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Canada edition

Where your financial data goes, stated plainly.

Real controls, honest status: what is in place today and what is still in progress.

Short answer

Finbryn treats Canadian client financial data as sensitive by default. PIPEDA does not block moving your data to a foreign processor for the work itself, but it makes the Canadian side of the arrangement accountable for the protection your data gets there, and we back that with a written contract, least-privilege access and multi-factor authentication. Below is every control, with its real status, not a marketing claim.

How access and data are handled

  • Least-privilege access

    Team members reach only the client systems and files their role requires, not a shared blanket login.

  • Device policy

    Work on client files happens under a written device policy, not on personal, unmanaged machines.

  • Comparable protection by contract

    PIPEDA requires the organization sending data outside Canada to remain accountable for it. Our agreement with clients sets out comparable protection obligations in line with that accountability principle.

  • Disclosed processing location

    We say in writing, before you sign, that the accounting work is performed by our accounting team in Pakistan under contract with Northlane Solutions Inc.. Personal data transfers are covered by the safeguards in the privacy policy.

Security

Controls and their current status

  • In place6
  • In progress7
  • Planned3
  1. Multi-factor authentication on client systems

    Every team member connecting to a client's accounting software, bank feed, or shared storage does so behind multi-factor authentication. Single-factor password access to client systems is not permitted under our internal access policy, regardless of role or tenure.

    Evidence: policy document

    In place
  2. Least-privilege access control

    Team members are granted access only to the specific client files and systems their engagement requires, not blanket access across the client base. Access is reviewed when an engagement ends or a role changes, and removed promptly rather than left open.

    Evidence: policy document

    In place
  3. No local storage of client files

    Client accounting data is worked on inside the client's own software (QuickBooks Online, Xero, or similar) or an approved shared workspace, not downloaded and saved to an individual team member's laptop or personal device. This limits how many places a client's financial data can end up.

    Evidence: policy document

    In place
  4. Signed non-disclosure agreement for every staff member

    Every team member with any access to client financial information signs a non-disclosure agreement before their first day on an engagement, covering client data specifically, not just general company confidentiality. This is a condition of employment, not an optional add-on for larger accounts.

    Evidence: policy document

    In place
  5. Full-disk encryption on team devices

    Laptops used to access client accounting systems run full-disk encryption, so a lost or stolen device does not expose readable client data. This is a baseline device requirement before any team member is granted client system access, not a later hardening step.

    Evidence: policy document

    In place
  6. Documented onboarding and offboarding for client access

    Every engagement follows a written checklist for granting access when a team member joins a client's books and revoking it when they leave the engagement or the company. This removes the common failure mode where a departed team member's access to a client's accounting software is simply forgotten.

    Evidence: policy document

    In place
  7. Written information security program (WISP)

    A written information security program aligned to IRS Publication 4557, covering administrative, technical, and physical safeguards for taxpayer and client financial data, is being drafted ahead of handling any US tax preparation data. A summary will be published once it is adopted, and no US tax data will be processed before it is in place.

    In progress
  8. Data processing agreement templates with SCCs and IDTA

    Standard Contractual Clauses for EU client data and a UK International Data Transfer Agreement, each paired with a transfer risk assessment, are being finalized with counsel to cover the cross-border transfer of client financial data from the UK and EU. These will be signed as part of onboarding for clients in those regions.

    In progress
  9. Section 7216 consent workflow for US tax data

    A written-consent workflow meeting the format required by Revenue Procedure 2013-14 is being built so that every US client explicitly consents, before any tax return information is disclosed, to that information being used and processed by our team. No US taxpayer data will be shared ahead of a signed consent.

    In progress
  10. Errors and omissions insurance

    A professional errors and omissions policy covering the firm's advisory and preparation-support work is in the process of being placed. We will not claim coverage is in force, or name a policy, until it is confirmed bound and the certificate is on file.

    In progress
  11. Cyber liability insurance

    A cyber liability policy covering data breach response for client financial data is in the process of being placed alongside our errors and omissions coverage. As with that policy, we will not claim coverage exists until it is confirmed bound.

    In progress
  12. Third-party software vendor review

    A documented review of the security posture of every software vendor in our stack, QuickBooks Online, Xero, and connected apps, is being formalized into a standing checklist run before any new tool is adopted for client work, rather than left to individual judgment.

    In progress
  13. Written incident response plan

    A documented, tested procedure for detecting, containing, and notifying clients of a security incident involving their data is being drafted alongside the written information security program. It will define notification timelines and responsibilities before it is relied on rather than after an incident occurs.

    In progress
  14. SOC 2 Type I examination

    We intend to engage an independent auditor for a SOC 2 Type I examination once the underlying controls above (WISP, incident response, vendor review, access management) are fully in place and operating, since a Type I report only has value once there is something real for the auditor to examine. No SOC 2 report exists today, and we will not use that language about ourselves until one is issued.

    Planned
  15. ISO 27001 certification

    ISO 27001 certification is a longer-term goal, particularly for UK and Australian clients where it carries more procurement weight, and would follow after SOC 2 readiness work is complete. No certification exists today and none is implied by any control listed above until it is actually issued.

    Planned
  16. Independent penetration test

    An independent, third-party penetration test of client-facing systems and internal tooling is planned as part of SOC 2 readiness work, to validate the access and encryption controls above rather than take them on faith. No test has been performed as of today, and none is claimed.

    Planned

Questions

Questions Canadian clients ask about data

Does PIPEDA stop you from processing my data outside Canada?

No. PIPEDA does not prohibit transferring personal information to a foreign processor for processing, but it keeps the Canadian side of the relationship accountable for making sure the data gets comparable protection.

Where does my data physically go?

Into your own QuickBooks Online, Xero or Sage 50 file, accessed under least-privilege permissions and a written device policy by the team named above.

Do you tell clients their data leaves Canada?

Yes, in writing, before you sign. This page and our engagement letter both state where the work is performed and which entity we contract under.

Does Finbryn hold a SOC 2 report?

No, not yet. A SOC 2 examination is planned, and we will not claim that status on this page until a real report exists.

Who has access to our financial data day to day?

Only the named pod assigned to your file and the reviewing senior principal, using role-based access inside your own accounting platform rather than a shared export. Access is removed if someone leaves the engagement or the account is closed.

What happens to our data if we stop working with Finbryn?

Your books stay in your own QuickBooks Online, Xero or Sage 50 account, so nothing needs to be exported or handed back. Any working papers we produced are shared with you before the engagement ends; we do not retain a separate copy for our own use.

Next step

Ask us anything about how this works

If a control on this page needs more detail for your own compliance review, book a call and we will walk through it.