Privacy Policy
PRIVACY PHILOSOPHY
Structure Chartered Professional Accountants LLP (“Structure”) values its relationship with its clients and is committed to protecting the privacy rights of its clients. We are, therefore, committed to maintaining the accuracy, confidentiality and security of personal information. We manage your personal information in accordance with Alberta’s Personal Information Protection Act (PIPA) and other applicable laws. This privacy policy explains how we collect, use, disclose and safeguard the personal information you provide to us.
By providing personal information to us, you consent to our collection, use and disclosure of your personal information in accordance with this privacy policy. This policy applies Structure and to any personal providing services on our behalf.
A copy of our privacy policy will be provided to any client on request.
This privacy policy covers only activities that are subject to the provisions of Canada’s federal and provincial privacy laws, as applicable.
INTRODUCTION
For the purposes of this privacy policy, “personal information” shall mean information that is, or can be, about or related to an identifiable individual.
PRINCIPLES
As part of Structure’s commitment to treat your personal information with respect, we follow these 10 fair information principles (the “Principles”) as set out in Generally Accepted Privacy Principles (GAPP) developed by the Chartered Professional Accountants of Canada.
Principle 1 – Management
Principle 2 – Notice
Principle 3 – Choice and Consent
Principle 4 – Collection
Principle 5 – Use, Retention and Disposal
Principle 6 – Access
Principle 7 – Disclosure to Third Parties
Principle 8 – Security for Privacy
Principle 9 – Quality
Principle 10 – Monitoring and Enforcement
Each of the Principles apply to Structure’s practices as follows:
Principle 1 – Management
We will maintain and protect the personal information under our control. We have policies and procedures for ensuring privacy and security of data, which are strictly enforced to protect the individuals from whom we may collect personal information. We have a Privacy Officer who is responsible for ensuring our compliance with the Principles and this privacy policy. If you have questions about this privacy policy or our use of your information, or if you need help changing your personal information, please contact us.
We have implemented policies and procedures which include communication and providing training to our employees on these policies and procedures.
Principle 2 – Notice
Structure will identify to you the purposes for which it will collect or use personal information before or at the time the information is collected.
Structure collects only that personal information required to perform its professional services and operate its business, and such information is collected by fair and lawful methods.
Principle 3 – Choice and Consent
Except where required or permitted by law, your informed consent is required for the collection, use or disclosure of your personal information. Should we wish to make use of your personal information for a secondary purpose (such as a mailing list), your consent will be obtained and you may opt-out of this secondary use whenever you wish.
By providing personal information to us, you consent to the collection, use and disclosure of your personal information in accordance with this privacy policy.
You may withdraw your consent at any time; however, by doing so, Structure may not be able to provide you with the goods and services that you requested.
Principle 4 – Collection
The personal information collected by us shall be limited to those details necessary for the purposes identified to you. We may collect this information from you via the Internet, over the telephone, in person or from third-party sources, such as credit reporting agencies.
What Types of Personal Information May We Collect?
The type of personal information we may collect depends on, and is related to, the reason (or purpose) such personal information was provided to us.
The following is a description of the types of personal information that we may request:
contact information, such as your name, mailing and/or email address, and home telephone number
credit card or other billing information
financial information and statements
personal information, such as Social Insurance Number and date of birth
Principle 5 – Use, Retention and Disposal
We will only use or disclose your personal information in accordance with the purposes for which it was originally collected unless you have otherwise consented, or when permitted by law. We will keep your personal information only for as long as is required to fulfill the purpose for which it was collected or as required by law.
We will use your personal information to:
maintain and develop our business and operations
establish and manage our relationship with you
provide you with the requested products and services
advise you of our professional services and information that we believe may be of interest to you
Principle 6 – Access
Upon your written request, we shall inform you of: (i) the type of personal information we have collected; (ii) how we have used your personal information in the past, and how we may in the future; and (iii) whether or not we have disclosed your personal information to any third parties (and, if so, to whom). You may ask about the accuracy and completeness of your personal information, and you may request that it be changed, if appropriate.
Please note that before we provide you with any information or correct any inaccuracies, we may ask you to confirm your identity and provide additional information to help us to respond to your request.
Clients of Structure have a right of access to their own personal information in a record that is in our custody, with a few limitations. For example, we cannot provide access to information that would also reveal personal information about another individual or confidential business details.
