General Policy

We publicly share our internal policies, guides, manuals, and procedures that do not contain client information. We call this practice a “radical openness clause”.

We do not disclose information received in arrangements with a confidentiality clause (unless the disclosure is required by law or professional standards).

We do not disclose without explicit consent any information received in arrangements without a confidentiality clause (unless the disclosure is required by law or professional standards).

We disclose the information required to be disclosed by law or professional standards.

Some rules regarding confidentiality:

• We use firm-approved technology solutions to store confidential data.
• We use laptop security screens and locks when leaving our desks.
• We do not share passwords and credentials.
• We collect only the minimum necessary information and return it as soon as it is not needed.
• We never leave confidential papers without oversight in a public space.

Release of records to the client

Definitions

Prepared by client (PBC): accounting or other records owned and prepared by the client entity that was received by us directly by the entity or on its behalf. Examples: original documents, electronic or hardcopy reproductions.

Non-attest client records prepared by the firm (PBF): bookkeeping records or financial reporting adjustments absent from the client's books and records, or otherwise unavailable to the client but necessary to have complete support for the client’s deliverables: journal entries, calculations support (without formulas unless essential for the client’s understanding of the resulting records), as well as SUAD, SAD, schedules of identified control deficiencies, and documents developed or suggested by us during engagements.

Client deliverable documents (CDD): specified in the engagement terms deliverables such as financial statements, financial models, audit reports, communications to those charged with governance, and tax returns.

Working papers (WPs): all documents created for the engagement that do not fall into other categories above: audit programs, analytical review, statistical sampling outcomes, and related analyses. This also includes client-prepared documentation if it is prepared solely as a response to the firm’s requests and is prepared by the client’s internal audit function or experts who were considered appropriate to rely upon for the purpose of attest engagements.