Privacy – SLF Legal Disclaimer
The information contained herein is intended to provide general information on various matters of interest and does not create or imply a business or professional relationship. Laws and regulations vary by jurisdiction and change from time to time; thus, the application and effect of laws can vary depending upon the unique situation of each user. Consequently, the information contained within this site should not be construed or used as legal, accounting, tax, investment or other professional advice or services. Any such reliance on this information is solely at the user’s own risk. Each user is urged to contact a qualified professional who understands the user’s specific situation in order to make an informed decision.
The information is provided as is, and neither SLF nor HLB North America make any express or implied representations or warranties, including warranties of performance, merchantability, and fitness for a particular purpose, regarding this information. SLF and HLB North America do not guarantee the completeness, accuracy or timeliness of this information.
Your use of this information is at your own risk. You assume full responsibility and risk of loss resulting from the use of this information. SLF and HLB North America will not be liable for any direct, special, indirect, incidental, consequential or punitive damages or any other damages whatsoever, whether in an action based upon a statute, contract, tort (including, without limitation, negligence) or otherwise, relating to the use of this information.
Certain links on this site lead to resources provided by third parties which are beyond the control of SLF and HLB North America. Consequently, we make no express or implied warranties as to the accuracy, timeliness or any other aspect of such information.
To the extent any of the above is not fully enforceable for any reason, the remainder shall continue to apply to the extent it is enforceable.
The use of this information is for non-commercial, informational purposes only and any copy of such must contain this entire copyright notice.
MULTI-YEAR ACCESSIBILITY CUSTOMER SERVICE PLAN
Providing Goods and Services to People with Disabilities
SLF is committed to excellence in serving all customers including people with disabilities.
SLF is committed to treating all people in a way that allows them to maintain their dignity and independence. We believe in integration and equal opportunity. We are committed to meeting the needs of people with disabilities in a timely manner, and will do so by preventing and removing barriers to accessibility and meeting accessibility requirements under the Accessibility for Ontarians with Disabilities Act.
ACCESSIBLE EMERGENCY INFORMATION
SLF is committed to providing the customers and clients with publicly available emergency information in an accessible way upon request. We will also provide employees with disabilities with individualized emergency response information when necessary.
We will ensure that our staff are trained and familiar with various assistive devices we have on site or that we provide that may be used by customers with disabilities while accessing our goods or services.
We will communicate with people with disabilities in ways that take into account their disability.
We welcome people with disabilities and their service animals. Service animals are allowed on the parts of our premises that are open to the public.
A person with a disability who is accompanied by a support person will be allowed to have that person accompany them on our premises.
Notice of temporary disruption
In the event of a planned or unexpected disruption to services or facilities for customers with disabilities i.e. no access to the elevators, SLF will notify customers promptly. This clearly posted notice will include information about the reason for the disruption, its anticipated length of time, and a description of alternative facilities or services, if available.
The notice will be placed on our door. In situations where there are booked appointments, the client will be notified via phone or email and alternate meeting arrangements will be made.
SLF will provide training to employees, volunteers and others who deal with the public or other third parties on our behalf on Ontario’s accessibility laws and on the Human Rights Code as it relates to people with disabilities. Training will be provided in a way that best suits the duties of employees, volunteers and other staff members.
Individuals in the following positions will be trained: Office Clerk, Receptionist, Managers and Partners. This training will be provided to new staff within 2 weeks of hiring.
Training will include:
- An overview of the Accessibility for Ontarians with Disabilities Act, 2005 and the requirements of the customer service standard
- SLF’s plan related to the customer service standard
- How to interact and communicate with people with various types of disabilities
- How to interact with people with disabilities who use an assistive device or require the assistance of a service animal or a support person
- How to use the computer to accommodate those with visual impairments, opening double doors for accessibility and the boardrooms that are more wheelchair accessible
What to do if a person with a disability is having difficulty in accessing SLF’s goods and services
Staff will also be trained when changes are made to your accessible customer service plan. SLF will refresh training of staff on an annual basis.
SLF will take the following steps to ensure employees are provided with the training needed to meet Ontario’s accessible laws by January 1, 2015.
INFORMATION AND COMMUNICATIONS
SLF will take the required steps to make all new websites and content on those sites conform to WCAG 2.0, Level A by January 1, 2014.
SLF will also take the required steps to make all websites and content conform to WCAG 2.0, Level AA by January 1, 2021.
