Loukidelis Professional Corporation (“LPC”) is committed to properly managing the personal information of clients and others, and of all visitors to our website (jltax.ca or the “Site”) that we collect, use and disclose in the course of business.
Controlling the collection, use and disclosure of personal information is an ongoing process. We will continue to review our personal information management practices and improve them as necessary to better protect the privacy of individuals.
What Is Personal Information?
Personal information means any information about or that can be used to identify you as an individual, including information in your résumé or about your employment, the matter about which you retained or contacted LPC, your account with us and any other information that you choose to provide to LPC.
In general, personal information does not include information that might appear on a business card or information that is available in public records (including a telephone book), and it does not include corporate information such as your corporation number, business address or business telephone number.
We abide by the following principles when collecting, using and disclosing your personal information:
- We are accountable for personal information under our control.
- The purpose for collecting personal information is identified at or before the time it is collected.
- We obtain your consent before collecting, using or disclosing your personal information, except where otherwise permitted or required by law.
- We limit the personal information we collect to that which is necessary for us to conduct business and to meet our professional obligations under the Rules of Professional Conduct of the Law Society of Upper Canada.
- The personal information we collect is only used, disclosed or retained for its original intended purpose (unless you provide your consent to a different use or disclosure) and we retain it only as long as necessary for those purposes.
- We take care to ensure that the information we have is accurate.
- We safeguard the privacy of your personal information through security measures.
- We are open with you about our policies and practices related to managing your personal information.
- Upon request, we provide you with access to your personal information, subject to any limitations imposed by law.
- We address your concerns. If you have questions or concerns regarding your privacy or this Policy please contact us.
By providing us with your personal information, you consent to the collection, use and disclosure of that information as described in this Policy.
We will not, as a condition of supplying a product or service, require you to consent to the collection, use or disclosure of your personal information beyond that required to enable us to provide the services requested. The form of the consent that we will seek before collecting, using or disclosing personal information may vary depending upon the circumstances and the type of information, and includes express oral or written consent, implied consent and opt-out consent. We will consider the sensitivity of the information and the individual’s reasonable expectations in determining how consent must be given.
You may refuse to give personal information and may, subject to legal or contractual restrictions and reasonable notice, withdraw consent at any time to the continued use and disclosure of personal information previously collected. The period of reasonable notice will vary depending on the nature of the information and its purpose to LPC. LPC will inform you of the implications of refusing or withdrawing consent, which may have legal consequences or preclude LPC from providing legal or other services to you.
If you provide us with the personal information of another individual, you represent and warrant that you have the authority to do so, including where applicable that you have obtained the necessary consent of the other person for us to collect, use and/or disclose their personal information.
Collection of Personal Information
We will not collect personal information indiscriminately. We will limit the amount and the type of information we collect to that necessary to fulfill the purposes we have identified to you, or as otherwise permitted or required by law.
We collect and use personal information
- to determine whether we can act for or against you, including to identify conflicts of interest;
- to offer and provide legal services to you and to communicate with you about our firm and our services;
- to administer our client records and to bill for our services;
- to fulfill our legal and professional obligations; and
- as permitted or required by law or for purposes for which you otherwise provide your consent.
When possible, we will collect personal information from you directly. However, to provide legal services to clients or for legal, administrative, marketing or management purposes, we may also collect personal information through outside sources such as credit bureaus, government agencies or institutions or through other third parties such as employment and other references, employers and service providers.
Internet Server Provider
Certain other information may be collected on the Site through various technologies, described below, without your actively providing the information.
Our website is hosted on servers shared with an Internet service provider (ISP). Any personal information collected on our behalf by the ISP, such as server log data (see below), is managed in accordance with this Policy and is protected by applicable law.
Certain information about Internet users’ traffic patterns is passively and automatically collected and linked to users’ Internet Protocol (“IP”) addresses. These unique IP addresses are assigned to all Web users by their ISPs, and are automatically logged by Internet servers. While the IP address itself does not identify an individual, it may, in appropriate circumstances such as an investigation of a security breach, be used with the cooperation of the ISP to locate and identify an individual using the website.
In the normal course of establishing and maintaining Internet connections, our servers automatically log information about visits to our website. Server logs record statistical information, such as a visitor’s IP address and type of operating system, the time and duration of visit and Web pages requested. The server logs also identify categories of visitors by items such as domain and browser type. These statistics are reported in aggregate form to us and are used to improve our website and ensure that it provides the optimal online experience for visitors.
We do not link server log information to any other data in a way that would enable us to identify individual visitors, except for security purposes, as discussed above.
Like many other websites, our Site makes use of “per session” cookie technology. Per session cookies are small text files that contain a unique identification number that is automatically deposited on a visitor’s computer. These cookies track information during an open session and are stored only temporarily in your computer’s memory. This information helps us determine the total number of visitors to the Site on an ongoing basis and the types of Internet browsers (e.g., Firefox, Chrome or Internet Explorer) and operating systems (e.g., Windows or Macintosh) that our visitors use. We use this information to facilitate and enhance your online visits. We do not cross-reference this information with any type of personal information that is voluntarily offered through the Site.
