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Green Chencinski Starkman Eles LLP respects the privacy rights of our clients, partners and employees and has always been committed to protecting all personal information in our possession or control. We have adopted this Privacy Policy to guide how we collect, use and disclose the personal information we require in the course of fulfilling our professional responsibilities and operating our business.

While we have always taken the privacy and confidentiality of our clients very seriously, we have developed this Privacy Policy to clearly define our ongoing commitment to protecting privacy rights. Certain of the practices discussed in the Policy reflect requirements set out in both federal and provincial privacy legislation that came into effect on January 1, 2004. Our goal is to respond to the requirements of the law, and to be responsive to our clients who expect us to demonstrate our commitment to respecting their privacy and protecting their personal information.

Principle #1: The firm is accountable for personal information in its possession or control.

Green Chencinski Starkman Eles LLP is accountable for all personal information in our possession or control. To ensure accountability for all personal information collected by the firm, we have developed appropriate policies and practices, trained those firm members that deal with your personal information and appointed a Privacy Officer to ensure that we comply with PIPEDA and this Privacy Policy.

Principle #2: The firm identifies the purposes for which it collects personal information from clients before it is collected.

We collect personal information from clients and use and disclose such information, only to provide the professional services that the client has requested.

The personal information collected from a client during the course of a professional service engagement may be shared with the firm's personnel participating in such engagement; disclosed to partners and employees within the firm to the extent required to assess compliance with applicable professional standards and rules of professional conduct, and the firm's policies, including providing quality control reviews of work performed; disclosed to members of the organization’s audit committee and board of directors, and others in the company that might not otherwise have access to the information, in the course of communicating aspects of the results of our audit; and provided to external professional practice inspectors, who by law, professional regulation, or contract have the right of access to the firm’s files for inspection purposes.

Principle #3: The firm obtains a client's consent before collecting personal information from that client.

The terms and conditions of every professional services engagement are documented in each engagement letter. These terms and conditions include a discussion about how Green Chencinski Starkman Eles LLP may use and disclose your personal information. By signing the engagement letter, you will be providing your consent to the collection, use and disclosure described in the terms and conditions.

You always have the option not to provide your consent to the collection, use and distribution of your personal information, or to withdraw your 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 provide you with our services.

Principle #4: The firm limits the amount and type of personal information it collects.

The firm collects only that personal information required to perform its professional services and operate its business, and such information is collected by fair and lawful means.

Principle #5: The firm uses or discloses personal information only for purposes for which it has consent, or as required by law. The firm retains personal information only as long as necessary to fulfill those purposes.

As required by professional standards, rules of professional conduct and regulation, the firm documents the work it performs in records, commonly called working paper files. Such files may include personal information obtained from a client.

Working paper files and other files containing, for example, copies of personal tax returns are retained for the time period required by law and regulation, including Rules of Professional Conduct.

The firm regularly and systematically destroys, erases or makes anonymous personal information no longer required to fulfill the identified collection purposes, and no longer required by laws and regulations.

Principle #6: The firm endeavours to keep accurate, complete and up-to-date, personal information in its possession or control, to the extent required to meet the purposes for which it was collected.

In order to provide you with a professional level of service and with appropriate benefits, the personal information that we collect about you must be accurate, complete and current. From time to time, you will be asked to update your personal information. You are expected to advise us of any changes to your personal information that may be relevant to the services we are providing to you. Clients are encouraged to contact their engagement partner to update their personal information.

Principle #7: The firm protects the privacy of personal information in its possession or control by using security safeguards appropriate to the sensitivity of the information.

Green Chencinski Starkman Eles LLP takes all reasonable precautions to ensure that personal information is kept safe from loss or theft, unauthorized copying, use, access, modification or disclosure. Among the steps taken are:

• premises security restricting access to offices and equipment;
• technology safeguards, including security software, firewalls to prevent hacking or unauthorized computer access;
• circulating this policy to all Green Chencinski Starkman Eles LLP employees with strict instructions to act in accordance with its principles
• internal password and security policies.

We note that while we take all appropriate steps to safeguard personal information under our control, there is an inherent risk involved in the exchange of information using any form of communication, such as e-mail, telephone, facsimile, and courier service. We assume no liability for any damages you may suffer as a result of interception, alteration or misuse of information during such transfers.

Principle #8: The firm is open about the procedures it uses to manage personal information.

Up-to-date information on our privacy policy can be obtained from our website or by contacting our Privacy Officer.

Principle #9: The firm responds on a timely basis to requests from clients about their personal information which the firm possesses or controls.

Individual clients of our firm have the right to contact the engagement partner in charge of providing service to them and obtain access to their personal information. Similarly, authorized officers or employees of organizations that are clients of the firm have the right to contact the engagement partner in charge of providing service to them and obtain access to personal information provided by that client. In certain situations, however, the firm may not be able to give clients access to all their personal information. The firm will explain why access must be denied and any recourse the client may have, except where prohibited by law.

Principle #10: Clients may challenge the firm's compliance with its Privacy Policy.

Green Chencinski Starkman Eles LLP 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, please forward your concerns in writing to our Privacy Officer. The Privacy Officer will ensure that a complete investigation of your complaint has been undertaken and will report the results of this investigation to you within 30 days. Our Privacy Officer can be reached by e-mail at jeles@gcse-ca.com, by phone at 416-512-6000 and by correspondence at The Madison Centre, 4950 Yonge Street, Suite 1906, Toronto, Ontario, M2N 6K1 c/o Privacy Officer.