Ten Principles of PIPEDA
- Accountability: Organizations are accountable for the personal information they collect, use, retain, and disclose in the course of their commercial activities, including, but not limited to, the appointment of a Privacy Officer.
- Identifying Purposes: Organizations explain the purposes for which the information is being used at the time of collection and can only be used for those purposes.
- Consent: Organizations must obtain an individual’s express or implied consent when they collect, use, or disclose the individual’s personal information.
- Limiting Collection: The collection of personal information must be limited to only the amount and type reasonably necessary for the identified purposes.
- Limiting Use, Disclosure, and Retention: Personal information must be used for only the identified purposes. It must not be disclosed to third parties unless the individual consents to the alternative use or disclosure.
- Accuracy: Organizations are required to keep personal information in active files accurate and up-to-date.
- Safeguards: Organizations use physical, organizational, and technological safeguards to protect personal information from unauthorized access or disclosure.
- Openness: Organizations must inform their clients and train their employees about their privacy policies and procedures.
- Individual Access: An individual has a right to access personal information held by an organization and to challenge its accuracy if need be.
- Provide Recourse: Organizations are to inform clients and employees on how to bring a request for access or complaint to the Privacy Officer and respond promptly to a request or complaint by the individual.
Privacy and Disclosure of Information
OFIC treats all personal information confidential, according to PIPEDA and PIPA that govern the collection, use, and disclosure of personal information. Personal information will not be used or disclosed for purposes other than those for which it was collected unless you provide expressed consent or if required by law.
OFIC collects personal information to allow us to provide you services and meet legal and regulatory requirements. Personal information is collected through our client discovery process, which involves:
- The KYC interview;
- Client telephone and face-to-face conversations and meetings;
- Documents submitted to us or related affiliates, and
- Any transactions with us or our affiliates.
While we do our best to obtain only necessary personal information from our clients, we are required to collect specific information to enable us to provide our services and fulfill our legal/regulatory obligations. In general, we collect information for the following purposes:
- To fulfill our fiduciary obligations as a Portfolio Manager;
- To verify your identity following applicable Anti-Money Laundering (“AML”) and Securities Legislation;
- To be able to open and service your Account;
- To be able to facilitate electronic fund transfers to and from your Account or from other financial institutions;
- To detect and prevent fraud and other unauthorized or illegal activities;
- To meet legal and regulatory requirements, and
- To fulfill tax reporting obligations.
Financial and Personal Information Collection
We collect information about your financial and personal circumstances when you open an account with us to ensure our investment recommendations are appropriate for you. We also collect information from you, such as your name, address, date of birth, and occupation. We may collect additional information from consumer reporting agencies to verify your identity under local AML regulatory requirements. We may also collect your Social Insurance Number (“SIN”) for income tax reporting purposes or register specific account types with the government.
For registered accounts, we are required to collect information about any beneficiaries that you designate to your Accounts, such as your designated beneficiary’s name and date of birth.
We may transfer your personal information to third-party service providers that provide services on our behalf and government agencies where permitted. Third-party service providers are not allowed to use your personal information for their own purposes and are contractually obligated to maintain strict confidentiality. We limit their use of your personal information to the performance of the specific service we have requested.
When you open an account with OFIC, you will also be required to open an account with the Custodian. The Custodian will provide account administrative services such as trade execution, clearing, and other services on our behalf. We must also notify them of any updates or changes to your Account information.
We and/or our Custodian may share your name, contact information, and holdings with issuers of securities that you hold in your Account and other persons/companies as required by securities law. Such issuers may require your personal information to deliver financial reports, tax documents, and other relevant materials to you or comply with applicable regulatory obligations.
We may disclose or report personal information in limited circumstances where we believe in good faith that disclosure is required or permitted under the law, including any applicable anti-money laundering legislation or similar laws.
We may collect and/or maintain Internet Protocol (“IP”) addresses of visitors to our website and other related information such as page requests, browser type, operating system, and average time spent on the website. We may use this information to understand user behaviour anonymously without personally identifying individuals.
We may obtain your consent to send you emails and other communications about products and services that may interest you. You can unsubscribe from these communications at any time by emailing firstname.lastname@example.org or by using the unsubscribe mechanisms provided in these communications. Please note that unsubscribing will not unsubscribe you from account-related documentation delivered to you for non-marketing purposes.
Your online access to the account portal is protected with a password of your choosing. We strongly recommend that you do not disclose your password to anyone. We will never ask you for your password in any unsolicited communication such as letters, phone calls, or email messages.
Safeguards to Protect Information
The privacy of our clients is crucial to us. We maintain reasonable administrative, technical, and physical safeguards to protect personal information in our possession. We train our employees to keep personal information private and confidential. Personal information is stored at OFIC’s office and may be stored on the networks of our service providers and at secured offsite storage facilities. You may access your personal information to verify its accuracy, withdraw your consent to any of the foregoing collections, uses, and/or disclosures being made of your personal information, and update your personal information by contacting the Privacy Officer email@example.com. Withdrawing your consent may impact our ability to service your Account.
Consent to the Collection of Data
Unless you advise otherwise, by providing us with your personal information, you have consented to our collection, use, and disclosure of your information as provided herein. If OFIC intends to disclose personal information to third parties for a purpose other than to manage and/or administer our services, then OFIC shall notify you of the purpose for such personal data to be disclosed. If you wish that such personal information not be used or disclosed to third parties for a purpose other than to administer or manage the services, you can opt-out by way of a written notice to the Privacy Officer at firstname.lastname@example.org.
1055 West Georgia Street
P.O. Box 11177 Vancouver, B.C. V6E 4N3
All submissions/inquiries should be directed to the attention of the Privacy Officer.