This statement describes David B. Robinson,
will be followed to respect the privacy of individuals who deal with David B. Robinson, CPA. Your privacy is important to us, and
maintaining your trust and confidence is one of our highest priorities. We
respect your right to keep your personal information confidential and
understand your desire to avoid unwanted marketing solicitations and invasions
of your privacy. Federal and State laws
requires us (along with other companies, including banks, brokerage houses, and
contained in the balance of this document.
We have prepared this policy to explain what types of information we
collect, how we use it, under what circumstances we may share it, and other
important information. This policy covers all the entities and activities
controlled by David B. Robinson, CPA (hereinafter referred to as “DBR”).
Under no circumstance do we provide personal information to non-DBR entities for the purpose of independent telemarketing or direct mail marketing of any product or service of these companies. In fact, we do not disclose any information except in the limited situations described in this document.
The type of information collected by David B. Robinson, CPA (DBR) regarding individuals and businesses generally includes the following: names, addresses (including email addresses), telephone and facsimile numbers, date of birth, occupation, details about an individual’s family (including spouse and children’s names, birthdays and genders) and financial details and concerns. Through our collection of this information, information about gender, education, medical history, social preferences and membership in professional, political and/or social associations/interests may come to be known by us and this is discussed in additional detail in the following paragraph. The information held by DBR may come from a number of sources including interviews and phone calls with you, publicly available sources, letters and/or e-mails to/from you, tax returns, organizers, tax return source documents, financial history questionnaires and receipts, books of record and, for example, cancelled checks, receipts and bank statements. We collect personal information about you, but only when that information is provided by you or is obtained by us with your authorization or through direct interaction with you. We use all information that we gather to prepare your income tax returns and may also use it to provide various tax, consulting and financial planning services to you at your request.
Some information DBR holds may be “Sensitive Information”
Because the data necessary to prepare tax returns and to provide various tax, consulting and financial planning services is obviously very personal and highly confidential, sensitive information will obviously come to our attention and knowledge. “Sensitive Information” is information or an opinion about an individual’s race or ethnic origin, gender, education, medical history, social and political opinions, membership in political associations, religious beliefs and affiliations, philosophical beliefs, memberships in professional or trade associations or trade unions, sexual preferences or practices and/or criminal records. DBR will only receive sensitive information with the individual’s consent through direct discussion or document examination. DBR will not overtly collect personal information unless the information is necessary for one or more of its functions or activities. DBR will collect the personal information only by lawful and fair means and not in an unreasonably intrusive way. Whenever DBR collects personal information about an individual, DBR will take reasonable steps to ensure that the individual is aware of the identity of DBR, the fact that he or she is able to gain access to the information and the purpose for which the information is collected. DBR cannot, however, be held responsible for inadvertently learning sensitive information through discussions that are initiated by you or documents presented to us by you but will, of course, treat such information in the same manner as all other information that we know about you.
The Purposes for which DBR uses this Information
The purposes for which DBR uses personal information collected includes the following: to open and administer client accounts, to provide financial services to clients, to administer and supervise employees and independent contractors of our firm, for marketing and sales initiatives such as DBR publications, brochures, newsletters and business and personal networking events, to promote events in the community with which DBR is associated, for billing and collection activities and related data processing and to consider potential employee’s applications for employment by the Firm.
We do not disclose personal information about our clients or former
clients to anyone. However, to the extent permitted by law and any applicable
state Codes of Professional Conduct, certain nonpublic information about you
may be disclosed in the following specific situations:
1. To comply with a validly issued and enforceable subpoena, warrant or summons.
2. In the course of a review of our firm's practices under the authorization of a state or national licensing board, or as necessary to properly respond to an inquiry or complaint from such a licensing board or organization.
3. As a part of any actual or threatened legal proceedings or alternative dispute resolution proceedings either initiated by or against us, provided we disclose only the information necessary to file, pursue, or defend against the lawsuit or action but to take reasonable precautions to ensure that the information disclosed does not become a matter of public record.
