Swain & Associates Inc.
Protecting your privacy and the confidentiality of your information – over the Internet, on the telephone, or through our offices – has always been fundamental to the way we do business at Swain & Associates Inc. We operate on the basis of a Privacy Policy and related procedures that guide the handling of the personal information we collect. We have created this privacy statement in order to demonstrate our firm commitment to protecting the privacy of our members, partners and potential Web site visitors. This policy and related procedures are consistent with the Canadian Standards Association Model Code for the Protection of Personal Information (herein “CSA Model Code”) and applicable privacy legislation.
This policy deals only with personal information handled by Swain & Associates Inc. Personal information is information about an identifiable individual, excluding business contact information. The following explains how Swain & Associates Inc. handles personal information. Swain & Associates Inc. reserves the right to change this policy and it may be updated periodically. These changes may affect our use of your personal information. Accordingly, please check for changes regularly.
Swain & Associates Inc. (herein “Swain”) is accountable for all personal information under its control. Swain’s Privacy Officer is the Chief Executive Officer who is designated as responsible for Swain’s privacy policy. The Privacy Officer can be reached by:
Any questions about Swain’s handling of personal information should be directed to the privacy officer. Please see below for more information about the process for referring questions about Swain’s handling of personal information.
The purpose for which Swain collects personal information will be identified at or before the time the information is collected. Swain may collect personal information for the purposes of:
Swain seeks consent for all personal information we collect, use and disclose through information provided to individuals prior to collection, or at the time of collection.
If you have voluntarily provided information, you have consented to the collection, use and disclosure of your personally identifiable information as described in this privacy policy. As required by the CSA Model Code, Swain will not use personal information for any purpose other than that for which you consented. Should Swain require personal information for a new purpose, we will contact you to seek consent for that new use.
Swain does not collect, use or disclose personal information of individuals except when individuals give consent and provide the information on a voluntary basis. There may be occasions where more specific personal information is necessary for us to proceed with a request for information, or provide you with a product or service. In such cases, we will provide you with a description on the information we need. In all cases, Swain limits the amount and type of information collected to only the personal information that is required to provide the individual with the requested information, product, or service. We collect only information that is voluntarily provided by you and undertake that such information will be kept strictly confidential.
We retain personal information only as long as is necessary to provide the individual with the requested product, service or information and delete or destroy this information after that time, i.e. if personal information is given to enable you to register for an event and you request that we keep that information on file for further registrations, the personal information will only be used for each event that you register for, and will be kept under locked security for one year. In some cases, however, legal reporting and retention requirements necessitate that Swain retain information for a specific amount of time. In general, Swain retains information for a period not longer than one calendar year, with the exception of financial information which must be kept for seven years.
Swain does not sell or trade any personal information with third parties. Swain may transfer information to service providers where information processing is outsourced by Swain in the course of its administrative procedures or member services in specific cases. Where personal information is transferred to a service provider for processing, we require the service provider to respect this Privacy Policy and we restrict them from using or disclosing personal information transferred to them for any purpose other than the provision of services to us.
Any personal information that Swain retains is kept in such a manner as to ensure its security and confidentiality at all times.
Swain respects the privacy of our members, partners, potential website visitors and Internet users and will protect that privacy as vigorously as possible. We store personal information in electronic and physical files that are secure. Our security measures include secure locks on filing cabinets, and using industry standard techniques such as firewalls, encryption, intrusion detection and restricted access to records and to equipment, including computers. Unfortunately, no data transmission over the Internet can be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, we cannot ensure or warrant the security of any information you transmit to us or receive from us electronically. This is especially true for information you transmit to us via e-mail. We have no way of protecting that info9rmation until it reaches us. Once we receive your transmission, we make our best efforts to ensure its security on our servers.
Swain makes every effort to keep personal information as accurate, complete, current and relevant as necessary for the identified purposes. Swain does not routinely update personal information.
Swain makes readily available to individuals our Privacy Policy and related procedures for managing personal information. We provide access to the Privacy Policy and related procedures to individuals on Swain’s Web site and in written form. Any questions about the handling of personal information by Swain can be raised with our privacy officer.
At the written request of an individual, he or she may view or edit their personal information as collected by Swain. Swain will inform them of what personal information we have about the individual, what it is being used for and, in cases where it has been disclosed, to whom it has been disclosed. There may be exceptional circumstances as provided by the CSA Model Code under which Swain may not be able to give an individual access to the personal information about her or him held by Swain. In this case Swain will explain the reason for this lack of access, as provided by the CSA Model Code.
To make a request, please send a letter, email or fax addressed to our Privacy Officer at the address indicated above. In your request, please include the following information:
Swain will reply to your request in no later than thirty days after receipt of the request, or if we are not able to respond within this time period, we will send you a notice of extension. If we are not able to disclose all the personal information we hold on you, we will give you a reason for our inability to do so, unless prohibited by law.
Any questions or comments about Swain’s handling of personal information should be directed to our privacy officer.
We collect and use personal, business and financial information for the following purposes:
In order to preserve the information for governmental and professional purposes, and to serve you better, we will retain and safeguard your information for as long as we determine is necessary, even if you are no longer a client. We will use appropriate technologies, and maintain high security standards to ensure the protection of your information.
With reasonable notice our client may review their personal information and request corrections if necessary. We are committed to maintaining accurate information, and urge you to notify us promptly of any changes in your personal information.
We understand that in the course of our review of your information, we may become party to personal information that you have collected on your employees, customers and other relations. We assure you that this information will be kept private and confidential and will not be released to any third party other than as may be required by law, unless consent is obtained.
During the course of our engagements we may request that you consent verbally or in writing to the collection and use of personal information. Any such consent will be voluntary on your behalf and may be withdrawn by you at any time. You will be advised if the lack of consent adversely affects the completion of our professional engagements.
We may use personal and financial information without consent if the consent is implicit in the nature of the services rendered. For example, we obviously need to gather, and provide to tax authorities, certain personal and financial information for the completion of your personal and corporate income tax returns.
We may be required to release information to regulatory bodies, governmental authorities and our professional organizations in certain limited circumstances and if appropriate, will notify you of the legal or professional requirements, which obligate us to release this information.
Each of our employees, partners and contractors is responsible for maintaining the confidentiality of all personal information to which they have access. These individuals are required to sign a confidentiality agreement binding them to this responsibility, which governs their actions, even if they leave or retire from the firm. Employees are required, as a condition of employment, to conform with our policies and procedures for protecting personal information as well as confidential business and financial information.
If you have any questions or comments about our firm’s policies and procedures regarding your privacy, we ask that you contact our Chief Privacy Officer