PROTECTING PERSONAL INFORMATION OF INVESTORS
This Policy applies to all personal clients of Credential (as defined below). It pertains to the protection of personal identifiable information.
- procedures to protect personal information;
- procedures to receive and respond to complaints and inquiries;
DEFINITIONS USED IN THIS POLICY
"Credential" and/or "Credential Companies" means:
- Credential Asset Management Inc.
- Credential Securities Inc. (and Credential Direct and Credential Correspondent Partners)
- Credential Insurance Services Inc.
- Credential Financial Strategies Inc.
"Sponsoring Organization" means the credit union or other financial services firm that you have a relationship with and that referred you to us.
TEN PRIVACY PRINCIPLES
At the heart of our philosophy and commitment to investors are our ten privacy principles concerning the collection, use and disclosure of personal information.
Accountability — We are responsible for protecting personal information that is in our control or is transferred to third parties with our clients' consent. Our Chief Privacy Officer is accountable for ensuring our compliance with the principles described in this Policy.
Identifying Purposes — The purpose(s) for which personal information is being collected will be identified, explained, and documented at the time of collection.
Consent — We will obtain consent prior to collecting, using and disclosing personal information. Informed consent (express or implied) is required for the collection, use or disclosure of personal information (except where permitted or mandated by law).
Limited Collection — We will only collect personal information that is needed for the specific purposes we have explained to our clients.
Limiting Use, Disclosure and Retention — We will use and disclose personal information only for the purposes we have identified to our clients, or when it is mandated or permitted by law. We retain personal information only for as long as it is necessary.
Accuracy — We keep personal information accurate, complete and up to date as is reasonably possible.
Safeguards — We safeguard personal information with appropriate protective and security measures.
Openness — Within a reasonable time after receipt of a written request, we will provide specific information on our personal information management policies and procedures. We will provide information that is easily understandable.
Access — Our clients have the right to review any and all personal information we have about them, except where Credential is required or permitted by federal or provincial law to deny access for a specific reason. We encourage our clients to verify the accuracy of the information we have and inform us of any corrections that need to be made.
Challenging Our Compliance — If a client has any concerns they may request that our Chief Privacy Officer investigate the matter and respond within a reasonable time.
WHY WE COLLECT PERSONAL INFORMATION
We collect personal information to establish and operate your account(s) with us. We obtain most of the information directly from you with your consent. The decision to provide us with your personal information always rests with you. We may, however, be limited in our ability to provide you with certain products and services, if you decline to provide us with information essential to fulfill your request
HOW WE USE PERSONAL INFORMATION
The type of information that we collect will depend on the type of product or service that you have requested. Here is the type of information that we generally collect and a description of how we use such information:
Name, Mailing Address, E-mail Address, Telephone Number
This information helps us identify you and allows us send you statements and other important notices. It also allows us to communicate with you to obtain instructions and respond to your requests and enquires.
Date of Birth
This helps us to fulfill our legal obligation to ascertain your identity and also helps protect you and us from error, identity theft and fraud. We may also use this information to determine your likely interest in other products and services that we offer.
Social Insurance Number
Under the Income Tax Act (Canada) we are required to obtain your social insurance number (SIN) if there are tax implications to your financial transactions. With your consent, we may also use your SIN for credit reporting purposes.
We collect this information to better understand your unique financial situation and investment needs and to help us provide appropriate investment advice.
This information is required for certain types of insurance products. Any personal health information collected in connection with an insurance product is never shared.
We may access your personal information for our and your Sponsoring Organization's internal audit purposes, to assist in protecting you from illegal or fraudulent activity.
Understanding Client Needs and Business Requirements
We may use your personal information to help us understand your habits and preferences and to help us understand your current and future needs. We may also use this information to help us forecast our future business requirements.
Settling Claims We will only collect personal information in a fair and lawful manner. The personal information collected is used exclusively for the purposes described above and for no other purpose. We do not rent or sell personal information to any third parties.
We may disclose your information to our insurance provider in the event a claim for monetary damages is made.
