Which of the following statements regarding a paralegal’s obligations

Which of the following statements regarding a paralegal’s obligations to their clients with regard to the Personal Information Protection and Electronic Documents Act (PIPEDA) is FALSE?
(a) The personal information that paralegals collect about clients must be protected under PIPEDA using a privacy policy and procedures
(b) Because the personal information about clients collected by paralegals is protected by their ethical duty of confidentiality, paralegals are exempt from the requirements to implement a privacy policy and procedures
(c) PIPEDA regulates the collection, use, and disclosure of personal information by organizations in Ontario, including paralegal firms, in the course of their commercial activity in the private sector
(d) PIPEDA does not apply to the personal information of the employees who work for paralegal firms
Authority: Text pp. 144-45