4. To provide information to affiliates of the firm and nonaffiliated third parties who perform services or functions for us in conjunction with our services to you, but only if we have a contractual agreement with the other party, which prohibits them from disclosing or using the information for other than the purposes, for which it was disclosed.
5. In conjunction with the normal due diligence process of any merger, provided that we take appropriate precautions (for example, through a written confidentiality agreement) so the prospective merger partner does not disclose information obtained in the course of the process.
6. To report information related to victims of abuse, neglect or domestic violence
7. To assist law enforcement or public health officials avert a serious threat to the health or safety of you or any other person.
8. Information may be disclosed to lawfully established executors or administrators to enable them to carry out their lawful duties.
As a general rule, DBR will not use or disclose personal information about an individual other than for its primary purpose of collection, unless the individual has consented to the use or disclosure. DBR will use the information it gathers for our own direct marketing purposes only where it is impractical for DBR to seek the individual’s consent before that particular use. DBR will not charge an individual for giving consideration to a request not to receive direct marketing communications if the individual makes a request not to receive direct marketing communications.
DBR will take reasonable steps to make sure that the personal information it collects, uses or discloses is accurate, complete and up-to-date. DBR will take reasonable steps to protect the personal information it holds from misuse and loss and from unauthorized access, modification or disclosure. DBR will take reasonable steps to destroy or permanently de-identify personal information if it is no longer needed.
Openness, Access and Correction
DBR employees and professional independent contractors are permitted to access the information they need to perform their jobs. We maintain strict internal policies against unauthorized disclosure or use of client information. Information held by any DBR related entity is available to other members of the DBR family of entities for authorized purposes. DBR has set out in this document its policies on management of personal information and will make this document available to anyone who asks for it. On request by a person or entity, DBR will take reasonable steps to let the requestor know, generally, what sort of personal information we hold, for what purposes, and how we collect, hold, use and disclose that information. As a general rule, DBR will, on request by an individual or business, provide them with access to their personal or business information, however DBR may choose not to provide individuals or businesses with access to such information. This would include cases where providing access would have an unreasonable impact on the privacy of other individuals or businesses, the request for access is frivolous or vexatious, the information relates to anticipated or existing legal proceedings and would not be discoverable in those proceedings, providing access would reveal the intentions of DBR in relation to negotiations with the individual in such a way as to prejudice those negotiations, providing access would be unlawful, providing access would be likely to prejudice an investigation of possible unlawful activity or providing access would be likely to prejudice activities which are carried out by DBR on behalf of an enforcement body. DBR will impose a charge to cover the cost of verifying and complying with all requests for information, including compliance with a validly issued and enforceable subpoena or summons and for locating, retrieving, reviewing, couriering and copying any material requested. The charge will be levied on the client whose records we are asked to produce but we will reasonably cooperate in assisting the client in recovering such costs from the requesting party if that party is not the client but, ultimately the responsibility for information production will always remain with our client and such charges are always expected to be paid promptly.
DBR will not adopt a government agency identifier (such as a tax file number or driver’s license number) as its identifier of an individual. Wherever it is lawful and practical, DBR will allow individuals the option of not identifying themselves when entering into transactions or discussions with us.
DBR will only transfer personal information about an
individual to a third party who is in a foreign country in specified
circumstances. This would include where the individual consents to the transfer
or where DBR has taken reasonable steps to ensure that the information
that it has transferred will not be held, used or disclosed by the recipient of
Confidentiality and Security of Non-Public Information
Except as otherwise described in this notice, we restrict access to nonpublic personal information about you to employees and professional independent contractors of our firm and other parties who must use that information to provide our services to you. Their right to further disclose and use the information is limited by the policies of our firm, applicable law, our Code of Professional Conduct, and nondisclosure agreements where appropriate. We also maintain physical, electronic, and procedural safeguards in compliance with applicable laws and regulations to guard your personal information from unauthorized access, alteration, or premature destruction.
How can an Individual Complain about Possible Breaches of Privacy by DBR?
A complaint by an individual regarding an alleged breach of
privacy by DBR should be forwarded in writing by
certified mail to the following address:
Privacy Complaints Officer, David B. Robinson, CPA, Post