Privacy and Confidentiality (QAM 2.2)

Privacy Policy

Rumberger & Fettis Accounting LLP and all its members shall safeguard and keep confidential any information
collected relating to clients that are required to be kept confidential and safeguarded in accordance with governing
laws, regulatory authorities, Rules of Professional Conduct/Code of Ethics, Rumberger & Fettis Accounting LLP’s
policy and specific client instructions or agreements.

Scope of Policy

Confidential information includes, but is not limited to:

    • Name or other unique identifiers;
    • Addresses, phone, fax, e-mail;
    • Age, sex, marital status, sexual orientation, personal relationships;
    • Political, religious, social, or other similar affiliations;
    • Lifestyle information;
    • Buying and consumption tendencies;
    • Financial or business information of any nature;
    • Proprietary trade information, secrets, processes, products, or market knowledge;
    • Government or other regulatory information identification numbers or similar identities; and
    • Electronic documents, data, and communications.

Collection and Retention of Information

Rumberger & Fettis Accounting LLP and all its members shall collect and retain only such personal or business
information as is necessary for the purposes required to fulfill Rumberger & Fettis Accounting LLP’s engagement
responsibilities.

Personal and client information shall be retained only as long as necessary for the fulfillment of those purposes or
for professional, regulatory, and legal requirements.

Access and Use of Information

Client information and any personal information obtained shall be used or disclosed only for the purpose for
which it was collected, except with the consent of the individual or entity or as required by law.

Upon request, an individual or entity should be informed of the existence, use, and disclosure of their personal
information and given access. Such information does not necessarily include working papers, which are the
property of Rumberger & Fettis Accounting LLP.

Staff Confidentiality Agreement

Staff is required to sign a confidentiality agreement upon commencement of employment (See Appendix C).

Role of the Privacy and Confidentiality Leader (PCL)

The OMP may designate a partner or senior staff member to be responsible for overseeing compliance with
Rumberger & Fettis Accounting LLP’s policies and procedures with regard to privacy and confidentiality.

The duties of the Privacy and Confidentiality Leader (PCL) are as follows:

  • To review federal/provincial privacy legislation and any guidance provided by the CICA;

  • To inform and train partners and staff on privacy and confidentiality policies and supporting documentation;

  • To ensure a confidentiality agreement is signed by all staff upon commencement of employment;

  • To ensure Rumberger & Fettis Accounting LLP’s privacy and confidentiality policies and procedures are

    • complete and up-to-date, including:

    • Issue resolution and management guidance, documentation tools included in checklists, work programs
      and templates;

    • Wording for inclusion in standard engagement letters and for general authorization; and

    • Maintaining protocols for all Firm members to follow, including electronic data, files,s, and information
      safeguards;

  • To develop and maintain the infrastructure required to protect the privacy and confidentiality of information
    held by Rumberger & Fettis Accounting LLP;

  • To be the authority for Rumberger & Fettis Accounting LLP in resolving questions of privacy and confidentiality;

  • To conduct periodic checks on compliance with Rumberger & Fettis Accounting LLP’s policies and procedures;
    and

  • To initiate and administer staff and partner disciplinary procedures and sanctions for non-compliance.