Staffing Considerations – Virtual or Outsourced; Domestic or Abroad

Having staff attend the office on a full-time basis appears to be for days gone by. As a result, one should carefully consider how staff working outside of the office impacts day to day operations.

The discussion below should be considered carefully under the following circumstances:

• Employees working virtually in BC
• Employees working virtually outside of BC or Canada
• Consultants (outsourced workers) working virtually in BC
• Consultants (outsourced workers) working virtually outside of BC or Canada

These are some thoughts to consider when it comes to virtual staff as well as outsourcing workers, either domestic or abroad:

• Have you informed your insurer that you are thinking of outsourcing and seeing if that has ramifications on your insurance?
• What privacy protocols will you have in place?
• Are your workers overseas, and if so, are they accessing files on a server stored in Canada without the ability to download these to their computer?
• Are you planning on using cloud services where the data might not be stored in Canada? (PIPEDA and FOIPPA considerations)
  • This document on cloud computing and privacy provides some information on what to look out for. sight into data being housed outside of Canada.  This document (maintaining confidentiality and public confidence) discusses the legislative acts in a bit more detail.
• What security protocols will you have in place to safeguard client information (in electronic or paper form) to ensure its confidential nature?
• Will you be going overseas to interview the people who will be working on your files or are you using a third-party’s staff?
• How will you be training and supervising people on Canadian standards (accounting, assurance, quality management)?
• Depending on the work that is outsourced, is domestic staff able to develop competencies that have been outsourced?
• What will be included in your engagement letter (in collaboration with your lawyer) to inform and explain this to the client?
• We have had situations where practitioners lost clients as they did not want their work being done overseas. In addition, we had practitioners who have had clients want a lower bill as the work is done overseas.

Please see the CPABC Code of Professional Conduct preamble for the reference to you being responsible for staff under your supervision:

Responsibility for compliance with the CPA Code

• Registrants are responsible to CPABC for compliance with the CPA Code by others who are either under their supervision or share with them proprietary interest in a firm or other enterprise. In this regard, a registrant must not permit others to carry out acts which if carried out by the registrant would contravene the CPA Code.
• Registrants who reside outside British Columbia continue to be subject to the CPA Code or its equivalent in each province of registration. They may also be subject to the code of another organized accounting profession in the jurisdiction in which they reside. Should the code in two or more jurisdictions conflict, a registrant will, where possible, observe the higher or stronger of the conflicting codes and, where that is not possible, the ethical conflict guidance set out as part of this Preamble will apply.

Other Code of Professional Conduct Rules to consider would be:

• Rule 201 Maintenance of the good reputation of the profession
• Rule 202 Integrity and due care and objectivity
• Rule 203 Professional competence
• Rule 208 Confidentiality of information
  • This article discusses workplace privacy policies which would be relevant to consider for domestic as well as international people. Workplace Privacy Policies What Are They and Why Are They Essential
• Rule 406 Responsibility for a non-registrant
  • CPAs Responsible For Non-Members in Public Practice