Last revised: July 29, 2019
This privacy statement explains what information we gather about you, what we use that information for and who we give that information to. It also sets out your rights in relation to your information and who you can contact for more information or queries.
Who this privacy statement applies to and what it covers
This privacy statement applies to Deuzeman CPA Professional Corporation (“Deuzeman CPA”, “we”, “us” or “our”). We are committed to protecting your privacy and handling your information in an open and transparent manner. This privacy statement sets out how we will collect, handle, store and protect information about you when:
- providing services to you or our clients;
- you use “our Website”; or
- performing any other activities that form part of the operation of our business.
When we refer to “our Website” or “this Website” in this policy we mean the specific webpages of www.deuzeman.ca and to specific webpages with a URL commencing www.deuzeman.ca/. This privacy statement also contains information about when we share your personal data with other members of the Deuzeman CPA Network and other third parties (for example, our service providers). In this privacy statement, your information is sometimes called “personal data” or “personal information”. We may also sometimes collectively refer to handling, collecting, protecting and storing your personal information as “processing” such personal information.
What information we collect?
How we use information about you?
Use of personal information to provide services to our clients We will use your personal data to provide you or our client with services. As part of this, we may use your personal data in the course of correspondence relating to the services. Such correspondence may be with you, our client, other members of the Deuzeman CPA Network, our service providers or competent authorities. We may also use your personal data to conduct due diligence checks relating to the services. Because we provide a wide range of services to our clients, the way we use personal data in relation to our services also varies. For example, we might use personal data:
- about a client’s employees to help those employees manage their tax affairs when working overseas;
- about a client’s employees and customers in the course of conducting an audit (or similar activity) for a client;
- about a client’s employees and customers in the course of implementing new human resources or customer relationship management systems;
- to provide immigration assistance to an individual, either directly or on behalf of a client;
- to support a client in the course of a forensic investigation; or
- about a client to help him/her complete a tax return.
Use of personal information for other activities that form part of the operation of our business We may also use your personal data for the purposes of, or in connection with:
- applicable legal or regulatory requirements;
- requests and communications from competent authorities;
- client account opening and other administrative purposes;
- financial accounting, invoicing and risk analysis purposes;
- client relationship purposes, which may involve: (i) sending you thought leadership or details of our products and services that we think might be of interest to you; (ii) contacting you to receive feedback on services; (iii) contacting you for other market or research purposes; or (iv) managing our own customer relationship management processes;
- recruitment and business development purposes (for example testimonials from a client’s employees may be used as part of our recruitment and business development materials with that employee’s permission);
- services we receive from our professional advisors, such as lawyers, accountants and consultants; or
- protecting our rights and those of our clients.
Use of personal information collected via our Website In addition to the purposes connected to the operation of our business above, we may also use your personal data collected via our Website:
- to manage and improve our Website;
- to tailor the content of our Website to provide you with a more personalised experience and draw your attention to information about our products and services that may be of interest to you; or
- to manage and respond to any request you submit through our Website.
The legal grounds we use for processing personal information
We are required by law to set out in this privacy statement the legal grounds on which we rely in order to process your personal data. As a result, we use your personal data for the purposes outlined above because: (i) of our legitimate interests in the effective delivery of our services to you or our client; (ii) of our legitimate interests in the effective and lawful operation of our business so long as such interests are not outweighed by your interests; (iii) of the legal and regulatory obligations that we are subject to, such as keeping records for tax purposes or providing information to a public body or law enforcement agency; or (iv) the information is required in order to provide our services to you or our client. To the extent that we process any sensitive personal data relating to you for any of the purposes outlined above, we will do so because either: (i) you have given us your explicit consent to process that data; (ii) we are required by law to process that data in order to ensure we meet our ‘know your client’ and ‘anti-money laundering’ obligations (or other legal obligations imposed on us); (iii) the processing is necessary to carry out our obligations under employment, social security or social protection law; (iv) the processing is necessary for the establishment, exercise or defence of legal claims; or (v) you have made the data public. Where we are legally required to obtain your explicit consent to provide you with certain marketing materials, we will only provide you with such marketing materials where we have obtained such consent from you.
