Chan Yu Wong LLP (CYW) has a responsibility to protect personal information regarding its clients, partners and employees. The Firm believes protecting your privacy is important and has developed a privacy policy designed to meet the needs of its clients and employees and conform to the Personal Information Protection and Electronic Documents Act (“PIPEDA”). This policy covers the collection, use and disclosure of personal information by CYW.

The Rules of Professional Conduct and related Council Interpretations of the Institute of Chartered Accountants of Ontario require that partners and staff maintain the confidentiality of client and former client information, as well as the confidentiality of Firm information, except in rare and very specific circumstances.

The Rules of Professional Conduct of the Institute of Chartered Accountants of Ontario also require that partners and staff not use confidential information for personal advantage, for the advantage of a third party or to the disadvantage of a client, former client or the Firm, unless consent has been obtained from the client, former client or the Firm.

Personal Information

Personal information includes any factual or subjective information, recorded or not, about an identifiable individual. This includes information in any form, such as:

• Age, name, ID numbers, income, or ethnic origin;
• Opinions, evaluations, comments, social status, or disciplinary actions; and
• Employee files, credit records, loan records, medical records, existence of a dispute with a client, intentions (for example, to acquire goods or services, or change jobs).

Personal information does not include the name, title, business address or telephone number of an employee of an organization.

CYW collects personal information only for the following reasons:

• To provide the products or services that clients have requested and maintain commercial relations with the clients;
• To understand clients’ needs and recommend products and services accordingly;
• To manage the Firm’s business which includes partnership and employment matters; and
• To meet legal and regulatory requirements.

CYW will not use clients’ or employees’ personal information for any other reason without their consent and will only share the information with third parties to assist in completing the above uses. Any third party’s use must adhere to the Firm’s privacy policies or be allowed by the legislation. Examples would be an outside payroll service, an agent hired to perform a service for the Firm, a collection agency, a law enforcement agency or emergency services.

“Cookies”

The Firm may from time to time use certain information commonly called cookies on its computer to save clients’ time as Visitors and Users of the Firm’s website. The Firm does not collect personal information in this fashion.
Accountability

CYW is accountable for all personal information in its possession, including any personal information disclosed to third parties for processing or other administrative functions.

CYW has appointed a Privacy Officer, who is part of senior management, to be accountable for the Firm’s privacy policies and enforcement. The Firm has also trained all of its partners and staff on privacy issues.

CYW’s Privacy Officer can be reached at:

Privacy Officer
Chan Yu Wong LLP
350 Highway 7 East, Suite 305
Richmond Hill, Ontario
L4B 3N2

Identifying Purposes
CYW shall identify the purpose for which personal information is collected before collecting it.

Consent
CYW shall obtain consent for all personal information collected, used or disclosed by CYW, unless such collection or use is inappropriate, or permitted by law.

Limiting Collection, Use, Disclosure and Retention
Personal information collected shall be limited to information that is necessary for the purposes identified by CYW and be collected by fair and lawful means.
Personal information collected by CYW, shall not be used or disclosed for purposes other than those for which it was collected, except with the consent of the individual or as required or permitted by law. Personal information shall be retained only as long as necessary for the fulfillment of those purposes.

Accuracy
Personal information shall be as accurate, complete, and up-to-date as is necessary to fulfill the purposes for which it is to be used. The Firm will use its best efforts to keep the information up-to-date.

Safeguards
CYW shall safeguard clients’ and employees’ information against unauthorized access, disclosure, copying, use or modification.

Openness
CYW shall make information available, to its clients and employees, about the policies and practices that apply to the management of their information.

Individual Access
Upon request, an individual shall be informed of the existence, use and disclosure of his/her information, and shall be given access to it. An individual will be given reasonable access to his/her information and may correct any personal information if its accuracy and completeness is challenged and found to be deficient.

Challenging Compliance
An individual shall be able to challenge compliance with the above privacy principles: CYW shall investigate all complaints in a timely manner.

Updated: January 6, 2006