PRIVACY STATEMENT

Trowbridge International Tax

Privacy Statement

Last updated: July 13, 2022

Introduction

This Privacy Policy applies to Trowbridge International in its collection, use, and disclosure of personal information in the course of commercial activities. These standards are in addition to our usual professional obligations of confidentiality relating to all client information in accordance with the rules established by the Institutes of Chartered Accountants.

Trowbridge does not collect, use or disclose personal information except for the purposes of conducting its business of providing professional services to its clients. Trowbridge reserves the right to modify the terms and conditions of this Privacy Policy at any time, and such modifications shall be effective immediately unless otherwise provided.

The Protection of Personal Information

Trowbridge collects, uses, and discloses personal information in accordance with all applicable laws, which reflect the principles articulated in the Personal Information Protection and Electronic Documents Act (Canada).

Personal information is information about an identifiable individual, recorded in any form and includes, but is not limited to, such things as race, ethnic origin, age, marital status, religion, education, medical, criminal, employment or financial information, address and telephone number or numerical identifiers such as a Social Insurance Number. It does not include the name, title, business address, or business telephone number of an employee of an organization.

How we use information about you?

Use of personal information to provide services to our clients.

We will use your personal data to provide you with services. As part of this, we may use your personal data in the course of correspondence relating to the services. Such correspondence may be with you, other members of the Trowbridge Network, our service providers, or competent authorities. We may also use your personal data to conduct due diligence checks relating to the services.

Because we provide a wide range of services to our clients, the way we use personal data in relation to our services also varies. For example, we might use personal data:

about a client’s employees to help those employees manage their tax affairs when working overseas;

to support a client in the course of a forensic investigation;

about a client to help him/her complete a tax return.

Use of personal information for other activities that form part of the operation of our business

We may also use your personal data for the purposes of, or in connection with:

applicable legal or regulatory requirements;

requests and communications from competent authorities;

client account opening and other administrative purposes;

financial accounting, invoicing, and risk analysis purposes;

client relationship purposes, which may involve: (i) sending you thought leadership or details of our products and services that we think might be of interest to you; (ii) contacting you to receive feedback on services; (iii) contacting you for other market or research purposes; or (iv) managing our own customer relationship management processes;

recruitment and business development purposes (for example testimonials from a client’s employees may be used as part of our recruitment and business development materials with that employee’s permission);

services we receive from our professional advisors, such as lawyers, accountants and consultants;

data analytics to better understand your digital interactions with us;

protecting our rights and those of our clients.

The legal grounds we use for processing personal information

We are required by law to set out in this privacy statement the legal grounds on which we rely in order to process your personal data.

As a result, we use your personal data for the purposes outlined above because : (a) of our legitimate interests in the effective delivery of our services to you; (b) of our legitimate interests in the effective and lawful operation of our business so long as such interests are not outweighed by your interests; (c) of the legal and regulatory obligations that we are subject to, such as keeping records for tax purposes or providing information to a public body or law enforcement agency or (d) the information is required in order to provide our services to you.

To the extent that we process any sensitive personal data relating to you for any of the purposes outlined above, we will do so because either: (i) you have given us your explicit consent to process that data; (ii) we are required by law to process that data in order to ensure we meet our ‘know your client’ and ‘anti-money laundering’ obligations (or other legal obligations imposed on us); (iii) the processing is necessary to carry out our obligations under employment, social security or social protection law; (iv) the processing is necessary for the establishment, exercise or defense of legal claims or (v) you have made the data public.

Where we are legally required to obtain your explicit consent to provide you with certain marketing materials, we will only provide you with such marketing materials where we have obtained such consent from you.

Who we disclose your information to?

In connection with one or more of the purposes outlined in the “How we use information about you?” section above, we may disclose details about you to: other members of the Trowbridge Network; third parties that provide services to us, and/or the Trowbridge Network; competent authorities (including courts and authorities regulating us or another member of the Trowbridge Network); your employer and/or their advisers; your advisers; credit reference agencies or other organizations that help us make credit decisions and reduce the incidence of fraud and other third parties that reasonably require access to personal data relating to you for one or more of the purposes outlined in the “How we use information about you?” section above.

In certain circumstances, information may be stored, processed, or accessed outside of Canada by us, a service provider, or a local subcontractor, and such information may be subject to disclosure under the laws of other jurisdictions. These laws may not provide the same level of protection as Canadian privacy laws.

Further details of the transfers described above and the adequate safeguards used by Trowbridge in respect to such transfers (including copies of relevant agreements) are also available from us by contacting info@trowbridge.ca.

We may also need to disclose your personal data if required to do so by law, a regulator, or during legal proceedings.

Protection of your personal information

We use a range of physical, electronic, and managerial measures to ensure that we keep your personal data secure, accurate, and up to date.

These measures include:

education and training to relevant staff to ensure they are aware of our privacy obligations when handling personal data;

administrative and technical controls to restrict access to personal data on a ‘need to know’ basis;

technological security measures, including firewalls, multi-factor authentication, encryption, and anti-virus software;

secure encrypted client portal, maintained by a third-party US-based software vendor, Thomson Reuters, and the documents that reside within it, reside on a US server.

Although we use appropriate security measures once we have received your personal data, the transmission of data over the internet (including by e-mail) is never completely secure. We endeavor to protect personal data, but we cannot guarantee the security of data transmitted to us or by us. Trowbridge will not email attachments with sensitive personal information nor will we request emails with such attachments.

How long we keep your information for?

We will hold your personal data on our systems for the longest of the following periods: (i) as long as is necessary for the relevant activity or services; (ii) any retention period that is required by law or professional standards; (iii) the end of the period in which litigation or investigations might arise in respect of the services or (iv) as directed by Trowbridge's own internal retention policies or practices, the length of which may vary depending on the nature of the information that is held. Further, any copies of personal data stored in our electronic backups will be destroyed in accordance with that backup’s ordinary lifecycle.

Your rights

You have various rights in relation to your personal data. In particular, you have a right to:

obtain confirmation that we are processing your personal data and request a copy of the personal data we hold about you;

ask that we update the personal data we hold about you, or correct such personal data that you think is incorrect or incomplete;

ask that we delete personal data that we hold about you, or restrict the way in which we use such personal data;

withdraw consent to our processing of your personal data (to the extent such processing is based on consent);

To the extent prescribed by applicable law, receive a copy of the personal data concerning you, which you have provided to us, in a structured, commonly used, and machine-readable format and to transmit such personal data to another party (to the extent the processing is based on consent or a contract);

object to our processing of your personal data.

To exercise any of your rights, or if you have any other questions about our use of your personal data, please email info@trowbridge.ca. You may also use these contact details if you wish to make a complaint to us relating to your privacy.

Right to complain

If you are unhappy with the way we have handled your personal data or any privacy query or request that you have raised with us, you have a right to complain to the Data Protection Authority (“DPA”) in your jurisdiction. If you would like to be directed to the appropriate DPA, please contact us.