Our Privacy Principles
Our Privacy Principles are modeled around Canada's Personal Information Protection and Electronic Documents Act. These govern the way that we collect, use and protect your personal information. Our ten principles are:
Principle 1 - Accountability: We are responsible for maintaining and protecting the information that we have about you. We have a designated Privacy Officer to help ensure that we are in compliance with our Privacy Code at all times.
Principle 2 - Identifying Purposes: We will explain the purpose(s) for which we are collecting your information either before or at the time that we collect the information from you.
Principle 3 - Consent: We require your knowledge and consent before we collect, use or disclose your personal information, except where we are required to do so by law.
Principle 4 - Limiting Collection: We will limit the collection of your personal information to that which is necessary for the purposes that we have identified. We will collect your information by fair and lawful means.
Principle 5 - Limiting Use, Disclosure and Retention: We will limit the use, disclosure and retention of your personal information to the purposes that we identified when we collected the information, unless you have given us your consent to do so, or where we are permitted or required to do so by law.
Principle 6 - Accuracy: We will keep your personal information as accurate, complete and current as is necessary to fulfill the purposes for which it is to be used.
Principle 7 - Safeguards: We will protect your information with security safeguards that are appropriate to the sensitivity of the information.
Principle 8 - Openness: We will make the policies and procedures that we use to manage your personal information available to you.
Principle 9 - Access: Upon request, we will inform you of the existence, use and disclosure of your own personal information and give you access to it. We will also help you to verify the accuracy and completeness of your information and amend it for you when necessary.
Principle 10 - Handling Customer Complaints and Suggestions: You may direct your questions or inquiries about the privacy of your personal information to our Privacy Officer. Reach us via e-mail at email@example.com or call our Fund Services Team at 416-203-7331.
How do we collect your information?
The information that we collect about you is retained in your electronic account in a protected environment. You or your Investment Advisor provided most of this information when you completed your account application form.
What information is collected?
The personal information that is contained in your electronic account may include your name, address, telephone number, e-mail address, social insurance number, date of birth, account holdings and history, as well as the name, address, date of birth and social insurance number of your beneficiary or spouse (when applicable). Depending on which services you have requested from us, we may also have information that may include your banking information.
How do we use your information?
Some of the purposes that we will identify in using or disclosing your information may include:
- Identifying you;
- Ensuring the accuracy of the information contained in your account;
- Opening and administering your account;
- Calculating, recording, storing and maintaining your account holdings and transaction history in your account;
- Processing transactions into, within, or out of your account as requested by you or your investment advisor or dealer;
- Producing statements of account or trade confirmation slips or providing this information to your dealer or investment advisor;
- Producing financial statements or tax slips to Canada Customs and Revenue Agency;
- Producing proxy mailings and assembling and using voting share databases;
- Producing mailing lists to facilitate the mailing of financial statements or other notices that we may provide to you from time to time that relate to your holdings;
- Protecting the business interests of and our agents;
- Meeting legal and regulatory requirements; and
- Verifying information that you had previously given to another organization when necessary to act on the identified purposes.
Who else do we collect information from?
There are instances where we may collect information about you from a third party in order to fulfill the identified purposes. These parties might include:
- Your investment advisor or dealer or intermediary;
- Other financial institutions or mutual fund companies;
- Other affiliated companies; and
- Third parties who represent that they have a legal right to disclose the information, such as an executor of an estate.
Who do we disclose your information to?
Sometimes we may disclose your information to our agents, our suppliers or other organizations. This information is only used for the identified purposes. These parties may include:
- Your investment advisor, dealer or intermediary;
- Other financial institutions or mutual fund companies;
- Other affiliated companies;
- Canadian governments and government agencies;
- Canada Post or other delivery services;
- Account statement preparation and mailing companies, courier companies, imaging companies and document storage companies.
Disclosing your information to these parties is necessary to provide you with the services that you require. When these disclosures are made, we ensure by contractual means that the use of your information is limited to the purposes for which the agent is required.
Disclosing your information when permitted or required by law
We must provide information where required by a valid demand, search warrant or other legally valid inquiry. We may disclose information to an investigative body in the case of a breach of an agreement or contravention of laws. We may also disclose information to help us collect a debt owed by you.
How do we obtain consent?
You expressly give us your consent to use your information for the purpose provided when you sign an application form or purchase units or shares of investments managed by us. You also expressly give us your consent to use your information for the purposes involved in operating and maintaining your account by continuing to do business with us.
How can you withdraw all or part of your consent?
If you would like to withdraw your consent to use your personal information you must contact our Fund Services Team. Your request will be conveyed to our Privacy Officer immediately. Your decision to withdraw your consent or withhold information may limit the products and services that we can offer you.
Your right to access your information
Except in limited circumstances, we will provide you with the information that we have about you so that you may verify or amend it. We will provide this within 20 days of receiving your request, unless we are prohibited to do so by law. Some situations that might prevent us from providing you with all or part of your information might include:
- Information that contains references to other persons and the references are subject to legal privilege;
- Where information that is confidential to us might be revealed;
- If the information relates to an investigation of a breach of agreement or contravention of laws; or
- If the information cannot be disclosed for other legal reasons.
Keeping your information accurate
The information that we have about you must remain accurate so that we can continue to provide you with efficient service. Please inform us of any errors in our information about you as soon as you are aware of them. We ask that you update us with your current information whenever necessary by contacting our Fund Services Team at 416-203-7331.
Where do we keep your information?
Our agents and ourselves keep your client records in electronic and paper format. Paper records forming part of your client record may also be kept in offsite storage facilities. Your client record may be transferred to other locations for disaster recovery purposes.
How do we protect your information against loss and unauthorized access?
Our employees and service providers have access to your information provided the information is required for the identified purposes and access is permitted only to the extent necessary for such purposes. In addition, we have taken additional measures to ensure that your information is protected, such as restricting physical access to critical business processing areas in our offices and using computer passwords and file encryption for online activities.
How long do we keep your information?
We retain your information only as long as it is required for the reasons it was collected. The length of time may vary depending on the product or service and the nature of the information. This period may extend beyond the end of your relationship with us but only for so long as it is legally necessary for us to have sufficient information to respond to any issues that may arise at a later date.
Resolving your concerns
If you have any questions or concerns about our treatment of your information please follow these steps:
Step 1. In most cases, a concern is resolved simply by discussing it with a member of our Fund Services Team, who can be contacted by telephone at 416-203-7331 or via e-mail at firstname.lastname@example.org or via fax at 416-203-6630.
Step 2. If your concerns have not been resolved to your satisfaction, please contact our Privacy Officer directly, who can be reached by telephone at 416-203-7331 ext. 228 or via e-mail at email@example.com or via fax at 416-203-6630.
Step 3. In the event that you have not obtained a satisfactory resolution through steps 1 and 2, you may escalate your issue to the Privacy Commissioner of Canada at 1-800-282-1376 or by writing to: The Privacy Commissioner of Canada, 112 Kent St, Ottawa, ON, K1A 1H3.
Who can answer your questions about privacy?
Please contact our Fund Services Team at: 416-203-7331 or via e-mail at firstname.lastname@example.org via fax at 416-203-6630.