Personal Information Protection Policy

CFL collects, uses and discloses personal information in the possession, or under the control, of its clients to the extent required to fulfill our professional responsibilities and operate our business. The firm is committed to maintaining the privacy of personal information provided by its clients and protecting all personal information in its possession or control. The Personal Information Protection Policy sets out the procedures that our firm follows in meeting its privacy commitments to its clients and complying with the requirements of provincial privacy legislation.

The following is a brief synopsis of our Personal Information Protection Policy.

Accountability

CFL is responsible for all personal information in its possession or control. This includes any personal information that our firm received directly from clients who are individuals, or indirectly, through clients that are organizations (e.g. corporations, government entities, not-for-profit organizations).

Our firm has educated its partners and employees regarding its Personal Information Protection Policy and their role and responsibilities in keeping personal information private.

Our firm has appointed a Privacy Officer to oversee policy issues at the firm. If you have any questions about the firm's privacy policies and practices, the firm's Privacy Officer can be reached by email at privacy@cflca.com, by phone at 250-562-4522 or by letter at 1820 Third Avenue, Prince George, BC V2M 1G4.

Personal Information

CFL collects personal information from clients and uses and discloses such information, only to provide the professional services that the client has requested. The types of information that may be collected are:

Name, home address, telephone numbers, personal identification numbers (e.g. social insurance numbers, credit card numbers), financial information (e.g. income, credit ratings, payroll information, personal indebtedness), personnel information, information in medical records, information related to gender, age, and marital status).

Personal information should be distinguished from business information such as name, title, business address and telephone number, which does not fall under the privacy legislation.

The purposes for which it is collected are set our below:

Consent

The knowledge and consent of a client is required for the collection, use, or disclosure of personal information, except where inappropriate. In certain circumstances personal information can be collected, used or disclosed without the knowledge and consent of the individual (e.g. in a case of an emergency where the client is unavailable and it is clearly in the best interest of the individual).

The continued use of our services will constitute implied consent for CFL to collect, use and disclose personal information.

You may withdraw consent at any time subject to legal or contractual restrictions and reasonable notice. You may contact us for more information regarding the implication of withdrawing consent.

Employee commitment

Our employees are committed to respecting the personal information we hold in our files. Our employees have signed a letter obliging them to abide by the firm policy relating to the proper use of personal information.

Limiting Collection of Personal Information

CFL collects only that personal information required to perform its professional services and operates its business. CFL shall collect personal information by fair and lawful means. Our firm collects personal information primarily from its clients. Our firm may also collect personal information from other sources including credit bureaus, employers and personal reference, or other third parties who represent that they have the right to disclose the information.

Limitations on Use

CFL uses or discloses personal information only for purposes for which it has consent, or as required by law. Our firm retains personal information only as long as necessary to fulfill these 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.

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;

provided to members of the organization's 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 (e.g. representatives of the Canadian Public Accountability Board, or a provincial Institute of Chartered Accountants), who by law, professional regulation or contract have the right of access to the firm's files for inspection purposes.

The firm regularly and systematically archives personal information no longer required to fulfill the identified collection purposes, and no longer required by laws and regulations.

Accuracy of Personal Information

The firm endeavors to keep accurate, complete and up-to-date personal information as is necessary for the purposes for which it is to be used.

Individual clients are encouraged to contact the firm's engagement partner in charge of providing service to them to update their personal information.

Security Safeguards

CFL protects personal information by security safeguards appropriate to the sensitivity of the information.

Physical security is maintained over personal information stored in hard copy form. Partners and employees are authorized to access personal information based on client assignment and quality control responsibilities.

Authentication is used to prevent unauthorized access to personal information stored electronically.

Our firm protects personal information disclosed to a third party by contractual agreements stipulating the confidentiality of the information and the purposes for which it is to be used.

All of our employees with access to personal information are required to respect the confidentiality of that information.

Openness

Up-to-date information on the firm's Personal Information Protection Policy can be obtained from the firm's Privacy Officer.

Individual Access

Our firm will respond on a timely basis to requests from clients about their personal information which the firm possesses or controls.

Individual clients of the 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 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 the reasons why access is denied and any recourse the client may have, except where prohibited by law.

Website

When you visit our website, we take steps to respect and protect your privacy.

A cookie is information about how and when you use a site, which a web server creates when you visit. This data is placed on your computer hard drive in the form of a small text file. There are two types of cookies: session cookies and persistent cookies. Session cookies are used only for the length of time you stay on the website. When you leave the site, they expire and are no longer active. Persistent cookies are more permanent and can be re-read when you return to the site that placed them on your computer. We use persistent cookies only to identify previous visits so that you may be directed to the part of our website in which you are interested. We do not use cookies to retrieve data from your hard drive or to obtain your e-mail address or other personal information.

You may choose not to accept cookies by setting your browser options to inform you when cookies are being sent, or to deny cookies altogether. Please note, however, that by not accepting cookies you may limit the functionality that we can provide to you when you visit our website.

To help us serve you better, we automatically collect generic, non-personal information about visits to our website. We do not collect personal information such as names, ages, phone numbers, addresses or e-mail addresses from visitors to our website. We do not collect individual profile information for visitors across multiple sites and do not aggregate information from any other sources about browsing patterns of individual visitors across multiple sites.

We do collect visitor information such as IP addresses, return visits from past guests, referring pages, pages visited, and time spent on the website. We collect such non-personally identifiable information in order to obtain statistical analysis of Web page traffic patterns for our Website, and to improve our services. We collect data in aggregate form, and data is not recorded or stored about individual visitors.