SHARING PERSONAL INFORMATION
With your Sponsoring Organization
We work in partnership with your Sponsoring Organization to provide you with an array of wealth management, insurance and other products and services. Allowing us to share your personal information with your Sponsoring Organization helps us fulfill our commitment to provide you with the best possible service and ensures you benefit from the full range of available products and services. With your consent, your Sponsoring Organization may use your personal information to:
- refer you to other products and services that it offers;
- refer you to the products and services offered by the other Credential Companies; and
- better manage its total relationship with you.
With Third Parties
If you request a product or service that requires that we extend credit to you we may, with your consent, obtain information about you through a credit check. We may also, with your consent, obtain information from references that you have provided to us. If you decline to provide us with consent, we may not be able to extend credit to you.
With our Employees
In the course of performing their duties, authorized employees may have access to personal, confidential information. Employees may only access information strictly necessary to perform their duties. All employees that are likely to have access to personal, client information must sign, on an annual basis, a Code of Business Conduct under which they commit to maintaining the confidentiality of such information. An employee who breaches their confidentiality obligations may be subject to disciplinary measures, including dismissal.
With the Credential Companies
We operate under a central processing system for certain transactions within the Credential Companies. Accordingly, we may share information within the Credential Companies from time to time. Only authorized employees of Credential Companies will have access to personal, confidential information and such access will be limited to the information strictly necessary to carry out their duties. All employees of the Credential Companies with such access must sign our Code of Business Conduct & Ethics. Any employee of a Credential Company who breaches his/her confidentiality obligations may be subject to disciplinary measures, including dismissal.
With Service Providers
We disclose information to certain third party service providers retained by us to perform certain specialized services, such as mailing statements, providing secured data storage or transacting trades on behalf of clients. In these cases, we only disclose the specific information required to perform the services. Each of our suppliers must undertake to use client information solely for the purposes of carrying out the services it has been retained to provide and must agree to safeguard information.
As Required by Law
In certain instances, we may be compelled to disclose information in response to a legally valid demand, enquiry, proceeding or other order. In these cases, we take steps to ensure the request is valid and we only disclose the specific information necessary to satisfy the enquiry or order.
We may be ordered by a court in Canada to disclose personal information to a third party or to the court, or to preserve personal information pending the outcome of a legal hearing. In such circumstances, CFI will verify the legitimacy of the court order and will take reasonable steps to limit the amount of personal information that is disclosed to that which is necessary to satisfy the court order.
With Securities Authorities
We are required to also share your information with self-regulatory authorities (such as the Investment Industry Regulatory Organization of Canada, the Mutual Fund Dealers Association, Bourse de Montreal Inc., and the Canadian Investor Protection Fund). These organizations require access to personal information of current and former clients, employees, agents, directors, officers, partners and others for regulatory purposes including surveillance of trading-related activity, sales, financial compliance, trade-desk review and other regulatory audits, investigation of potential regulatory and statutory violations, regulatory databases, enforcement or disciplinary proceedings, reporting to securities regulators, and information-sharing with securities regulatory authorities, regulated marketplaces, other self-regulatory organizations and law enforcement agencies in any jurisdiction in connection with any of the foregoing.
Transfers of a Business
We will not disclose personal information for purposes other than those for which it was collected, except with the consent of the individual or as required or permitted by law.
SAFEGUARDING PERSONAL INFORMATION
We use a variety of security measures to protect your personal and investment information including:
- locked fireproof cabinets;
- electronic security such as data encryption, password protection, on-line data protection;
- restricting employee access to files and data centers; and
RIGHT TO ACCESS PERSONAL INFORMATION
If you would like to know what personal information we have concerning you, you can make a written request at any time. You must make a written request that provides us with sufficient detail to enable us, with reasonable effort, to identify you and your personal information.
We will inform you within thirty days in detail what personal information we have, how we collected it, how we use it, and to whom it has been disclosed. However, please understand that in some instances it is inappropriate to provide you with information that constitutes commercial proprietary data, is protected by solicitor-client privilege, would compromise the confidentiality of another individual's personal information (including a spouse, former spouse or family member), or is restricted or permitted to be withheld by law. We make a reasonable effort to provide you with the information you have requested within a reasonable time. We will provide a detailed explanation if we are unable to meet your request. If you are not satisfied you may contact the Office of the Information and Privacy Commissioner (see below for contact information).
