Privacy policy

[PLACEHOLDER: this is a starting draft, not legal advice. Have it reviewed by counsel before publication, and set the effective date and legal entity name.]

Effective date: [PLACEHOLDER: date]
Who we are: Mansel Financial [PLACEHOLDER: legal entity name]

1. What this policy covers

This policy explains how Mansel Financial (“the practice”, “we”) handles personal information collected through this website and in the course of providing accounting, bookkeeping, tax and advisory services. We are subject to the Personal Information Protection and Electronic Documents Act (PIPEDA) and follow its ten fair information principles.

2. What we collect

Through the website, we collect only what you send us: your name, email address, telephone number, company name, the service you are interested in and the message you write. The website does not use advertising or analytics cookies. [PLACEHOLDER: amend if analytics are added.]

In the course of an engagement we collect the information needed to do the work: financial records, tax slips, payroll data, banking information, identification required by the Canada Revenue Agency, and in some cases social insurance numbers. This information is collected only after an engagement letter is in place, through secure channels we agree with you, and never through the website contact form.

3. Why we collect it

• To respond to your enquiry and assess whether we can act for you
• To perform the services set out in your engagement letter
• To meet legal and regulatory obligations, including those owed to the Canada Revenue Agency and provincial authorities
• To keep records as required by law and by professional standards

We do not sell personal information, and we do not use it for marketing without your consent.

4. Consent

By sending an enquiry you consent to us using the information in it to reply. Consent for information collected during an engagement is given in the engagement letter. You may withdraw consent at any time, subject to legal and contractual restrictions and reasonable notice; withdrawing consent may mean we cannot continue to act for you.

5. Disclosure

We disclose personal information only:

• To government bodies where required to perform the work you have engaged us for, such as filing a return with the Canada Revenue Agency
• To service providers who process data on our behalf, such as accounting software, secure file transfer and email providers, under contracts that require them to protect it [PLACEHOLDER: list providers]
• To your other advisers, with your instruction
• Where required by law, a court order or a regulator

Some service providers store data outside Canada. Where that is the case, the information may be subject to the laws of that jurisdiction.

6. Retention

Working papers and client records are kept for the period required by the Income Tax Act and professional standards, generally at least six years from the end of the taxation year to which they relate, and then securely destroyed. Website enquiries that do not lead to an engagement are deleted within [PLACEHOLDER: retention period].

7. Safeguards

Personal information is protected by physical, organisational and technical measures appropriate to its sensitivity, including encrypted storage and transmission, access limited to the people doing the work, and secure destruction. No method is perfectly secure. If a breach creates a real risk of significant harm, we will notify you and the Office of the Privacy Commissioner of Canada as the law requires.

8. Access and correction

You may ask what personal information we hold about you, how it has been used and to whom it has been disclosed, and you may ask us to correct it. Write to the contact below. We will respond within thirty days, or explain why more time is needed.

9. Questions and complaints

Direct questions about this policy to the privacy officer: [PLACEHOLDER: name], (647) 887-6942, consult@manselfinancial.com. If you are not satisfied with our response, you may contact the Office of the Privacy Commissioner of Canada.

10. Changes

We may update this policy. The effective date at the top will change when we do.