Protecting our clients’ privacy is important to us. These privacy principles are adhered to by us to ensure that the information submitted to us will be treated with the utmost confidentiality and in adherence with the Personal Information Protection and Electronic Documents Act of Canada (PIPEDA). Our privacy policies are evidenced in the following ten privacy principles.
1. Accountability
We are responsible for all personal information that we collect or that is under our control. Our employees, agents and suppliers are also required to keep our clients’ information safe and confidential. We have appointed a Privacy Officer who is accountable for our compliance with these privacy principles. The contact details of the Privacy Officer can be found at the end of this document.
2. Identifying Purposes
We will identify the purposes for which we collect, use or disclose personal information. We are required to collect certain pieces of information by the regulatory bodies that oversee us. Personal information could include name, address, date of birth, identification, Social Insurance Number, citizenship, country of residence, banking information, occupation, marital status, dependents, income, net worth, and health status.
3. Consent
We will only collect, use or disclose client information with the knowledge and consent of its clients except where inappropriate or as otherwise required or permitted by law. By completing account forms or applications, clients consent to the collection and use of personal information for the purposes of receiving the applicable service or product. Clients also consent to the disclosure of their personal information to our employees, agents, contractors and third-party service providers.
4. Limiting Collection
Only such information as is necessary for our services will be collected from our clients. When personal information is needed, it will be obtained directly from our clients. If necessary, only reputable and reliable sources will be used to supplement this information.
5. Limiting Use, Disclosure And Retention
Personal information will not be used or disclosed for purposes other than those for which it was collected, except with the consent of the individual or as required by law. Personal information will be retained only as long as necessary for fulfillment of those purposes and to comply with record retention policies of our regulators such as the provincial securities commissions, FINTRAC and the provincial insurance councils. We may also retain client information for a reasonable amount of time to protect us in case of legal action where we would need our records intact to investigate any claims.
6. Accuracy
We will keep client personal information as accurate, complete and up-to-date as necessary for the purposes for which it is to be used. We may need to contact a client periodically to verify that the information we have on file is current. To assist in this process, clients are asked to contact us if their personal information changes or to ensure that the information we have on file is correct.
7. Safeguards
We will protect personal information with security safeguards appropriate to the sensitivity of our clients’ personal information. We maintain records and retain personal information in electronic or paper format and protect this information using industry standard security safeguards.
8. Openness
We will make available to clients specific information concerning the policies and procedures relating to the management of their personal information.
9. Individual Access
Upon request, clients will be informed of the existence, use and disclosure of their personal information and shall be given access to that information. Clients may verify the accuracy and completeness of the information and may request that it be amended, if appropriate.
10. Handling Client Inquiries, Complaints And Suggestions
If you have a question, concern or complaint about our privacy policy and principles, please send your comments and your contact details to our Privacy Officer in writing to the following address:
Attn: Privacy Officer: 14 Nature Court, Hamilton, Ontario L9C 7T5