Approved by the Board: March 21, 2022
1. Duty of the Association and Governing Legislation
The Association of Chartered Professional Accountants of Newfoundland and Labrador (CPA NL) is a self-regulatory body established by the Chartered Professional Accountants and Public Accountants Act (the “Act”) to protect the public in the province of Newfoundland and Labrador. Regulations, By-laws and the Rules of Professional Conduct have been established in furtherance of the Act (collectively known as the “Regulatory Framework”).
Throughout this policy, “we”, “us” and “our” refer to CPA NL. “Registrant” refers to all members, firms or students that are registered with CPA NL, as defined in the Act.
CPA NL will comply with the requirements of the Act and Canada Personal Information Protection and Electronic Documents Act (“PIPEDA”). Many of the activities of CPA NL that can be classified as regulatory are not covered by PIPEDA with only so called commercial activities being subject to the act. Nevertheless in its regulatory role CPA NL will use fair and reasonable practices to meet its obligations under the legislation and any other applicable law.
2. Definition of Personal Information
Personal information does not include contact and employment information which is required by CPA NL for it to communicate with and inform its members.
In addition, information about individuals contained in the following records is not considered personal information:
- Public telephone and business directories;
- Public registries and court records;
- Publicly available printed and electronic publications.
In order to fulfill its mandate and objectives to regulate the CPA profession in Newfoundland and Labrador, CPA NL collects, uses and discloses personal information about its members. From time to time, CPA NL also collects, uses and discloses personal information about non-members.
- Members in good standing, suspended or former;
- Registered CPA Firms;
- Students registered with Atlantic School of Business.
- Non-members (ie. the general public) who register an account through the CPA NL Portal online.
CPA NL obtains your consent to collect, use and/or disclose personal information. The method of obtaining consent is through the use by members and non-members of CPA NL products and services.
In the case of members, the method of obtaining consent is through their membership application, and their continuing registration with CPA NL and/or through the use of the CPA NL website, online Portal or annual registration renewal online.
5. Collecting Personal Information
CPA NL identifies the purpose for which your personal information is being collected either before or at the time the information is actually collected.
CPA NL is permitted to collect personal information for reasonable purposes and as otherwise permitted by applicable law. When collecting personal information, CPA NL will:
- Limit the collection to what is reasonable to achieve the purposes for which the information was collected or for a use that is consistent with that purpose;
- Ensure that all individuals have the right to request access to their personal information which CPA NL collects about them;
- Ensure that all individuals have the right to seek correction of their personal information if that personal information is inaccurate;
Collection of personal information about members is done mainly through an application for membership. Updates of personal information are requested annually by CPA NL, and members are encouraged to update this information online.
CPA NL also collects personal information about members and non-members through registration forms for various programs, such as professional development seminars and courses, member functions, and other activities.
In addition, personal information may be collected in the following circumstances:
- As part of the peer practice inspection process, a Practice Inspector may view personal information of employees or clients of a registered firm. This information is seen by the Practice only, unless the Practice Inspection Committee determines that it is necessary to report a matter to the Complaints Authorization Committee (CAC) for investigation. In such case, the relevant information may be made available to the CAC.
- CPA NL or the Foundation may from time to time receive personal information relating to a scholarship application, or an application for reduction or waiver of fees for medical or financial hardship or other special circumstances. By virtue of the application itself, the member consents to personal information being used by the appropriate committee to evaluate the application.
- In the course of a complaint investigation, personal information may be obtained by either the Registrar or an investigator acting as an agent of CPA NL. As part of the investigation or discipline process, this information may be made available to the appropriate committee.
6. Using or Disclosing Personal Information
6.1 Disclosure of Personal Information to the Public
Disclosure of personal information may be required or permitted under legal duty or right, and CPA NL may disclose such information without consent. If, in the opinion of CPA NL, it is appropriate or necessary to disclose personal information due to a legal duty or right, CPA NL will only disclose such information that is necessary to fulfill such legal duty or right.
In some instances, disclosure of personal information may include broad publication of a disciplinary order. Specifically, CPA NL may publish the names of members who have been found guilty of conduct deserving of sanction and the particulars of a disciplinary order, as specified in the Act and/or by Order of an Adjudication Tribunal.
CPA NL may publish names and particulars related to restrictions, suspensions, cancellations or expulsions of registrations due to non-compliance with the Regulatory Framework through publication on the CPA NL website or via other means.
6.2 Disclosure to Other Organizations
In order to meet its regulatory and other mandates, CPA NL does exchange personal information, either in response to specific inquiries or more generally, with the following affiliated organizations:
- Chartered Professional Accountants of Canada (CPA Canada);
- The CPA Atlantic School of Business (ASB);
- Other Provincial CPA bodies, including CPA Bermuda;
- Canadian Public Accountability Board (CPAB).
