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General

Abacus Group (hereafter “Abacus”, “we”, “us” or “our”) respects the privacy rights of our clients, principals and employees and is committed to protecting all personal information acquired in the course of fulfilling professional responsibilities.

The Privacy Policy sets out a summary of principles and procedures that Abacus follows in meeting its privacy commitments, and complying with the requirements of laws and regulations under applicable privacy laws in Canada, including the Personal Information Protection and Electronic Documents Act.

Abacus reserves the right to update and modify this Privacy Policy from time to time. We recommend that you review this policy periodically to stay aware of any changes. The date on which this Privacy Policy was last amended appears at the bottom of this page.

Principle #1 – Accountability

Abacus is accountable for all personal information in our possession or control, which includes information that we receive both directly (e.g.: clients, principals, employees, etc.) or indirectly (e.g.: government, regulatory bodies, etc.).

Abacus has: (i) established and effected policies and procedures aimed at properly protecting your information; (ii) educated its staff and associated personnel regarding such policies and procedures along with their roles and responsibilities in protecting personal information; and (iii) appointed a Chief Privacy Officer, to oversee privacy issues.

Principal #2 – Communication

With our clients

Abacus may collect, use or disclose personal information for the purposes of providing professional services.  Engagement letters issued to clients include details on the reasons why Abacus would require certain personal information, how it will be used, and whom it may be shared with to fulfil our mutually-agreed service requirements. Abacus may also collect and use personal information about clients, prospective clients, and alumni, for the purposes of sending news and information updates or invitations to events hosted or sponsored by Abacus.

With our principals and employees

Abacus collects personal information about principals, employees, and contract personnel in order to remunerate or provide benefits to them, comply with laws and regulations, administer performance management tools, to improve internal program offerings, policies and procedures.  We will also collect personal information to establish, manage or terminate employment. In certain cases, Abacus may also aggregate employee personal information to provide business metrics to evaluate the effectiveness of our Human Resource programs, but this aggregated information will be anonymous.

We may also use or disclose principal or employee information in the course of investigating, negotiating or completing a business transaction (e.g.: purchase, sale, etc.).

When Abacus collects personal information, we will inform you of the reasons why we require the information, how it will be used, and with whom it may be shared. Collection may occur without knowledge or consent, as permitted by law (e.g.: investigations).

Principal #3 – Consent

With our clients

Abacus issues engagement letters with Terms and Conditions, including a section on how Abacus may use and disclose your personal information. By signing of the engagement letter, the clients will provide consent to the collection, use and disclosure of such information.

With our principals and employees

Abacus will explain your options and obtain your implicit or explicit consent at the time of collecting, using or disclosing your personal information. We will always collect personal information by fair and lawful means (e.g.: application forms). Principals and employees will be advised on the purposes of which their personal information is being collected.

You do not consent or you withdraw consent

Abacus clients are always given the option not to provide their consent to the collection, use and distribution of their personal information.  Clients may also choose to provide consent initially, and withdraw their consent at a later point in time.  Where a client chooses not to provide us with permission to collect, use or disclose personal information, we may not have sufficient information to continue our professional services.

Where a principal, employee or an applicant to the firm chooses not to provide us with permission to collect, use or disclose personal information, we may not be able to employ them, continue to employ them or provide them with our wellness and benefits package.

Principal #4 – Limitation of Information Collected

Abacus will limit the amount and type of personal information we collect to that which is reasonably required to provide our services or continue our operations.

Principal #5 – Disclosure and Retention

If Abacus intends to use personal information for any purpose, other than that previously identified, we will obtain consent.  However, Abacus may use personal information without consent for the purpose of acting in respect of an emergency that threatens life, health or security of an individual, or otherwise permitted by law including for purposes of an investigation.

We may also disclose personal information without consent as permitted or required by the applicable federal and provincial privacy laws, including: (i) to comply with a subpoena, a warrant or order made by the court or other body with appropriate jurisdiction; (ii) to comply with the rules of professional conduct, as required by our regulatory bodies; (iii) to a government institution, requesting the information; and (iv) to investigative body, where we believe the information concerns of a breach of an agreement, contravention of federal, provincial or foreign law, or we suspect information relates to national security or international affairs.

In compliance with the professional standards, we keep a record of work performed by Abacus principals and employees. This may include personal information that may be retained until no longer reasonably required for legal, administrative, audit or regulatory purposes.  All records are safeguarded against inappropriate access (see Principal #7).

Abacus retains personal information about current and past principals and employees in accordance with employment laws and standards. We will destroy human resource records containing principal and employee personal information until no longer reasonably required for legal, administrative, audit or regulatory purposes.  Certain additional information may be retained to administer and keep former principals and employees informed about our alumni program. Former principals and employees may request at any time that they do not wish to be informed about the alumni program.

Abacus collects personal information from potential applicants, which is retained for 2 years so that Abacus may contact the applicant about other positions that may also be of interest. Should another suitable position at Abacus become available within this 2-year period, Abacus may contact the applicant to discuss this other position.  If Abacus contacts the applicant to discuss another position, the applicant’s information will be retained for an additional 2-year period. If a candidate is hired, the personal information collected during the application process is retained in order to establish, manage or terminate the employment relationship.

Principal #6 – Accuracy

In order to provide our professional services to our clients and provide benefits to our principals and employees, the personal information we collect must be complete, accurate and up-to-date.

From time to time, clients, principals and employees may be asked to update their personal information.  Clients, principals and employees are encouraged to advise us of any changes to their personal information that may be relevant to the services we are providing. Clients should contact their engagement principal to update their personal information. Employees and applicants to the firm should contact the human resources service team to update their personal information.

Principal #7 – Safeguards

Abacus protects the privacy of personal information in its possession or control by using safeguards appropriate based on the sensitivity of information. We have implemented security measures (i.e. physical, logical, organizational and contractual) to protect your personal information from loss or theft, unauthorized access, disclosure, copying, use or modification.

Principal #8 – Transparency of Procedures

Abacus will be transparent about procedures used to manage your personal information through our privacy policy or by contacting our Chief Privacy Officer (see Principal #9).

Principle #9 – Timely Response

Abacus will respond on a timely basis to requests from its clients, principals and employees about their personal information, which Abacus possesses or controls.  We will generally make available to you any personal information that we have collected about you, utilized or disclosed, upon your written request, to the extent permitted or required by law.

If there is a question in regards to the accuracy or completeness of your personal information, you may request to make changes at any time. For any requests for changes to your personal information, we will require identity validation, and we will then amend your personal information as required.

We will attempt to respond to your written requests within a reasonable time frame, not later than (15) business days after receipt of such requests. We will advise you if we are unable to meet your requests within this time frame.

Principal #10 – Challenge Compliance

Abacus will respond to individual complaints regarding this Privacy Policy. We will investigate and attempt to address all complaints.  To challenge compliance with this Policy, individuals should forward their concerns in writing to the Chief Privacy Officer, who will ensure that a complete investigation is undertaken.  A report of findings will be completed within a reasonable time frame, not later than (15) business days after receipt of such requests. We will advise you if we are unable to meet your requests within this time frame.

All comments, questions, concerns or complaints regarding your personal information or our Privacy Policy and practices, should be forwarded to our Chief Privacy Officer, as follows:

By mail:
Attn: Chief Privacy Officer
Abacus Group

143 Willowdale Ave.

Toronto, Ontario

 

We will inform you of the relevant procedures when you make an inquiry or lodge a challenge or complaint.

 

Last revised: February 24, 2019