Principle 7 – Disclosure to Third Parties
Except as explained in this privacy policy, as required by law or regulation or as otherwise consented to by you, we do not disclose any personal information to third parties. We will not disclose your information to third parties to enable them to market their products or services to you without your consent.
We may share your information with our employees, contractors, consultants, and other parties who require such information to assist us with managing our relationship with you and providing our products and services to you.
In addition, personal information may be disclosed or transferred to another party during the course of or completion of, a change in ownership of or the grant of a security interest in all or part of Structure through, for example, an asset or share sale, or some other form of business combination or merger, or joint venture, provided that such party is bound by appropriate agreements or obligations required to use or disclose your personal information in a manner consistent with the use and disclosure provision of this privacy policy, unless you consent otherwise.
Principle 8 – Security for Privacy
The security of your personal information is a priority to Structure. Structure is responsible for protecting personal information under its control, including personal information that has been transferred to, or received from, a third party.
In the event that personal information is transferred to a third party, Structure will take steps to ensure that such recipients safeguard the Personal Information and use the information only for authorized purposes. Some examples of such measures are as follows:
physical security measures, such as restricted access facilities and locked filing cabinets
electronic security measures for computerized personal information, such as password protection, database encryption and personal identification numbers
Structure processes, such as limiting access to such personal information to a selected group of individuals
contractual obligations with third parties that require access to personal information, by agreements stipulating the confidentiality of the information and requiring them to protect and secure the personal information
Only employees with a business need to know, or whose duties reasonably so require, are granted access to personal information and shall be required to respect the privacy of that information.
Our Employees and Your Personal Information
In the course of daily operations, access to private, sensitive and confidential information is restricted to authorized employees who have a legitimate business purpose and reason for accessing it. As a condition of their employment, all employees of Structure are required to follow this policy. Employees are informed about the importance of privacy and they are required to agree to a code of conduct that prohibits the disclosure of any personal information to unauthorized individuals or parties.
Unauthorized access to and/or disclosure of personal information by an employee of Structure is strictly prohibited. All employees are expected to maintain the confidentiality of personal information at all times, and failing to do so will result in appropriate disciplinary measures, which may include dismissal.
Principle 9 – Quality
We shall make every reasonable effort to ensure your personal information is accurate, complete and up-to-date. You are responsible for advising Structure of any inaccuracies or changes to your personal information. Any such inaccuracies or changes may be reported to our office.
Principle 10 – Monitoring and Enforcement
If you have questions about this policy or our use of your information, or if you need help changing your personal information, please contact us.
Please submit your request to:
Matt Sharp
Structure Chartered Professional Accountants LLP
230 – 5010 Richard Road SW
Calgary, Alberta T3E 6L1
Phone: 403-475-8033
Fax: 403-475-0931
If you are not satisfied with the response from Structure, you can contact the Information and Privacy Commissioner of Alberta:
Office of the Information and Privacy Commissioner of Alberta
Suite 2460, 801 – 6th Avenue SW
Calgary, Alberta T2P 3W2
Phone: 403-297-2728
Toll Free: 1-888-878-4044
Email: generalinfo@oipc.ab.ca
Website: www.oipc.ab.ca
Websites Governed by this Privacy Policy
The website that is governed by the provisions and practices stated in this privacy policy is: www.structurecpa.com
Structure’s website may contain links to other third party sites that are not governed by this privacy policy. Although we endeavour to only link to sites with high privacy standards, our privacy policy will no longer apply once you leave Structure’s website. Additionally, we are not responsible for the privacy practices employed by other third-party websites. Therefore, we suggest that you examine the privacy statements of those sites to learn how your information may be collected, used, shared and disclosed.
Updating this Privacy Policy
Any changes to our privacy policy and information handling practices will be acknowledged in this policy in a timely manner. We may add, modify or remove portions of this policy when we feel it is appropriate to do so. You may determine when this policy was last updated by referring to the date at the bottom of this page.
BY PROVIDING PERSONAL INFORMATION TO US, YOU SIGNIFY YOUR CONSENT TO OUR COLLECTION, USE AND DISCLOSURE OF YOUR PERSONAL INFORMATION IN ACCORDANCE WITH THIS PRIVACY POLICY.
Last revised Monday, August 25, 2023
3758382.2