At Doug Nicholson & Co., CGA, respecting privacy is an important part of
our commitment to our clients and employees. That is why we have developed The Doug Nicholson & Co.,
and guidelines regarding the minimum requirements for the protection of personal information
provided by us to their clients and employees. The objective of The Policy is to promote
responsible and transparent personal information management practices in a manner consistent
with the provisions of the Personal Information Protection and Electronic Documents Act (Canada).
Summary of Principles
Principle 1 - Accountability
We are responsible for personal information under our control and to be accountable for our compliance with the following principles.
Principle 2 - Identifying Purposes for Collection of Personal Information
We will identify the purposes for which personal information is collected at or before the time the information is collected.
Principle 3 - Obtaining Consent for Collection, Use or Disclosure of Personal Information
The knowledge and consent of a client or employee is required for the collection, use, or disclosure of personal information,
except where inappropriate or required by law.
Principle 4 - Limiting Collection of Personal Information
We will limit the collection of personal information to that which is necessary
for the purposes identified by us. We will only collect personal information by fair
and lawful means.
Principle 5 - Limiting Use, Disclosure, and Retention of Personal Information
We will not use or disclose personal information for purposes other than those for
which it was collected, except with the consent of the individual or as required by law.
Principle 6 - Accuracy of Personal Information
We will strive to keep our personal information as accurate, complete, and up to
date as is necessary for the purposes for which it is to be used.
Principle 7 - Security Safeguards
We will protect personal information by our implemented security safeguards appropriate to the sensitivity of the information.
Principle 8 - Openness Concerning Policies and Procedures
We will make readily available to clients and employees specific information
about our policies and procedures relating to the management of personal information.
Principle 9 – Client and Employee Access to Personal Information
We will inform our client or employee of the existence, use, and disclosure
of his or her personal information upon request and shall give the individual
access to that information. A client or employee is able to challenge the
accuracy and completeness of the information and have it amended as appropriate.
Principle 10 - Challenging Compliance
A client or employee will be able to address a challenge concerning compliance with
Scope and Application
adhere to the ten principles as a whole. Each principle must be read in conjunction with
the accompanying commentary. As permitted by the Personal Information Protection and
drafted to reflect personal information issues specific to Doug Nicholson & Co., CGA.
by Doug Nicholson & Co., CGA in the course of commercial activities.
whether oral, electronic or written.
of the following information by Doug Nicholson & Co., CGA:
(a) an employee’s name, title or business address or telephone number;
(b) information that we collect, use or disclose for journalistic, artistic or literary
purposes and do not collect, use or disclose for any other purpose; or
(c) other information about the individual that is publicly available and is
specified by regulation pursuant to the Personal Information Protection and
Electronic Documents Act (Canada).
Doug Nicholson & Co., CGA’s corporate clients. However, such information may
be protected by other policies and practices or through contractual arrangements.
of the Personal Information Protection and Electronic Documents Act (Canada),
the regulations enacted there under, and any other applicable legislation or regulation.
Collection: The act of gathering, acquiring, recording, or obtaining
personal information from any source, including third parties, by any means.
Consent: Voluntary agreement for the collection, use and disclosure of personal information
for defined purposes. Consent can be either express or implied and can be provided directly
by the individual or by an authorized representative. Express consent can be given orally,
electronically or in writing, but is always unequivocal and does not require any inference
on the part of Doug Nicholson & Co., CGA. Implied consent is consent that can reasonably
be inferred from an individual’s action or inaction.
Client: An individual who purchases or otherwise acquires or uses any of
Doug Nicholson & Co., CGA’s products or services or otherwise provides personal information
to Doug Nicholson & Co., CGA in the course of Doug Nicholson & Co., CGA’s commercial activities.
Disclosure: Making personal information available to a third party.
Employee: An employee of or independent contractor of Doug Nicholson & Co., CGA.
Personal information: Information about an identifiable individual, but does not include
the name, title, business address or telephone number of an employee of an organization.
Third party: An individual or organization outside of Doug Nicholson & Co., CGA.
Use: The treatment, handling, and management of personal information by and
within Doug Nicholson & Co., CGA or by a third party with the knowledge and
approval of Doug Nicholson & Co., CGA.
please contact Office Manager at (204) 772-6338 or via Contact us.
Please visit the Privacy Commissioner of Canada’s web site at www.privcom.gc.ca.