6.3 Other Parties
CPA NL does provide personal information permitted under the Act to be publicly available on a limited basis to agencies engaged to provide mailing services on behalf of CPA NL when:
- in the opinion of CPA NL, such provision and exchange constitutes a service,
- the information to be mailed is pertinent to the members of CPA NL; and
- CPA NL has the written agreement of contracted agencies to adhere to specific requirements with respect to their use of such information.
7. Retention of Personal Information
CPA NL will only retain personal information for as long as reasonably necessary to fulfill the purposes for which the personal information was collected, or to meet its obligations under the Act.
Personal information about a former registrant is not actively maintained and, for so long as it is held by CPA NL, CPA NL cannot assure the accuracy of such information.
Personal information that is no longer required to fulfill the purposes for which it was collected is shredded and/or disposed of in a manner that safeguards the confidentiality of the information.
8. Access to Personal Information
Members have access to their personal information as contained in the CPA NL Portal online.
Members and non-members can request access to their personal information by submitting a written request to the Registrar by email ([email protected]) or by regular mail.
9. Correction of Personal Information
CPA NL will make reasonable efforts to ensure that the personal information obtained is accurate and complete. CPA NL relies on members and non-members to ensure that certain information about them, such as mailing addresses (regular and electronic) and telephone numbers, is current, complete and accurate.
In the event of any inaccuracies, members are encouraged to use the CPA NL Portal online to correct it wherever possible; and non-members may make a change request to the Registrar by email ([email protected]) or by regular mail.
10. Safeguarding Personal Information
CPA NL takes reasonable steps to protect personal information collected and has made appropriate arrangements to safeguard against unauthorized access, collection, use, disclosure, copying, modification, disposal or destruction of personal information. All CPA NL staff and volunteers are required to comply with policies and procedures in relation to the security, management, and protection of personal information within the custody or under the control of CPA NL.
CPA NL uses the following methods of protection:
- Physical measures, including the storage of personal information in locked filing cabinets and restricting access to offices;
- Organizational measures, including controlling access to databases and limiting access to personal information to a “need to know” basis;
- Technological measures, including the use of firewalls and passwords for personal information stored electronically;
- Investigative measures, such as where CPA NL has reasonable grounds to believe that personal information is being inappropriately collected, used or disclosed; and
- Reasonable security measures to back up data in the case of a disaster and/or catastrophe.
11. Concerns or Complaints
If an individual is dissatisfied with the way CPA NL has handled their personal information, they are entitled to submit a complaint to the Privacy Officer via email at [email protected]
or by mail:
500-95 Bonaventure Avenue
St. John’s, NL
Attn: Privacy Officer
The Privacy Officer will investigate all complaints concerning compliance and make every reasonable effort to resolve complaints including, if necessary, recommending changes to policies and procedures.
12. Website Privacy
Access to the Portal online requires the CPA ID for Registrants and a preferred email for non-members. Personal information collected through the online Portal will only be used by persons authorized by CPA NL to access the information for the purposes provided in this Policy.
12.1 Cookies, IP Addresses, and Links to Other Websites
CPA NL’s website logs IP addresses, but not the email addresses, of visitors. This real time information is aggregated, logged, and used to measure statistical information about usage of the site, including the total number of visits, page errors, average time spent on the site, and pages viewed, both in real-time, and within a certain historical time frame. CPA NL uses this aggregated information to measure the use of our website and to improve its content and usage.
CPA NL’s website may contain links to other internet sites owned and operated by third parties. While we try to provide a link only to sites that share our high standards and respect for privacy, we are not responsible for the content or the privacy practices of those sites. Since you are solely responsible for deciding whether to visit any particular site, we strongly recommend that you review the privacy policies applicable to those other websites before you proceed to visit the site or provide any personal information there. CPA NL assumes no responsibility or liability for the content and activities of these linked sites.
12.2 Regarding Third Parties
CPA NL does not sell personal information to third parties. Third parties are contracted by CPA NL to assist in operating our website and providing services to our members; therefore, these third parties may have access to personal information, if necessary, in certain circumstances.
CPA NL collects and uses confidential information communicated between members and their clients. CPA NL will take reasonable measures to protect that information in accordance with the Regulatory Framework and any applicable laws.
All contracts entered into by CPA NL with contractors that may have access to personal information will contain specific provisions requiring compliance with the Regulatory Framework and any applicable law relating to the security and privacy of personal information.
How to contact us
by calling the CPA NL Office (709)753-3090
by email to [email protected]
by fax to the CPA NL Office (709)753-3609
by mail to:
CPA Newfoundland and Labrador
500-95 Bonaventure Avenue
St. John’s, NL A1B 2X5