SLF will take the following steps to ensure existing feedback processes are accessible to people with disabilities upon request by January 1, 2015.
Customers who wish to provide feedback on the way SLF provides goods and services to people with disabilities can do so by one of the following ways to the attention of the Office Manager:
2300 Yonge Street, Suite 1500, Box 2434,
Toronto, Ontario M4P 1E4
Tel: 416-785-5353 ext. 2201
All feedback, including complaints, will be directed to the Office Manager. Customers can expect to hear back within 2 weeks.
- SLF is committed to fair and accessible employment practices.
- We will take the necessary steps to notify the public and staff that, when requested, SLF will accommodate people with disabilities during the recruitment and assessment processes and when people are hired.
- SLF will take the necessary steps to develop and put in place a process for developing individual accommodation plans and return-to-work policies for employees that have been absent due to a disability.
- We will take the necessary steps to ensure the accessibility needs of employees with disabilities are taken into account.
- SLF will take the necessary steps to prevent and remove other accessibility barriers identified.
- SLF will take the required steps to make sure all publicly available information is made accessible upon request by January 1, 2016.
Modifications to this or other policies
- Any policy of SLF that does not respect and promote the dignity and independence of people with disabilities will be modified or removed.
- This document is available in alternative formats upon request, such as: print; electronic or large font.
ACCESSIBILITY STANDARDS FOR CUSTOMER SERVICE POLICY
PURPOSE AND POLICY STATEMENT
The goal of the Accessibility for Ontarians with Disabilities Act, 2005 (the “Act”) is to create a more accessible Ontario, by identifying, and to the extent possible, preventing, and eliminating barriers experienced by persons with a disability.
The Accessibility Standards for Customer Service (“the Standard”) has been established under the Act to ensure goods and services are, where at all possible, equally accessible to every member of the public.
We at SLF or “the Firm”) strive to make our goods and services accessible to people with disabilities. The objective of this policy (the “Policy”) is to ensure we meet the requirements of the Standard and promote its underlying core principles, described below.
The Policy applies to all persons who, on behalf of SLF deal with members of the public or other third parties. This includes our employees, volunteers, agents and contractors.
The Policy also applies to all persons responsible for the development, implementation or oversight of SLF policies, practices and procedures.
- Accessibility Report – The report required to be filed pursuant to section 14 of the Act.
- Assistive Device – Any device used to assist a person in performing a particular task or tasks or to aid that person in activities of daily living.
- Disability – Has the same definition as is provided under the Act and Human Rights Code, R.S.O. 1990, c. H.19.
- Service Animal – An animal is a service animal for a person with a disability, if it is readily apparent that the animal is used by the person for reasons relating to his or her disability; or
- if the person provides a letter from a physician or nurse confirming that the person requires the animal for reasons relating to the Disability.
- Support Person – A person who accompanies a person with a disability to assist with communication, mobility, personal care or medical needs or with access to goods or services.
- “We”, “Our” and “Staff” means SLF and its employees, volunteers, agents and contractors.
CORE PRINCIPLES OF THE POLICY
We endeavor to ensure that the Policy and related practices, policies and procedures are consistent with the following four (4) core principles:
- Dignity – Persons with a disability must be treated as valued customers as deserving of service as any other customer.
- Equality of Opportunity – Persons with a disability should be given an opportunity equal to that given to others to obtain, use and benefit from our goods and services.
- Integration – Wherever possible, persons with a disability should benefit from our goods and services in the same place and in the same or similar manner as any other customer. In circumstances where integration does not serve the needs of the person with a disability, goods and services will, to the extent possible, be provided in another way that takes into account the person’s individual needs.
- Independence – Goods and services should, where possible, be provided in a way that respects the independence of persons with a disability. To this end, we will be willing to assist a person with a disability but will not do so without the express permission of the person.
SLF has created an Accessibility Committee responsible for:
- Developing and implementing policies, practices and procedures to ensure the accessible provision of goods and services to persons with a disability.
- Developing and implementing an accessibility training program as required by the Standard.
- Developing a feedback procedure as required by the Standard.
- Filing Accessibility Reports as required under section 14 of the Act.
PROVIDING GOODS AND SERVICES TO PEOPLE WITH DISABILITIES
Policies, Practices, and Procedures
SLF shall make all reasonable efforts to ensure that its policies, practices, and procedures which impact the delivery of its goods and services to the public or to other third parties (“Customer Service Related Policies”) are consistent with the principles of dignity, equality of opportunity, integration and independence as defined above.