Use of Personal Information
We use personal information only as described in this Policy or as otherwise permitted or required by law. Before your personal information is used or disclosed for a new purpose, we will ask for your consent unless use or disclosure without your consent in the circumstances is otherwise permitted or required by law.
LPC generally uses personal information about clients for the provision of legal advice, including obtaining and carrying out client instructions, reporting and communicating with clients, billing and accounting, and protecting against fraud, illegal activities or error. LPC may also use your personal information to maintain our knowledge management system and to manage our business. We may also use personal information to send you newsletters about our services or about legal developments that we think would interest you and to invite you to client functions, seminars and sporting or cultural events.
If you send personal information through our Site, we will use it to assess website use and traffic, and to respond to your feedback, questions and comments.
Disclosure of Personal Information
We disclose personal information only as described in this Policy, with your consent, or as otherwise permitted or required by law. To provide legal services, we may sometimes disclose our clients’ personal information to third parties, including foreign agents and government or regulatory agencies. We may disclose personal information
- to third parties when it is necessary to do so to provide legal services to you – for example, when we engage an expert or consultant on your behalf in a matter or when we retain another law firm or agent to act or assist us on your behalf;
- to service providers, inside or outside Canada, retained by LPC to assist us with marketing or other services, including technical support and mailing. We limit the service provider’s right to use the personal information only for the services it provides to us, and we require the service provider to maintain the confidentiality of the personal information and to take steps to protect the security of the personal information we give it where you have instructed us to disclose your personal information to a third party for a designated purpose. Personal information provided to third parties outside of Canada is subject to the laws of those jurisdictions outside of Canada.
- to third parties to assist us in evaluating your creditworthiness or to collect debts outstanding on an account;
- to anyone who we reasonably believe is your agent;
- to our insurers and to regulatory agencies in connection with regulatory or other activities relating to the obligations of LPC and its professional responsibilities in relation to the practice of law;
- in connection with a business transaction involving LPC; and
- to third party or parties, where you consent or where such disclosure is required or permitted by law.
Your personal information may be processed, accessed and/or stored in Canada or another jurisdiction, and will be subject to the laws of that jurisdiction.
Retention of Personal Information
LPC will retain information, including personal information, for as long as it is needed for the purposes for which it was collected. For example, if you send us personal information electronically to apply for employment with LPC, we will retain your personal information for a reasonable period to permit future consideration for employment. LPC may also be subject to legislative requirements regarding the retention of certain types of information.
Protection of Personal Information
We use the standard safeguards of the legal profession to protect the security of personal information in our possession, including physical, organizational and technological measures.
Your Access to Your Personal Information
You can ask to view your personal information by writing to us (for contact information, please see jltax.ca/contact). You can request that corrections be made where you can show that the information we possess is inaccurate. Please note that under certain circumstances, you may not be permitted access because, for example, the disclosure of your records would cause security, legal or confidentiality concerns.
Links to Other Websites
The Site may contain links to other websites. While we try to link only to websites that share our standards and respect for privacy, we are not responsible for the content or privacy practices of other websites. We strongly encourage all Site visitors to review the privacy statements and policies of all external websites.
LPC operates a video camera near its main entrance to deter theft, protect the confidential information of clients and assist law enforcement with the investigation of unlawful activities on LPC premises.
The camera is installed near the main entrance. The camera captures the following data:
- The camera captures still images of all persons entering or leaving the premises, 24 hours per day, 7 days per week. Consideration was given to setting the camera to take images only outside of business hours, but the firm experienced a theft in the fall of 2015 that appears to have taken place during business hours while a lawyer had the door to his office closed.
- The operator of the camera (John Loukidelis or “John”) can monitor a live feed of the entrance during business hours, but he will do so only if the firm’s receptionist is not at her desk.
- The operator of the camera can also monitor a live feed from his cell phone, which he typically does only outside of business hours and then only if the system notifies him that someone has entered the premises.
The camera can record video and sound, and it can pan and tilt 360 degrees. The operator of the camera will use these functions only in the event the system has detected an unauthorized person accessing the premises or for testing purposes after giving notice to the occupants of the office.
Only John can operate the camera, view the still images it generates, monitor its feed and access the data generated by the camera. All of the foregoing data is password-protected.
The only data retained by the system on a regular basis are the still images of persons entering and leaving the premises. These images are retained for 30 days and then permanently deleted unless their retention is necessary for investigative purposes.
John will attempt to notify all persons affected if recorded data about them is inadvertently disclosed (ie disclosed otherwise than in accordance with this policy).
John can answer questions about this policy and compliance with it.
Individuals who wish to obtain copies of the data recorded about them by the system should contact John at http://jltax.ca/contact.
Changes to This Policy
We may amend this Policy at any time. We will post the Policy as amended on our website and will take reasonable steps to inform you of any amendments. We will obtain the necessary consents required under applicable privacy laws if we seek 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.
More Information About LPC’s Privacy Practices
Please contact us with any questions or concerns you have about this Policy or LPC’ handling of your personal information. We will investigate and respond to your concerns.