Privacy Policy

Mowbrey Gil LLP and Mowbrey Gil Business Advisory Services Inc. (collectively “Mowbrey Gil”) has always been aware of and careful to protect the privacy rights of our clients, as well as our partners and employees. We have always been and will continue to be committed to protecting all personal information.

As members of the Chartered Professional Accountants of Alberta, and other professional organizations, our firm, our partners, and our employees must abide by the regulations, by-laws as well as the rules of professional conduct of these organizations. Mowbrey Gil takes the privacy and confidentiality of our clients and our partners and employees very seriously, and we have developed this Privacy Policy to clearly define our ongoing commitment to protecting privacy rights.

This Privacy Policy is designed to meet the compliance standards established by Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA) as well as the Personal Information Protection Act (Alberta) (PIPA). PIPEDA and PIPA are based on the Ten Principles established by the Canadian Standard’s Association’s Model Code for the Protection of Personal Information, which principles were recognized as a Canadian standard in 1996, and address the ways in which organizations should collect, use and disclose personal information.

Our privacy policy is organized according to the Ten Principles referred to above:

1. Accountability

  • Mowbrey Gil is accountable for all personal information in our custody or control. This includes any personal information that we receive directly from sources including individual clients, partners, and employees as well as information collected indirectly through corporate and government clients. We have established policies and procedures intended to protect personal information. We have appointed a Privacy Officer (J. Nethersole who can be contacted at j.nethersole@mowbreygil.com, or by calling our office) to oversee privacy issues for Mowbrey Gil and have educated our partners and employees about our Privacy Policy and their role in protecting your personal information.

2. Identifying Purposes

Client Information

  • In most instances, Mowbrey Gil will collect, use or disclose personal information only to provide professional services to you. All professional engagements will require you to sign an engagement letter outlining the services we have been engaged to provide. By signing an engagement letter you will be assumed by us to have agreed to the collection of information sufficient to carry out the agreed engagement. If we are required to share the information collected during our engagement with anyone outside of Mowbrey Gil, except where required by statute, that fact will be disclosed in our engagement letter.
  • Your personal information may be disclosed internally, and to representatives of the Institute of Chartered Accountants of Alberta, for the purposes of determining compliance with applicable professional standards, Mowbrey Gil’s internal policies, or in the performance of quality reviews.

Employee Information

  • We collect personal information from our partners and employees in order to pay them, comply with laws, provide them with benefits, and generally manage our human resources.
  • We also collect personal information from individuals seeking employment with Mowbrey Gil.
  • When we collect personal information, except in certain circumstances where we receive unsolicited personal information from you, we inform you of the reasons why we require such information, what use will be made of it and with whom it may be shared.

3. Knowledge and Consent

i. Knowledge

Client Personal Information

  • The details of every professional services engagement are documented in each engagement letter. By signing an engagement letter you will be assumed by us to have agreed to the use of any personal information collected in order to complete the engagement. Except as described elsewhere in this policy statement, engagement letters will detail any necessary disclosure of personal information to third parties, and by signing an engagement letter, we will assume you have consented to that disclosure.

Partner and Employee Information

  • Forms used to provide human resources-related services to partners and employees will describe the process for which personal information is required and with whom it will be shared. These forms will allow for you to consent to these purposes.
  • Employment candidates will also be advised of the purposes for which their personal information is being collected, except in certain circumstances where the information provided is unsolicited, and you will be provided an opportunity to consent to the collection, use and disclosure as described.

ii. Consent

You have the option not to provide your consent to the collection, use or distribution of your personal information.

  • When a client chooses not to provide us with permission to collect, use or disclose personal information, we may be unable to provide that client with the required services.
  • Where a partner, employee or candidate for employment chooses not to provide us with permission to collect, use or disclose personal information we may not be able to employ you or to provide you with benefits.

You may withdraw your consent at any time, subject to legal or contractual restrictions and reasonable notice. Should you wish to do so, please contact our Privacy Officer and you will be informed of the implications of your withdrawing your consent.

4. Limiting Collection

  • As far as possible, we will limit the collection of personal information from clients and employees to that which is required to provide our services or operate our business.

5. Limiting Use, Disclosure and Retention

i. Use and Disclosure of Personal Information

If we intend to use your personal information for a purpose not previously consented by you, we will obtain your prior consent. There are, however, circumstances in which we may use personal information without consent:

  • in an emergency that may threaten the life, health or security of an individual; or
    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; or
  • to a government institution that has requested the information, identified its lawful authority, an 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 related to national security or the conduct of international affairs; or is for the purpose of administering any federal or provincial law; or
  • 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.

ii. Retention of Personal Information

  • In order to comply with professional standards, we are required in many cases to keep a record of the work performed by us (“working papers”). Working papers may include personal information. We secure our working papers against inappropriate access as described elsewhere in this Privacy Policy. Mowbrey Gil retains personal information about current and past partners and employees in accordance with employment laws and standards. Personal information collected on applications for employment forms, and in certain unsolicited ways, is secured against inappropriate access as described elsewhere in this Privacy Policy. If you apply for employment with us we retain the personal information you provide indefinitely so that we may consider you for a position at a future date.

6. Accuracy

In order to provide our clients with an acceptable level of service, the personal information that we collect must be accurate, complete and up-to-date. In order to provide our partners and employees with appropriate human resource services, the information collected from them must be accurate, complete and up-to-date. We may ask you on a regular basis to update your personal information. We encourage you to advise us of changes to your personal information that may be relevant to the services we are providing to you.

  • Clients should contact a member of the Mowbrey Gil team to update their personal information.
  • Employees and potential employees should contact our Office Manager should they need to update their personal information.

7. Safeguards

  • We protect your personal information using industry standard practices. We use physically secure facilities, and tools and practices designed to safeguard your personal information from any unauthorized access. We clearly define internal policies and practices as an additional safeguard.
  • Our security measures and practices are designed to prevent the loss, misuse or alteration of your personal information.
    We store personal information under our control in secure environments not available to the public. For example, access to our premises is clearly restricted, and certain rooms and filing cabinets are locked when not in use by authorized persons.
  • We have instituted measures to prevent unauthorized electronic access to personal information. Electronic information is maintained in a secure environment.

8. Openness

  • We maintain the most current version of our entire privacy policy on our website, www.mowbreygil.com, and a printed version can be obtained from our Privacy Officer by emailing j.nethersole@mowbreygil.com or by calling our office.

9. Individual Access

  • Our clients have the right to review and obtain a copy of personal information on record in our offices by contacting their engagement partner.
  • Our employees and partners have the right to review and obtain copies of their personal information on record by contacting the Office Manager.
  • We will provide, in most instances, a prompt and appropriate response to any request. You should contact our Privacy Offices of there are any concerns about the access we provide.

10. Challenging Compliance

  • We will respond to any complaints and concerns relating to privacy.
  • We will investigate and attempt to resolve all complaints.
  • If you wish to challenge compliance with this Privacy Policy, we would encourage you to send your concerns to our Privacy Officer in writing. Our Privacy Officer will ensure that a complete investigation of your complaint has been undertaken and will report their findings to you, in most instances, within 30 days.