Each independent firm of the AC Group has a responsibility to protect personal information regarding its clients, partners and employees. Each firm believes protecting your privacy is important and has developed a privacy policy designed to meet the needs of its clients and employees and conform to the Personal Information Protection and Electronic Documents Act ("PIPEDA"). This policy covers the collection, use and disclosure of personal information by each firm.

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The Rules of Professional Conduct and related Council Interpretations of the applicable Provincial Institute of Chartered Professional Accountants require that partners and staff maintain the confidentiality of client and former client information, as well as the confidentiality of firm information, except in rare and very specific circumstances.

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The Rules of Professional Conduct of the various Provincial Institutes of Chartered Professional Accountants also require that partners and staff not use confidential information for personal advantage, for the advantage of a third party or to the disadvantage of a client, former client or the Firm, unless consent has been obtained from the client, former client or the Firm.

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Personal Information

Personal information includes any factual or subjective information, recorded or not, about an identifiable individual. This includes information in any form, such as:

• Age, name, ID numbers, income, or ethnic origin;

• Opinions, evaluations, comments, social status, or disciplinary actions; and

• Employee files, credit records, loan records, medical records, existence of a dispute with a client, intentions (for example, to acquire goods or services, or change jobs).

• Personal information does not include the name, title, business address or telephone number of an employee of an organization.

Each firm collects personal information only for the following reasons:

• To provide the products or services that you have requested and maintain commercial relations with you;

• To understand your needs and recommend products and services accordingly;

• To manage its business which includes partnership and employment matters; and

• To meet legal and regulatory requirements.

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No firm will use your personal information for any other reason without your consent and will only share your information with third parties to assist in completing the above uses. Any third party's use must adhere to the firm's privacy policies or be allowed by the legislation. Examples would be an outside payroll service, an agent hired to perform a service for you, a collection agency, a law enforcement agency or emergency services.

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Accountability

Each firm is accountable for all personal information in its possession, including any personal information disclosed to third parties for processing or other administrative functions.

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The AC Group has appointed its President and Executive Officer to be the Group's Privacy Officer, to be accountable for both the AC Group's and each firm's privacy policies and enforcement. Each firm has also trained all of its partners and staff on privacy issues.

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The AC Group's Privacy Officer can be reached at:

AC Group of Independent Accounting Firms Limited
Unit 1 - 7 Mellor Avenue

Dartmouth NS  B3B 0E8
PRIVATE EMAIL

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Identifying Purposes

Each firm shall identify the purpose for which personal information is collected before collecting it.

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Consent

Each firm shall obtain consent for all personal information collected, used or disclosed by the firm, unless such collection or use is inappropriate, or permitted by law.

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Limiting Collection

Personal information collected shall be limited to information that is necessary for the purposes identified by each firm and be collected by fair and lawful means.

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Limiting Use, Disclosure and Retention

Personal information collected by each firm, shall not be used or disclosed for purposes other than those for which it was collected, except with the consent of the individual or as required or permitted by law. Personal information shall be retained only as long as necessary for the fulfillment of those purposes.

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Accuracy

In order to provide you with a professional level of service and with appropriate benefits, the personal information that each firm collects about you must be accurate. Accuracy means both completeness and being current.

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While each firm takes reasonable steps to ensure the continued accuracy of the personal information it has retained, the accuracy of the information is dependent on the cooperation of its clients in providing appropriate updates on a timely basis. From time to time, you may be asked to update your personal information. You are encouraged to contact the engagement partner of any changes to your personal information that may be relevant to the services the firm is providing to you.

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Safeguards

Each firm shall safeguard your information against unauthorized access, disclosure, copying, use or modification.

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Openness

Each firm shall make information available, to its clients and employees, about the policies and practices that apply to the management of their information.

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Individual Access

Upon request, an individual shall be informed of the existence, use and disclosure of their information, and shall be given access to it. An individual will be given reasonable access to their information and may correct any personal information if its accuracy and completeness is challenged and found to be deficient.

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Challenging Compliance

An individual shall be able to challenge compliance with the above privacy principles. The Privacy Officer shall investigate all complaints in a timely manner.