Last revised: September 25, 2020
At William Dale Somerville Professional Corporation, we are committed to providing our clients with exceptional service. As providing this service involves the collection, use and disclosure of some personal information about our clients, protecting their personal information is one of our highest priorities.
While we have always respected our clients’ privacy and safeguarded their personal information, we have strengthened our commitment to protecting personal information as a result of Alberta’s Personal Information Protection Act (PIPA). PIPA sets out the ground rules for how Alberta businesses and not-for-profit organizations may collect, use and disclose personal information.
We will inform our clients of why and how we collect, use and disclose their personal information, obtain their consent where required, and only handle their personal information in a manner that a reasonable person would consider appropriate in the circumstances.
Personal information –means information about an identifiable individual. This information may include, but is not limited to, your mailing address, telephone number, email address Internet Protocol (“IP”) address, age, gender, marital status, health information and credit card information. Personal information does not include business contact information as described below.
Business contact information – means information that would enable an individual to be contacted at a place of business and includes name, position name or title, business telephone number, business address, business email or business fax number. Business contact information is not covered by this policy or PIPA.
Privacy Officer – means the individual designated responsibility for ensuring that William Dale Somerville Professional Corporation complies with this policy and PIPA.
1 – Collecting Personal Information
1.1 Unless the purposes for collecting personal information are obvious and the client voluntarily provides his or her personal information for those purposes, we will communicate the purposes for which personal information is being collected, either orally or in writing, before or at the time of collection.
1.2 We will only collect client information that is necessary to fulfill the following purposes:
- To verify identity;
- To identify client preferences;
- To understand the financial needs of our clients;
- To deliver requested services;
- To provide advisory services; and
- To ensure a high standard of service to our clients.
2 – Consent
2.1 We will obtain client consent to collect, use or disclose personal information (except where, as noted below, we are authorized to do so without consent).
2.2 Consent can be provided orally, in writing, electronically, through an authorized representative or it can be implied where the purpose for collecting, using or disclosing the personal information would be considered obvious and the client voluntarily provides personal information for that purpose.
2.3 Consent may also be implied where a client is given notice and a reasonable opportunity to opt-out of his or her personal information being used for mail-outs or the marketing of new services or products and the client does not opt-out.
2.4 Subject to certain exceptions (e.g., the personal information is necessary to provide the service or product, or the withdrawal of consent would frustrate the performance of a legal obligation), clients can withhold or withdraw their consent for William Dale Somerville Professional Corporation to use their personal information in certain ways. A client’s decision to withhold or withdraw their consent to certain uses of personal information may restrict our ability to provide a service or product. If so, we will explain the situation to assist the client in making the decision.
2.5 We may collect, use or disclose personal information without the client’s knowledge or consent in the following limited circumstances:
- When the collection, use or disclosure of personal information is permitted or required by law;
- When the personal information is available from a public source (e.g., a telephone directory);
- When we require legal advice from a lawyer;
- For the purposes of collecting a debt;
- To protect ourselves from fraud; and
- To investigate an anticipated breach of an agreement or a contravention of law.
3 – Using and Disclosing Personal Information
3.1 We will only use client personal information where necessary to fulfill the purposes identified at the time of collection or for a purpose reasonably related to those purposes such as:
- To provide professional assurance, tax or advisory services;
- To invoice and collect payment for professional services and products provided to clients;
- To conduct client surveys in order to enhance the provision of our services; and
- To contact our clients directly about products and services that may be of interest.
3.2 We will not use or disclose client personal information for any additional purpose unless we obtain consent to do so.
3.3 We will not sell client lists or personal information to other parties unless we have consent to do so.
4 – Retaining Personal Information
4.1 If we use client personal information to make a decision that directly affects the client, we will retain that personal information for at least one year so that the client has a reasonable opportunity to request access to it.
4.2 Subject to item 4.1, we will retain client personal information only as long as necessary to fulfill the identified purposes or a legal or business purpose.
5 – Ensuring Accuracy of Personal Information
5.1 We will make reasonable efforts to ensure that client personal information is accurate and complete where it may be used to make a decision about the client or disclosed to another organization.