If SLF changes any of its practices we will include a description of these amendments on our website.
SLF strives to communicate with persons with a disability in a manner that takes into account the disabilities.
Communicating with Persons with a Disability
Our accountants and staff communicate with clients and their representatives and others in a variety of ways, including face to face interactions, letters, telephone calls and electronic communications ie emails. In determining the appropriate method and form of communication, we will take into account accessibility needs resulting from disabilities.
Clients and their representatives and others are encouraged to identify accessibility needs in communicating and interacting with SLF
All persons to whom this Policy applies will receive training on how to interact and communicate with persons with various types of disabilities.
Clients, their representatives, and other individuals are permitted, where possible, to use their own Assistive Device when on our premises for the purposes of obtaining, using or benefiting from our goods and services.
If there is a physical, technological or other types of barrier that prevents the use of an Assistive Device on our premises we will first endeavor to remove that barrier. If we are not able to remove the barrier we will ask the person how he/she can be accommodated and what alternative methods of service would be more accessible to him/her. We will make best efforts to provide an alternative means of assistance to the person with a disability.
To the extent required, the Firm will ensure that our staff is trained and familiar with various assistive devices that may be used by individuals when accessing our services and any assistive devices made available by the Firm.
Accessibility at Our Premises
We offer the following facilities and services at SLF to which the Policy applies to enable persons with a disability to obtain, use or benefit from our goods and services:
- Financial Statements and documents formatted with larger print
- Brochures or handouts in larger print (upon request)
- Improved lighting in certain areas for individuals with a vision disability
- Boardrooms that are easily accessible to those in wheelchairs
All persons to whom this Policy applies will receive training on how to use facilities or services made available on SLF premises to assist persons with a disability to obtain, use or benefit from SLF goods and services.
Persons with a disability may enter premises owned and/or operated by RioCan Management accompanied by a Service Animal, and keep the Service Animal with them if the public has access to such premises and the Service Animal is not otherwise excluded by law.
If a service animal must be excluded by law, we explain to our customer why this is the case and explore alternative ways to meet the customer’s needs.
All persons to whom this Policy applies will receive training on how to interact with persons with a disability accompanied by a Service Animal.
A person with a disability may enter premises owned and/or operated by RioCan Management Incorporated with a Support Person and have access to the Support Person while on the premises.
SLF may require a person with a disability to be accompanied by a Support Person where it is necessary to protect the health or safety of the person with a disability or the health or safety of others on the premises.
All persons to whom this Policy applies will receive training on how to interact with persons with a disability who are accompanied by a Support Person.
Notice of Temporary Disruptions
SLF will notify customers if there is a planned or unexpected disruption of a facility or service persons with a disability use to access our goods and services.
The notice will be posted and/or communicated to individuals with disabilities in a manner that is reasonable in the circumstances.
The notice will include the following information:
- That a facility or service is unavailable.
- The anticipated duration of the disruption.
- The reason for the disruption.
- Alternative facilities or services, if available.
TRAINING AND RECORDS
SLF will provide training and ongoing training as required under the Standard, to all persons to whom this Policy applies. Training will be provided to staff who deal with clients and their representatives or other third parties, and those who are responsible for client service policy development, practice or procedures as required by applicable laws.
Content of Training
Such training will include the following components:
- An overview of applicable laws related to the provision of services to individuals with disabilities.
- An overview of the Policy and any other practices, policies or procedures developed by SLF with respect to the provision of services to individuals with disabilities.
- Information regarding how to interact and communicate with individuals with various types of disabilities, including interaction with individuals who use assistive devices, support persons and/or service animals.
- Instruction on how to use any equipment or assistive devices that the Firm may have available to assist individuals with disabilities to obtain, use or benefit from SLF’s goods and services.
- Instruction on what to do if an individual with a disability is having difficulty accessing SLF services.
Training will be provided to all persons to whom this Policy applies as soon as practicable after he or she is assigned the applicable duties.
Records of the training provided, including the training protocol, the dates on which the training is provided and the number of individuals to whom the training is provided shall be maintained in accordance the requirements of the Standard
The Firm is committed to improving our client service by listening to our clients and responding to their feedback. SLF welcomes and appreciates feedback regarding this policy and its implementation. Clients and their representatives and other third parties are encouraged to provide feedback on the way SLF provides services to individuals with disabilities.
