Privacy Policy

In keeping with our obligations as legal professionals, we are committed to maintaining the accuracy, security and privacy of personal information in accordance with applicable legislation. Our client relationships are founded on trust and we are committed to maintaining that trust. This privacy policy describes Harris, Sheaffer LLP’s (“Harris, Sheaffer” or “we” or “us” or the “firm”) practices relating to the collection, use and disclosure of personal information provided to us. This privacy policy has been developed in order to comply with the Personal Information Protection and Electronic Documents Act(“PIPEDA”).

This Harris, Sheaffer Privacy Policy is a statement of principles and guidelines concerning the protection of Personal Information of our clients, service providers and other individuals (“you”).

Consent

BY SUBMITTING PERSONAL INFORMATION TO HARRIS, SHEAFFER, YOU AGREE THAT WE MAY COLLECT, USE AND DISCLOSE SUCH PERSONAL INFORMATION ACCORDANCE WITH THIS PRIVACY POLICY AND AS PERMITTED OR REQUIRED BY LAW. Subject to legal and contractual requirements, you may refuse or withdraw your consent to certain of the identified purposes at any time by contacting the Harris, Sheaffer Chief Privacy Officer. If you refuse or withdraw your consent, we may not be able to provide you or continue to provide you with certain services or information which may be of value to you. If you provide Harris, Sheaffer with personal information of another individual, you represent that you have all necessary authority and/or have obtained all necessary consents from such person to enable us to collect, use and disclose such personal information for the purposes set forth in this Privacy Policy.

What is personal information?

Canadian privacy legislation defines “Personal Information” broadly as information about an identifiable individual or as information that allows an individual to be identified. For the purposes of this policy, Personal Information means information about an identifiable individual as defined from time to time in applicable privacy legislation. The types of Personal information that Harris, Sheaffer may collect about you includes your name, home address, telephone number, personal e-mail address, billing and account information, information about a client’s legal issue and other information incidental to providing legal advice and services. Personal Information is to be contrasted with business information such as your name, title or position, business address, telephone number, facsimile number or e-mail address. Business information is not covered by privacy legislation.

Why do we collect your Personal Information?

In general, Harris, Sheaffer collects, uses and discloses Personal Information about our clients in order to provide our clients with professional legal services. More specifically, we collect, use and disclose your Personal Information for the following purposes:

1. To establish and manage client relationships, provide legal advice, perform legal services, fulfil legal duties, and avoid conflicts of interest. This may include the sharing of Personal Information by and between Harris, Sheaffer personnel;

2. To establish and maintain commercial relationships with clients, including to issue invoices, administer accounts, and to collect and process payments;

3. As permitted by, and to comply with, any legal or regulatory requirements or provisions; and

4. For any other purpose to which you consent.

The collection of Personal Information is limited to only that which is necessary for these purposes. We do not use Personal Information to sell to direct marketing agencies or provide it to anyone outside the firm.

To whom do we disclose your Personal Information?

From time to time, Harris, Sheaffer may disclose your Personal Information to:

1. Our insurers and to regulatory agencies such as provincial law societies, insurers or others in connection with regulatory or other activities relating to the obligations of Harris, Sheaffer and its practice of the profession of law;

2. A person who, in the reasonable judgment of Harris, Sheaffer is providing or seeking the information as your agent; and

3. Any third party or parties, where you consent to such disclosure or where disclosure is required or permitted by law.

When Personal Information must be disclosed?

Notwithstanding our commitment to protecting our client’s Personal Information, there are some limited instances where we are obliged to disclose information without consent. These are the following:

1. Where the information is known to the public; and

2. Where required by law or by order of a tribunal.

In such circumstances, we will not disclose more information than is required.

Where do we store your Personal Information?

Your Personal Information is stored in secured locations and on servers controlled by Harris, Sheaffer located at our offices.

How may you obtain access to your Personal Information?

Upon your written request, subject to certain exceptions, Harris, Sheaffer will inform you of the existence, use, and disclosure of your Personal Information and will give access to that information. Access requests should be sent to our Chief Privacy Officer, using the contact information below.

How do we protect your Personal Information?

To help protect the confidentiality of your Personal Information, Harris, Sheaffer employs administrative and technological safeguards appropriate to the sensitivity of your Personal Information. A number of measures are taken to ensure the security of our client’s Personal Information. These include the following:

1. Our staff are trained to collect and use Personal Information only as necessary to perform their duties and in accordance with our privacy policy;

2. Our firm restricts the collection of Personal Information to that required for the purposes noted above ;

3. Once Personal Information is no longer required for the purposes noted above and under the rules of the Law Society of Upper Canada, it is destroyed in due course;

4. Paper information is under supervision.

Changes to the Privacy Policy

Harris, Sheaffer reserves the right to modify or supplement this Privacy Policy at any time. If we make a change to this Privacy Policy, we will make such revised policy and changes available upon request to the Harris, Sheaffer Chief Privacy Officer. However, Harris, Sheaffer will obtain the necessary consents required under applicable privacy laws if it seeks to collect, use or disclose your Personal Information for purposes other than those to which consent has been obtained unless otherwise required or permitted by law.

Requests for access and challenging compliance

We welcome any requests to verify the accuracy of the Personal Information we have, and the identity of any parties to whom we may have had reason to disclose the information. Should any of our clients wish to make a complaint about our privacy practices, we invite them to notify our Chief Privacy Officer or contact any of our professionals who have assisted in serving them. We will investigate all complaints and provide a timely written response. Should any complaint be found to be justified, we will take appropriate measures to resolve the matter to the satisfaction of the client.

Harris, Sheaffer has appointed Michael Baum in our office as Chief Privacy Officer to oversee compliance with this Privacy Policy and applicable privacy laws. For information on Harris Sheaffer’s privacy practices, please contact the Harris, Sheaffer Chief Privacy Officer at:

Harris, Sheaffer LLP
Chief Privacy Officer
4100 Yonge Street
Suite 610
Toronto, Ontario
M2P 2B5
Tel: (416) 250-5800
Fax: (416) 250-5300

e-mail: chiefprivacyofficer@harris-sheaffer.com

For more general inquiries, the Information and Privacy Commissioner of Canada oversees the administration of privacy legislation in the private sector. The Information and Privacy Commissioner can be contacted at:

112 Kent Street
Ottawa, Ontario
K1A 1H3
phone: (613) 995-8210
toll-free: 1-800-282-1376

www.privcom.gc.ca