KEEPING PERSONAL INFORMATION ACCURATE
If there is a change in your personal information or you become aware of an error in the personal information we have on file for you, please contact Partner & Client Care at 1-855-714-3900. You must make a written request that provides us with sufficient detail to enable us, with reasonable effort, to identify you and the personal information and the correction being sought.
We will correct inaccurate or incomplete information within a reasonable time and notify you when such changes are completed. There is no charge for correcting your information. We will also insure that any third parties that have received your personal information from us are notified of such changes or corrections. If there is any information that is still in dispute, we will make a note on your file. We rely on you to inform us and your dealer of any changes or corrections that we may not be able to reasonably ascertain without your input.
RETENTION OF PERSONAL INFORMATION
Your personal information is kept on file for as long as we need it to provide you with the products or services you have requested and to meet legal or regulatory requirements. The length of time your personal information is retained may vary according to the product or service and the sensitivity and nature of the information. This period may extend beyond the termination of our relationship for as long as it is reasonably necessary for legal or business purposes. After your information is no longer needed for the specific purposes identified to you, we will destroy, delete, erase or convert your personal information to an anonymous form.
HOW TO WITHDRAW CONSENT
You may contact us to withdraw your consent at any time provided there are no contractual or other legal requirements limiting such withdrawal. Our Client Relations Officers will explain your options and any consequences of withdrawing your consent.
If you do not consent to certain uses of your personal information, or if your consent is properly and legally withdrawn, we may not be able to provide you with certain products or services. We will thoroughly explain the consequences to help with your decision.
We do not, without your knowledge, collect any personal information about you while you are visiting our site. We do, however, collect anonymous information such as IP addresses (the Internet address of a browser's computer), browser types, the pages viewed, the time and date of your visit, which site you came from, plus any Internet ads you may have clicked on to reach our site. This statistical information helps us to understand how our website is used (e.g., which pages or sections are most popular and when are peak activity times) as well as how visitors find our site. This information also assists us in planning for future improvements to the site to better meet visitor needs. This information cannot in any way be used to personally identify a visitor.
In certain areas of our website, you may be asked to provide information that allows us to enhance your site visit or to answer any inquiries you may have about our products and services. Your participation is optional.
For instance, we will ask you for information when you:
- Take part in an online survey
- Subscribe to our newsletter or mailing list
- Participate in an online promotion or contest
- E-mail us an inquiry
When you e-mail us an inquiry, your e-mail address may reveal confidential information such as your name and organization. Any information you provide will be kept confidential and will only be used to respond to your comments or questions. Please note that e-mail inquiries are not encrypted and others could view the contents of your message as it is sent over the Internet. For this reason, do not include confidential information such as account numbers in e-mail messages.
We are certified by VeriSign, a leader in the field of e-commerce security verification. VeriSign provides digital security certificates to all of the Fortune 500 companies that have a presence on the Web.
You may notice that our site contains a number of links to external websites. We are not responsible for the content or privacy policies of these other websites.
Be careful when you send information over the Internet. Any unprotected e-mail communication over the Internet is, as with communication via any other media (e.g., cellular phones, post office mail), not confidential, subject to possible interception or loss, and is also subject to possible alteration.
PROCEDURE FOR HANDLING PRIVACY COMPLAINTS
If you feel that the confidentiality of your personal information has been compromised, we encourage you to contact us to resolve the matter. Our complaint process is fair, impartial and confidential.
In most cases, your concern can be resolved by discussing it with your representative or one of our Client Relations Officers. To contact a Client Relations Officer:
Credential Financial Inc.
#700-1111 West Georgia Street
Vancouver, British Columbia, V6E 4T6
When a privacy complaint is received the date the privacy complaint was received will be recorded and an acknowledgement of receipt of such complaint (if made in writing) shall be sent to you within thirty (30) days.
If your concerns have not been resolved by your representative to your satisfaction, please contact our Chief Privacy Officer:
Chief Privacy Officer
Credential Financial Inc.
#700-1111 West Georgia Street
Vancouver, British Columbia, V6E 4T6
Our Chief Privacy Officer will investigate all records, conduct interviews with staff, and respond to you within thirty (30) days.