Who we disclose your information to?
In connection with one or more of the purposes outlined in the “How we use information about you?” section above, we may disclose details about you to: other members of the Deuzeman CPA Network; third parties that provide services to us and/or the Deuzeman CPA Network; competent authorities (including courts and authorities regulating us or another member of the Deuzeman CPA Network); your employer and/or their advisers; your advisers; credit reference agencies or other organizations that help us make credit decisions and reduce the incidence of fraud and other third parties that reasonably require access to personal data relating to you for one or more of the purposes outlined in the “How we use information about you?” section above. Our Website hosts various blogs, forums, wikis and other social media applications or services that allow you to share content with other users (collectively “Social Media Applications”). Importantly, any personal information that you contribute to these Social Media Applications can be read, collected and used by other users of the application. We have little or no control over these other users and, therefore, we cannot guarantee that any information that you contribute to any Social Media Applications will be handled in accordance with this privacy statement. Please note that some of the recipients of your personal data referenced above may be based in countries outside of the Canada, whose laws may not provide the same level of data protection. In such cases, we will ensure that there are adequate safeguards in place to protect your personal data that comply with our legal obligations. Where the recipient is not a member of the Deuzeman CPA Network, the adequate safeguard might be a data transfer agreement with the recipient based on standard contractual clauses approved by the European Commission for transfers of personal data to third countries. We may also need to disclose your personal data if required to do so by law, a regulator or during legal proceedings. We may share non-personal, de-identified and aggregated information with third parties for several purposes, including data analytics, research, submissions, thought leadership and promotional purposes.
Protection of your personal information
We use a range of physical, electronic and managerial measures to ensure that we keep your personal data secure, accurate and up to date. These measures include:
- education and training to relevant staff to ensure they are aware of our privacy obligations when handling personal data;
- administrative and technical controls to restrict access to personal data on a ‘need to know’ basis;
- technological security measures, including firewalls, multi-factor authentication, encryption and anti-virus software; and
- physical security measures, such as staff security passes to access our premises.
Although we use appropriate security measures once we have received your personal data, the transmission of data over the internet (including by e-mail) is never completely secure. We endeavor to protect personal data, but we cannot guarantee the security of data transmitted to us or by us.
How long we keep your information for?
We will hold your personal data on our systems for the longest of the following periods: (i) as long as is necessary for the relevant activity or services; (ii) any retention period that is required by law or professional standards; (iii) the end of the period in which litigation or investigations might arise in respect of the services or (iv) as directed by Deuzeman CPA’s own internal retention policies or practices, the length of which may vary depending on the nature of the information that is held. Further, any copies of personal data stored in our electronic backups will be destroyed in accordance with that backup’s ordinary lifecycle.
You have various rights in relation to your personal data. In particular, you have a right to:
- obtain confirmation that we are processing your personal data and request a copy of the personal data we hold about you;
- ask that we update the personal data we hold about you, or correct such personal data that you think is incorrect or incomplete;
- ask that we delete personal data that we hold about you, or restrict the way in which we use such personal data;
- withdraw consent to our processing of your personal data (to the extent such processing is based on consent);
- To the extent prescribed by applicable law, receive a copy of the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and to transmit such personal data to another party (to the extent the processing is based on consent or a contract); and
- object to our processing of your personal data.
To exercise any of your rights, or if you have any other questions about our use of your personal data, please email [email protected] or write us at one of our physical addresses. You may also use these contact details if you wish to make a complaint to us relating to your privacy.
Right to complain
If you are unhappy with the way we have handled your personal data or any privacy query or request that you have raised with us, you have a right to complain to the Data Protection Authority (“DPA”) in your jurisdiction. If you would like to be directed to the appropriate DPA, please contact us.
Changes to this privacy statement
We may modify or amend this privacy statement from time to time. To let you know when we make changes to this privacy statement, we will amend the revision date at the top of this page. The new modified or amended privacy statement will apply from that revision date. Therefore, we encourage you to periodically review this statement to be informed about how we are protecting your information.