At all times, we adhere to the requirements of the law and our professional responsibilities, and to be responsive to our clients who expect us to respect their privacy and protect their personal information.
What is personal information?
Personal information is information about an identifiable individual. It includes but is not limited to name, mailing address, telephone numbers, email address, business facsimile number, age, gender, marital status, health status, financial status, credit card information and credit history.
How do we collect your personal information?
Personal information is collected by fair and lawful means (for example, when you engage us to provide services, use the Tower Street Wealth website or speak to a Tower Street representative). We collect personal information from you and from third party service providers, where we have obtained your consent to do so or as otherwise permitted by law.
In most instances, we will collect personal information about our clients only for the purposes of providing professional services. Each engagement letter includes an explanation of why we require the information, what use will be made of it and with whom it may be shared in order to provide professional services.
We will also collect personal information about clients and prospective clients for the purpose of sending news and information updates or invitations to events hosted or sponsored by Tower Street Wealth.
How will we ask for your consent?
We generally obtain your consent prior to collecting, and in any case, prior to using or disclosing your personal information for any purpose. You may provide your consent to us either verbally, electronically or in writing. The form of consent that we seek, including whether it is express or implied, will largely depend on the sensitivity of the personal information and the reasonable expectations you might have in the circumstances.
The terms and conditions of professional services engagements are documented in each engagement letter. These terms and conditions include a discussion about how we may use and disclose your personal information. By signing the engagement letter, clients provide their consent to the collection, use and disclosure described therein.
What happens if you choose not to give us your consent?
Clients always have the option not to provide their consent to the collection, use and distribution of their personal information, or to withdraw their consent at a later stage. Where a client chooses not to provide us with permission to collect, use or disclose personal information, we may not have sufficient information to continue providing the client with our services.
How do we use your personal information?
We limit the collection of personal information to that which is reasonably required to provide our services or operate our business.
In most instances, we use personal information about clients only for the purposes of providing professional services such as the following:
- To provide clients with professional assurance and advisory services
- To invoice and collect payment for professional services and products provided by us to clients
- To register clients for events
- To register clients for, and facilitate their participation in, certain areas of our website
- To research, develop, manage, protect and improve our professional assurance, tax or advisory services
- To gather client opinions and feedback
- To develop and maintain our relationship with clients and communicate with them
- Such other uses as may be permitted or required by applicable law
Client personal information may also be disclosed internally for the purpose of determining compliance with applicable professional standards, within Tower Street Wealth internal policies or in the performance of quality reviews.
We also collect and use personal information about clients and prospective clients for the purpose of sending news and information updates or invitations to events hosted or sponsored by Tower Street Wealth or it’s affiliate companies.
Personal information may also be shared internally in order to allow us to offer services or products that may be interest to clients.
To whom do we provide your personal information?
If Tower Street Wealth intends to use personal information for any purpose not previously identified to the individual, we will obtain their prior consent.
However, Tower Street Wealth may use personal information without consent for the purposes of acting in respect of an emergency that threatens the life, health or security of an individual, including steps taken under pandemic policies, or as otherwise permitted by law including for purposes of an investigation. We may also disclose personal information without consent as permitted or required by applicable federal and provincial privacy laws, including:
To comply with a subpoena, a warrant or an order made by a court or other body with appropriate jurisdiction or to comply with rules of conduct required by regulatory bodies to a government institution that has requested the information, identified its lawful authority and indicates that disclosure is for the purpose of enforcing, carrying out an investigation or gathering intelligence relating to any federal, provincial or foreign law; or suspects that the information relates to national security or the conduct of international affairs; or is for the purpose of administering any federal or provincial law.
To an investigative body or government institution on our initiative when we believe the information concerns a breach of an agreement or a contravention of a federal, provincial or foreign law, or we suspect the information relates to national security or the conduct of international affairs.
However, we will attempt to advise our clients in each of these circumstances when permitted to do so.
How long will we utilize, disclose or retain personal information?
In compliance with professional standards, we keep a record of the work performed by Tower Street Wealth. This record, or “working papers”, may include personal information and will be retained until such working papers are no longer reasonably required for legal, administrative, audit or regulatory purposes.
How can personal information that we have collected, utilized or disclosed be reviewed?
Clients have the right to review and obtain a copy of their personal information on record in our office by contacting their engagement partner.
In most instances, individuals will receive a response to their access request within 30 days. If an individual has any concerns about the access that is provided, they are encouraged to contact our Privacy Officer at 416.256.4000.
How is it determined that personal information we have is accurate?
In order to provide clients with a professional level of service the personal information that we collect must be accurate, complete and current. From time to time, clients may be asked to update their personal information. Individuals are encouraged to advise us of any changes to their personal information that may be relevant to the services we are providing.
Clients are encouraged to contact their engagement partner to update their personal information.
What if the information we have is inaccurate?
If it is demonstrated that the personal information in our records is inaccurate or incomplete, we will amend the personal information as required. Where appropriate, we will transmit the amended information to third parties having access to your personal information.
What safeguards have we implemented to protect personal information?
Tower Street Wealth protects personal information by using physically secure facilities, industry standard security tools and practices, and clearly defined internal policies and practices. Security measures are in place to protect the loss, misuse and alteration of the personal information under our control. Personal information is stored in secure environments that are not available to the public (e.g. password-protected computer systems, restricted access premises, locked rooms and filing cabinets).
Tower Street Wealth will respond to individual complaints and questions relating to privacy. We will investigate and attempt to resolve all complaints.
To challenge compliance with this Policy, individuals should forward their concerns in writing to Tower Street Wealth’s Privacy Officer. The Privacy Officer will ensure that a complete investigation of all complaints has been undertaken and will report their findings to the individual in most instances within 30 days.
Protecting the privacy of our clients is very important to us. If you have any question or concerns about your privacy and our role in protecting it, please contact our Privacy Officer at 416.256.4000.