Feedback can be directed by one of the following ways to the attention of the Office Manager:
2300 Yonge Street, Suite 1500, Box 2434,
Toronto, Ontario M4P 1E4
Tel: 416-785-5353 ext. 2201
Responding to Feedback
Individuals can generally expect a response or preliminary response to their feedback within two (2) weeks of receipt by the Firm, if the nature of the feedback requires a response.
In responding to feedback, SLF will take such steps as are necessary to rectify any issues or concerns raised in a manner consistent with the Policy and our commitment to providing excellent and accessible client service. Depending on the circumstances, such steps may include requesting additional information from the individual providing the feedback, investigating specific complaints and/or providing documentation or communications in accessible formats. The Firm will advise the individual providing the feedback of the results of the feedback review process as appropriate in the circumstances.
In certain circumstances, we may be required to take more action to effectively address the complaint including but not limited to conducting an internal investigation and/or a review of SLF’s policies, practices and procedures. In such circumstances, the customer will receive an acknowledgment that the complaint has been received within two (2) weeks and we will respond to the complaint as soon as is practicable thereafter.
DOCUMENTATION TO BE MADE AVAILABLE
This Policy, and related practices and protocols shall be made available to any member of the public upon request.
Notification of same shall be posted on SLF’s website and at a conspicuous place at each premise to which this Policy applies.
FORMAT OF DOCUMENTS
SLF will provide documents, or the information contained in documents, required to be provided under the Standard, to a person with a disability in a format that takes the person’s disability into account.
QUESTIONS ABOUT THIS POLICY
For more information about the Policy or for questions regarding SLF’S policies, practices and procedures for accessible customer service please contact:
The Office Manager
2300 Yonge Street, Suite 1500,
Toronto, Ontario M4P 1E4
Tel: 416-785-5353 ext. 2201
How we will handle information we learn about you from your visit to our website.
The information we receive depends upon what you do when visiting our site. Please note that we collect no personally identifying information about you when you visit our site unless you choose to provide that information to us.
If you visit our site to read or download information such as career opportunities, press releases, blogs or online databases, we collect and store only the following information about your visit:
- The name of the domain from which you access the Internet (for example, aol.com, if you are connecting from an America Online account) and the Internet Protocol (IP) address or host name which may or may not identify a specific computer.
- The date and time you access our site.
- The pages you visit.
- The Internet address of the website from which you linked directly to our site.
These web access logs may be preserved indefinitely and used at any time and in any way necessary to prevent security breaches and to insure the integrity of the data on our servers. We generally do not collect information through the use of web browser cookies, unless noted on a particular web page. With the exception of web access and email log data that is collected from all visitors, we do not collect any information online from children.
If You Send Us an E-mail:
You may decide to send us personally identifying information (for example, your mailing address) in an electronic mail message or web-based form requesting that information or products be mailed to you. Information collected in this manner is used solely for responding to your request unless noted on the specific web page where your request is made. We generally do not share this information with other government agencies, commercial and non-commercial entities, or the public unless noted on a particular web page. Any information that you provide us with an email may be subject to disclosure under a Freedom of Information Act request. We also retain an email log of the time each message is received by the server, the source and destination address of each message, the time each message is forwarded, the delivery status of each message, and a unique email identifier number. The email log may be retained for up to 90 days.
For SITE MANAGEMENT, information from web access and email logs is collected for statistical purposes. This computer system uses software programs to create summary statistics, which are used for such purposes as assessing the number of visitors to the different sections of our site, what information is of most and least interest, determining technical design specifications, and identifying system performance or problem areas.
For SITE SECURITY purposes and to ensure that this service remains available to all users, this computer system employs software programs to monitor network traffic, to identify unauthorized attempts to upload or change information and to prevent denial of services attacks or other attacks intended to cause damage. Unauthorized modification of any information stored on this system may result in criminal prosecution.
Our website may contain links to various other organizations. Once you link to another site, please be aware that you are then subject to the privacy policies of the new site. Also, SLF is not responsible for the privacy practices employed by other sites that may link to the SLF website.
SLF PRIVACY PRINCIPLES
Principle #1: SLF is accountable for personal information in its possession or control.
