Cecconi Simone Privacy Policy


At Cecconi Simon Inc. (“Cecconi Simone”, “we”, “our”, or “us”), we are committed to protecting the privacy and the confidentiality of personal information of our clients (“Clients”) and employees (“Employees”). In order to comply with applicable privacy legislation and to instil confidence in our Clients and Employees that the personal information they entrust to us is safe, we have developed this Privacy Policy. We want our Clients and Employees to know why we ask for their personal information, how we use it, what safeguards we employ, and how to contact us with privacy-related questions. 

In this Privacy Policy, “Personal Information” means information that specifically identifies a Client or Employee and is provided to or collected by Cecconi Simone. The type of personal information Cecconi Simone collects, uses and discloses may include a Client’s or Employee’s name, age, gender, residential mailing address, residential phone numbers or email addresses, financial, credit, and banking information, social insurance number (and other identification numbers), employment experience (past and present) and records, health information and tax records. We may also collect, use and disclose photographs of work we have performed at a client’s residence or business. Personal Information does not, however, include a Client’s or Employee’s business title, business address or business telephone number in such individual’s capacity as an employee of an organization or enterprise.

In this Privacy Policy, “Personal Health Information” includes information concerning an Employee’s physical or mental health collected or generated in the course of Cecconi Simone providing an Employee with health services or benefits. In the case of Employee, Personal Information will also include Personal Health Information and all applicable information contained in the Employee’s personnel file. 


Identifying The Purposes and Use of Personal Information 

Before collecting any Personal Information, Cecconi Simone will identify why the Personal Information is required and how it will be used. This Personal Information is documented and kept on file at Cecconi Simone’s offices at 1335 Dundas Street West, Toronto, Ontario, M6J 1Y3. Cecconi Simone will obtain the Client’s or Employee’s consent before using or disclosing Personal Information for purposes other than the original reasons given. 

Cecconi Simone collects and uses a Client’s Personal Information for the following purposes:
• Collecting, recording and using Personal Information relevant to the performance of the services rendered to and for a Client 
• Recording and determining the services received by a Client during his or her relationship with us 
• Administration, billing, accounting and collection in relation to a Client’s relationship with us 
• Protecting against fraud and error 
• Offering a Client additional products and services which may be of interest to such Client 
• Notifying Clients of upcoming seminars or other speaking engagements organized by Cecconi Simone 
• Communicating with a Client generally or to ensure Client satisfaction 
• Improving the goods and services offered to Clients in the future
• Showcasing the work performed by us at a Client’s residence or business in trade and industry publications and through other mediums
• Communicating the Personal Information to an agent, intermediary or other third party during the course of a contract or mandate for the performance of any of the purposes listed in this Privacy Policy
• Complying with all applicable laws 
• Such other specific purposes which are communicated to a Client or Employee by Cecconi Simone and its representatives before collection 

Cecconi Simone collects and uses an Employee’s Personal Information for the following purposes:

• Decision-making regarding an Employee’s hiring, duties, transfer, training, discipline, promotion and retention
• Recording and determining an Employee’s eligibility for participation in various Cecconi Simone benefit plans, including group RRSP/DPSP, health and dental benefits 
• Compliance with all municipal, provincial, federal and other applicable laws regarding an Employee 
• Recording and maintaining an Employee’s attendance record, service award and bonuses record, performance evaluations, performance improvement plans, remuneration details, or maintaining any other necessary information for establishing, managing or terminating the employment relationship (including its related benefits), as well as the determination of the applicable income and benefits 
• Such other specific purposes which are communicated to the Employee by 
Cecconi Simone and its representatives before collection 

We may use, share and disclose a Client’s or Employee’s Personal Information to our affiliates, associates, agents, suppliers, and such other third parties as Cecconi Simone, acting reasonably, may deem necessary for the fulfillment of the purposes noted above or where otherwise permitted by law. In the unlikely event that Cecconi Simone or substantially all of its assets are acquired by a third party, a Clients and Employee’s Personal Information may be one of the assets transferred to such third party. 


I Consent 

Except in certain extraordinary circumstances, Cecconi Simone does not collect, use or disclose a Client’s or Employee’s Personal Information without their knowledge and consent. Such extraordinary circumstances may include, without limitation, when legal, medical or security reasons make it impossible or impractical to obtain consent. A Client’s and Employee’s consent will be obtained at the time of collection of the Personal Information, or when a new use for the Personal Information is identified. A Client or Employee may withdraw their consent at any time, subject to any legal or contractual restrictions and on the provision of reasonable notice to Cecconi Simone. If a Client or Employee chooses to withdraw his or her consent, he or she is required to do so in writing to the Chief Compliance Officer (please see section VII of this Privacy Policy). Any implications to withdrawing consent will be explained to the Client or Employee at the time written notice of such withdrawal is received by Cecconi Simone. Such implications may include, but are not limited to, a breakdown, interruption or cessation of Cecconi Simone’s relationship with the Client or Employee.