If after contacting our Chief Privacy Officer your concerns remain unresolved, you may contact the Information and Privacy Commissioner for British Columbia at:
Office of the Information and Privacy Commissioner for British Columbia
PO Box 9038, Stn. Prov. Govt.
Victoria, B.C. V8W 9A4
4th Floor, 947 Fort Street
Victoria, BC V8V 3K3
Telephone: (250) 387-5629
For toll-free access call Enquiry BC at one of the numbers listed below and request a transfer to (250) 387-5629:
Vancouver: (604) 660-2421
Elsewhere in BC: 1-800-663-7867
Fax: (250) 387-1696
Web site: www.oipc.bc.ca
(NOTE: The OIPC does not accept requests for review or complaints by e-mail.)
If your transaction was completed in Alberta, please contact the Alberta Information and Privacy Commissioner:
For FOIP and HIA Issues contact:
Office of the Information and Privacy Commissioner
#410, 9925 - 109 Street
Edmonton, Alberta, T5K 2J8
Office Phone: (780) 422-6860
Toll Free: 1-888-878-4044
Fax: (780) 422-5682
Web site: www.oipc.ab.ca
For PIPA Issues contact:
Office of the Information and Privacy Commissioner
Suite 2460, 801 6 Avenue SW
Calgary, Alberta, T2P 3W2
Office Phone: (403) 297-2728
Toll Free: 1-888-878-4044
Fax: (403) 297-2711
Web site: www.oipc.ab.ca
For toll-free access to the above offices or any provincial government office, dial 310-4455 from anywhere in Alberta. Outside Alberta, call long distance (780) 427-2711. Operators are available from 8 a.m. to 6 p.m., Mountain Standard Time, Monday to Friday.
For province-wide toll-free access from a cellular phone, enter *310 (for Rogers-AT&T) or #310 (for Telus).
Deaf/hearing impaired callers with a TDD can reach Alberta Government offices by dialing 427-9999 in Edmonton or 1-800-232-7215 in other Alberta locations.
If your transaction was completed in other provinces or territories in Canada or trans-nationally, please contact the Privacy Commissioner of Canada:
Office of the Privacy Commissioner of Canada
112 Kent Street
Place de Ville, Tower B 3rd Floor
Ottawa, Ontario, K1A 1H3
Office Phone: (613) 995-2042
Toll Free: 1-800-282-1376
Fax: (613) 947-6850
Web site: www.priv.gc.ca
Credential Asset Management Inc.
Credential Asset Management Inc. is a mutual fund dealer and the principal distributor of funds offered by Northwest & Ethical Investments L.P.. As well, Credential Asset Management Inc. Mutual Funds Investment Specialists offer approximately 2,500 third-party funds through credit union branches across Canada.
Credential Securities Inc.
Credential Securities Inc. is a full-service investment dealer, offering investors stocks, bonds, mutual funds, and other investment products through licensed Investment Advisors. Credential Securities is a member of the Investment Industry Regulator Organization of Canada, and a member of the Canadian Investor Protection Fund.
Credential Direct is a division of Credential Securities Inc. Credential Direct provides investors with direct access to self-managed investing services via the Internet, or by speaking with a representative. Investors can access the services through www.credentialdirect.com or, for credit union members, through their credit union's dedicated Internet portal.
Credential Correspondent Partners
Credential Correspondent Partners is a division of Credential Securities Inc. Credential Correspondent Partners provides custody, trading, clearing, processing and reporting services for portfolio managers and independent wealth management firms.
Credential Insurance Services Inc.
Credential Insurance Services Inc. is a managing general agency, providing both a back-office facility and access to life insurance and living benefits products.
Credential Financial Strategies Inc.
Credential Financial Strategies Inc. is a full service insurance brokerage, designed to meet the financial planning, investment and insurance needs of clients.
UPDATING THIS POLICY
If we update this Policy, we will inform you of the modifications in this Policy in a timely manner. We reserve the right to add, delete, modify or otherwise amend this Policy, as we deem appropriate. For your convenience, the last date this Policy was modified has been indicated at the bottom of the Privacy website.