5.2 Clients may request correction to their personal information in order to ensure its accuracy and completeness. A request to correct personal information must be made in writing and provide sufficient detail to identify the personal information and the correction being sought.
5.3 If the personal information is demonstrated to be inaccurate or incomplete, we will correct the information as required and send the corrected information to any organization to which we disclosed the personal information in the previous year. If the correction is not made, we will note the clients’ correction request in the file.
6 – Securing Personal Information
6.1 We are committed to ensuring the security of client personal information in order to protect it from unauthorized access, collection, use, disclosure, copying, modification or disposal or similar risks.
6.2 The following security measures will be followed to ensure that client personal information is appropriately protected:
- physically secured offices where personal information is held;
- the use of user IDs, passwords, encryption, and firewalls; and
- restricted employee access to personal information as appropriate.
6.3 We will use appropriate security measures when destroying client’s personal information such as shredding documents and deleting electronically stored information.
6.4 We will continually review and update our security policies and controls as technology changes to ensure ongoing personal information security.
7 – Providing Client Access to Personal Information
7.1 Clients have a right to access their personal information, subject to limited exceptions including:
- disclosure that would reveal personal information about another individual; and
- health and safety concerns.
7.2 A request to access personal information must be made in writing and provide sufficient detail to identify the personal information being sought.
7.3 Upon request, we will also tell clients how we use their personal information and to whom it has been disclosed if applicable.
7.4 We will make the requested information available within 30 business days, or provide written notice of an extension where additional time is required to fulfill the request.
7.5 A fee may be charged for providing access to personal information. Where a fee may apply, we will inform the client of the cost and request further direction from the client on whether we should proceed with the request.
7.6 If a request is refused in full or in part, we will notify the client in writing, providing the reasons for refusal and the recourse available to the client.
8 – Website privacy
8.1 Log Files
Like many other websites, our website makes use of log files. These files merely log visitors to the site – usually a standard procedure for hosting companies and a part of hosting services’ analytics. The information inside the log files includes internet protocol (IP) addresses, browser type, Internet Service Provider (ISP), date/time stamp, referring/exit pages, and possibly the number of clicks. This information is used to analyze trends, administer the site, track user’s movement around the site, and gather demographic information. IP addresses, and other such information are not linked to any information that is personally identifiable.
8.2 Cookies and Web Beacons
8.3 Our Advertising Partners
We have no access to or control over these cookies that are used by third-party advertisers.
We use Google Analytics with demographics enabled, to enable us to better track who is interested in our services. No personally identifiable information is viewable by us. Google provides a tool to opt out of tracking at https://tools.google.com/dlpage/gaoptout/
8.6 Third Party Privacy Policies
If you wish to disable cookies, you may do so through your individual browser options. More detailed information about cookie management with specific web browsers can be found at the browsers’ respective websites. What Are Cookies?
8.7 Children’s Information
We believe it is important to provide added protection for children online. We encourage parents and guardians to spend time online with their children to observe, participate in and/or monitor and guide their online activity. We do not knowingly collect any personally identifiable information from children under the age of 13. If a parent or guardian believes that our website has in its database the personally-identifiable information of a child under the age of 13, please contact us immediately and we will use our best efforts to promptly remove such information from our records.
9 – Questions and Complaints: The Role of the Privacy Officer or designated individual
9.1 The Privacy Officer or designated individual is responsible for ensuring William Dale Somerville Professional Corporation’s compliance with this policy and the Personal Information Protection Act.
9.2 Clients should direct any complaints,
concerns or questions regarding William Dale Somerville Professional
Corporation’s compliance in writing to the Privacy Officer. If the Privacy
Officer is unable to resolve the concern, the client may also write to the
Information and Privacy Commissioner of Alberta.
Contact information for William Dale Somerville Professional Corporation’s Privacy Officer or designated individual:
W. Dale Somerville, FCPA, FCA
Email: [email protected]
Mail: 6240 97 Street NW, Edmonton, AB T6E 3J6