentiality of that information.
Principle 8 — Openness Concerning Policies and Procedures
BMM Accounting Servies Ltd. shall make readily available to Clients specific information about its policies and procedures relating to the management of personal information.
8.1. BMM Accounting Servies Ltd. shall make information about its policies and procedures easy to understand, including:
(a) the title and address of the person or persons accountable for BMM Accounting Servies Ltd.’s compliance with The BMM Accounting Servies Ltd. Privacy Code and to whom inquiries and/or complaints can be forwarded;
(b) the means of gaining access to personal information held by BMM Accounting Servies Ltd.;
(c) a description of the type of personal information held by BMM Accounting Servies Ltd., including a general account of its use; and
(d) a description of what personal information is made available to related organizations (e.g., subsidiaries).
8.2. BMM Accounting Servies Ltd. shall make available information to help Clients exercise control of the collection, use and/or disclosure of their personal information and, where applicable, privacy-enhancing services available from BMM Accounting Servies Ltd..
Principle 9 — Client Access to Personal Information
Upon request, BMM Accounting Servies Ltd. shall inform a Client of the existence, use, and disclosure of his or her personal information and shall give the individual access to that information. A Client shall be able to challenge the accuracy and completeness of the information and have it amended as appropriate.
9.1. Upon request, BMM Accounting Servies Ltd. shall afford Clients a reasonable opportunity to review the personal information in the individual’s file. Personal information shall be provided in understandable form within a reasonable time, and at minimal or no cost to the individual.
9.2. In certain situations, BMM Accounting Servies Ltd. may not be able to provide access to all the personal information that it holds about a Client. For example, BMM Accounting Servies Ltd. may not provide access to information if doing so would likely reveal personal information about a third party or could reasonably be expected to threaten the life or security of another individual. Also, BMM Accounting Servies Ltd. may not provide access to information if disclosure would reveal confidential commercial information, if the information is protected by solicitor-client privilege, if the information was generated in the course of a formal dispute resolution process, or if the information was collected in relation to the investigation of a breach of an agreement or a contravention of the laws of Canada or a province.
9.3. Upon request, BMM Accounting Servies Ltd. shall provide an account of the use and disclosure of personal information and, where reasonably possible, shall state the source of the information. In providing an account of disclosure, BMM Accounting Servies Ltd. shall provide a list of third parties to which it may have disclosed personal information about the individual when it is not possible to provide an actual list.
9.4. In order to safeguard personal information, a Client may be required to provide sufficient identification information to permit BMM Accounting Servies Ltd.] to account for the existence, use and disclosure of personal information and to authorize access to the individual’s file. Any such information shall be used only for this purpose.
9.5. BMM Accounting Servies Ltd. shall promptly correct or complete any personal information found to be inaccurate or incomplete. Any unresolved differences as to accuracy or completeness shall be noted in the individual’s file. Where appropriate, BMM Accounting Servies Ltd. shall transmit to third parties having access to the personal information in question any amended information or the existence of any unresolved differences.
9.6. Clients can obtain information or seek access to their individual files by contacting the BMM Accounting Servies Ltd. Privacy Officer.
Principle 10 — Challenging Compliance
A Client shall be able to address a challenge concerning compliance with the above principles to the designated person or persons accountable for BMM Accounting Servies Ltd.’s compliance with The BMM Accounting Servies Ltd. Privacy Code.
10.1. BMM Accounting Servies Ltd. shall maintain procedures for addressing and responding to all inquiries or complaints from its Clients regarding BMM Accounting Servies Ltd.’s handling of personal information.
10.2. BMM Accounting Servies Ltd. shall inform its Clients about the existence of these procedures as well as the availability of complaint procedures.
10.3. The person or persons accountable for compliance with The BMM Accounting Servies Ltd. Privacy Code may seek external advice where appropriate before providing a final response to individual complaints.
10.4. BMM Accounting Servies Ltd. shall investigate all complaints concerning compliance with The BMM Accounting Servies Ltd. Privacy Code. If a complaint is found to be justified, BMM Accounting Servies Ltd. shall take appropriate measures to resolve the complaint including, if necessary, amending its policies and procedures. A Client shall be informed of the outcome of the investigation regarding his or her complaint.
For more information regarding The BMM Accounting Servies Ltd. Privacy Code, please contact the BMM Accounting Servies Ltd. Privacy Officer at 604.946.2995 or via bmm@bmmaccounting.ca
Please visit the Privacy Commissioner of Canada’s web site at www.privcom.gc.ca.