SLF is accountable for all personal information in its possession or control. This includes any personal information that SLF received directly from clients who are individuals, or indirectly, through clients that are organizations (e.g., corporations, government entities, not-for-profit organizations). SLF has:
- established and put into effect policies and procedures aimed at properly protecting personal information;
- appointed Privacy Officers to oversee privacy issues at each office of the Firm.
If you have any questions about the SLF’s privacy policies and practices, please contact the following:
Toronto Privacy Officer
2300 Yonge Street, Suite 1500
Toronto, Ontario, M6A 2X1
Tel: (416) 785-5353
SLF collects personal information and uses and discloses such information only to provide the professional services that have been requested.
Principle #2: SLF identifies the purposes for which it collects personal information from clients before it is collected.
The types of information that may be collected, and the purposes for which it is collected, are set out in Principles 3 and 4 of this privacy statement.
Principle #3: SLF obtains consent before collecting personal information.
Client Personal Information
The terms and conditions of every professional services engagement are documented in an engagement letter. This engagement letter will set out your responsibility to obtain any consent(s) required under applicable privacy legislation, for collection, use and disclosure to us of personal information. By signing the engagement letter, you are formally acknowledging this responsibility.
Partner and Employee Information
Forms and applications used to provide human resources related services to partners and employees will describe the purposes for which personal information is required. By signing such forms and applications, you consent to the collection and use of this information for the purposes described.
Choosing Not to Provide Consent
At your discretion, you may choose not to provide your consent as described above. Where a client chooses not to provide consent, SLF may not have sufficient information to provide our services. Where a partner, employee or candidate for employment chooses not to provide consent, SLF may not be able to provide employment and/or benefits.
Principle #4: SLF collects only that personal information required to perform its professional services and operate its business, and such information is collected by fair and lawful means.
SLF limits, where possible, the collection of client and employee personal information to that which is required to provide our services and operate our business.
Principle #5: SLF uses or discloses personal information only for purposes for which it has consented, or as required by law. SLF retains personal information only as long as necessary to fulfill those purposes.
As required by professional standards, rules of professional conduct and regulation, SLF 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 SLF’s personnel participating in such engagement;
- Disclosed to partners and employees within SLF to the extent required to assess compliance with applicable professional standards and rules of professional conduct, and SLF’s policies, including providing quality control reviews of work performed;
- Provided to members of an organization’s audit committee and board of directors, and others in an organization that might not otherwise have access to the information, in the course of communicating aspects of the results of our engagement; 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 SLF’s files for inspection purposes.
SLF regularly and systematically destroys, erases, or makes anonymous personal information no longer required to fulfill the identified collection purposes, and no longer required by laws and regulations.
If SLF intends to use your personal information for a purpose not previously identified to you, your prior consent will be obtained, unless it is for the purpose of acting in respect of an emergency that threatens the life, health or security of an individual. We may also disclose personal information without consent in the following situations:
- 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 of regulatory bodies.
- To a government institution that has requested the information, identified its lawful authority, and indicates that disclosure is for the purpose of enforcing, carrying out an investigation, or gathering intelligence relating to any law or if the matter relates to national security.
SLF will retain personal information concerning current and past partners and employees in accordance with employment standards and laws. Personal information collected from employment applicants may be retained indefinitely.
Principle #6: SLF endeavors to keep accurate, complete, and up-to-date, personal information in its possession or control, to the extent required to meet the purposes for which it was collected.
Individual clients are encouraged to contact their engagement partner in charge of providing service to them to update their personal information.
Employees and candidates should contact the HR department should they need to update their personal information.
Principle #7: SLF protects the privacy of personal information in its possession or control by using security safeguards appropriate to the sensitivity of the information.
Physical security (e.g., restricted access, locked rooms and filing cabinets) 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. Encryption is used to prevent unauthorized access to personal information received or sent over the Internet.
For files and other materials containing personal information entrusted to a third party service provider (e.g., a provider of paper based or electronic file storage), SLF obtains appropriate assurance to affirm that the level of protection of personal information by the third party is equivalent to that of SLF.
Principle #8: SLF is open about the procedures it uses to manage personal information.
Principle #9: SLF responds on a timely basis to requests concerning personal information which the Firm possesses or controls.
Individual clients of SLF 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 partners in charge of providing service to them 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 must be denied and any recourse the client may have, except where prohibited by law.
Partners and employees have the right to review and obtain copies of personal information on record by contacting the Human Resources department.
In most cases, you should expect a response to a request within 30 days.
Links To Third Party Websites