By retaining the services or becoming an employee of Cecconi Simone, Clients and Employees have consented to the disclosure of their Personal Information to a third party in the circumstances or for the purposes set out in this Privacy Policy. 


II Limitting Collection

Cecconi Simone limits the collection of a Client’s or an Employee’s Personal Information to that which is necessary for the purpose identified in this Privacy Policy, or for any additional purpose identified to the Client or Employee before collection of the Personal Information.


III Limitting Use, Disclosure and Retention 

Personal Information is not used or disclosed for purposes other than those for which it was originally collected, except with the consent of the Client or Employee, or as permitted by law. Personal Information is only retained as long as may be necessary for the fulfillment of these purposes, or to meet government requirements, whichever is longer, following which it is destroyed, erased, or rendered anonymous. 


IV Accuracy

Cecconi Simone strives to ensure that a Client’s or Employee’s Personal Information is as accurate, complete and up to date as necessary for the purposes for which it is used. Information is updated only when necessary to fulfill specified purposes. Employees are required to notify Cecconi Simone of a change of Personal Information as soon as possible for payroll and tax purposes. 


V Safeguards 

Cecconi Simone has security safeguards in place designed to protect against loss, theft, unauthorized access, disclosure, copying, use or modification of Personal Information under the care of Cecconi Simone. The nature of the safeguards depends on the sensitivity, format, location and storage of the Personal Information. These security measures include locked cabinets, computer passwords, software firewalls to stop hackers, encryption software, restricting access to Personal Information to only those employees or representatives who have a need to know and, if deemed necessary by Cecconi Simone in its sole discretion, confidentiality covenants from third parties to whom Personal Information has been disclosed. E-Mail is not a 100% secure medium, and Clients and Employees should be aware of this when contacting us to send Personal Information. 


VI Accountability and Openness  

Cecconi Simone is responsible for the Personal Information under its control and has appointed a Chief Compliance Officer to ensure that we comply with all applicable privacy legislation and the terms of this Privacy Policy. All employees involved in maintaining or collecting Personal Information are trained via this Privacy Policy. Personal Information provided to third party service providers with whom Cecconi Simone has a contractual agreement will have levels of protection comparable to the internal protection of Personal Information maintained at Cecconi Simone. The Chief Compliance Officer addresses and investigates questions or concerns regarding a Client’s or Employee’s Personal Information. The Chief Compliance Officer may be reached by mail at Cecconi Simone Inc., 1335 Dundas Street West, Toronto, Ontario, M6J 1Y3, Attention: Chief Compliance Officer, or by telephone at (416) 588-5900. A copy of this Privacy Policy and any future updates or amendments are available at www.cecconisimone.com and upon request from Cecconi Simone.


VII Individual Access

 Upon written request of a Client or Employee, Cecconi Simone will provide such Client or Employee with access to their Personal Information. Cecconi Simone will correct or amend any inaccuracies in the Client’s or Employee’s Personal Information, and such amended information will be forwarded to any third parties who require access to the information. Cecconi Simone has the right to refuse a request for access to Personal Information:
• If the information is protected by legal privilege
• If granting access would reveal confidential commercial or financial information
• If doing so would reasonably be expected to threaten the life or security of another individual
• If the information was collected for purposes related to the detection and prevention of fraud
• If the information was generated in the course of a formal dispute resolution process
• If the information would likely reveal Personal Information about another Client or Employee, as the case may be
• If the request is vexatious or frivolous
• To protect Cecconi Simone’s rights and property

If the request of a Client or Employee for such individual’s Personal Information is denied, the individual will be informed in writing of the reasons for the denial, as well as any recourse available to such Client or Employee. Access to a Client’s or Employee’s Personal Information will be at no cost to such Client or Employee. Minimal Charges may apply, however, for the transcription, reproduction or transmission of documents containing Personal Information.


VIII Challenging Compliance  

If a complaint (“Complaint”) regarding Cecconi Simone’s handling of Personal Information is received, an individual (the “Investigator”) with the skills necessary to conduct an investigation fairly and impartially will be assigned. The Investigator will have access to all relevant records and will be permitted to speak with Employees who handled the Personal Information access request. The complainant will receive notification of the outcome of the investigation clearly and promptly. Any inaccurate Personal Information or policy/procedure changes will be modified, if necessary, based on the outcome of the Complaint. 


IX Currency of this Privacy Policy  

Cecconi Simone reserves the right to change this Privacy Policy at any time and from time to time. Any changes or additions to section I of this Privacy Policy regarding those situations where Cecconi Simone will collect, use or disclose Personal Information will not apply to a Client or Employee without the prior consent of such Client or Employee. All Clients and Employees are encouraged to contact Cecconi Simone to determine if any updates have been made to this Privacy Policy.