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BROWN & BEATTIE LTD. PRIVACY OFFICER:

Ben Martin
556 Edward Avenue, Unit 71
Richmond Hill, ON, L4C 9Y5

PRIVACY COMMISSIONER OF CANADA

112 Kent Street
Ottawa, ON, K1A1H3

Privacy Policy

Introduction

This privacy policy describes how Brown & Beattie Ltd. manages privacy and personal information in compliance with the Personal Information Protection and Electronic Documents Act (PIPEDA).

Scope

This Policy applies to those who utilize information systems, business applications, networks and information owned by Brown & Beattie Ltd.:

  • Full-time employees,
  • Part-time employees,
  • Temporary supplemental staff,
  • Contractors,
  • Consultants,
  • Business partners and parties.

This Policy also applies to all information systems, data, business applications and networks, used or administered by Brown & Beattie Ltd. and to all computational environments operated by, or operated on behalf of Brown & Beattie Ltd.

Accountability

Brown & Beattie Ltd. considers the privacy of its clients to be one of the most important obligations managed by the organization. To this end, we manage our clients' information in the following ways.

Identifying purposes

We manage our clients' information as part of the normal course of doing business. One of the key items outlined in PIPEDA is the protection not only of personally identifiable information (PII) but also the protection of information related to disputes between organizations and persons as well as information related to future plans of organizations or persons. Due to the type of work we undertake for our clients, we are regularly exposed to information which falls under these definitions.

Consent

As described above, we manage our clients' information as part of the normal course of doing business. In most cases, there is implied consent for us to hold your information due to our engagement with our clients. Where implied consent is not available, we ask for written consent to collect, manage, and utilize our clients' information.

Limiting collection

We make every effort to collect as little private information as possible, collect that information from the most authoritative source and to retain that information for the minimum required period in order to complete the engagement with our client.

Limiting use, disclosure, and retention

As part of our management of our clients' information, we will not disclose information except in the following cases:

  • if disclosure is required as a normal and accepted part of the engagement, unless we are instructed otherwise
  • if we are compelled to do so by a court of law
  • if we use the services of a third party to complete some portion of the client engagement and the third party is contractually bound to adhere to our policies
  • if we gain the explicit consent of the client
  • when the information is already publicly known

Accuracy

The private information that we hold on behalf of our clients is used regularly to provide services and it must be accurate and up-to-date. Wherever possible, we will confirm critical information with our clients, but we expect to be informed of changes in a timely manner.

Safeguards

In order to fulfill our obligations to provide appropriate privacy for our clients' information, we have undertaken a program of information management which includes adherence to the ISO27002 standard for information security management. Our Security Policy outlines the controls placed on information to ensure that it remains safe. These controls are intended to protect the confidentiality, integrity and availability of information entrusted to us.

Openness

This policy and other policies related to how we manage information are available to our clients for inspection. Artifacts of compliance with these policies can be made available with reasonable request.

Individual access

Our clients are entitled to see any information we hold that relates to them as long as it does not infringe upon our commitment to another individual or organization involved in the same piece of work. Requests which require significant effort or costs to answer may incur a fee.

Challenging compliance

If any person or organization requires more information on our policies, access to private information maintained, or is concerned that we are not fulfilling our obligations under this policy, they may contact our Privacy Officer or the Privacy Commissioner of Canada at the following addresses.

Brown & Beattie Ltd. Privacy Officer
Ben Martin, 556 Edward Street, Unit 71, Richmond Hill, ON, L4C 9Y5

Privacy Commissioner of Canada
112 Kent Street, Ottawa, ON, K1A 1H3

Enforcement

Failure to comply with terms and conditions of this Policy may lead to disciplinary action being taken against the individual and in some cases could result in legal proceedings.