Privacy Policy
Guiding Principles
1. Accountability: Montcalm and Associates is responsible for personal information under its control and shall designate an individual or individuals who are accountable for compliance with privacy principles.
2. Identifying Purposes: The purpose(s) for which personal information is collected from all clients shall be identified at or before the time the information is collected.
3. Consent: The knowledge and consent of the client are required for the collection, use, or disclosure of personal information, except for legal or security reasons.
4. Limiting Collection: The collection of personal information shall be limited to that which is necessary for the purposes identified. Information shall be collected by fair and lawful means.
5. Limiting Use, Disclosure and Retention: Personal information shall not be used or disclosed for purposes other than those for which it was collected, except with the consent of the client or as required by law. Personal information shall be retained only as long as necessary for the fulfillment of those purposes.
6. Accuracy: Personal information shall be as accurate, complete, and up-to-date as is necessary for the purposes for which it is to be used.
7. Safeguards: Personal information shall be protected by security safeguards appropriate to the sensitivity of the information. All client information/files should remain in a secure location at all times.
8. Openness: Montcalm and Associates and its representatives shall make readily available to all clients specific information about its policies and practices relating to the management of personal information.
9. Client Access: Upon request, a client shall be informed of the existence, use, and disclosure of his or her personal information and shall be given access to that information. A client shall be able to challenge the accuracy and completeness of the information and have it amended as appropriate.
10. Challenging Compliance: A client shall be able to address a challenge concerning compliance with the above principles to the designated individual or individuals accountable at Montcalm and Associates for compliance with this Privacy Policy.
Management of Information
* All references made to Montcalm and Associates include its officers & directors, managers and employees.
CLIENT RECORD AND PERSONAL INFORMATION: The personal information collected about you for the purposes identified in Montcalm and Associates' Privacy Policy is held in a record called the “client record”. The personal information collected may include (but is not limited to) your name, address and telephone number, employer name, address and telephone number, social insurance number, birth date, income and net worth, account holdings, the name, address, and birth date of your spouse or beneficiary, and medical/health information (insurance applications).
PURPOSE FOR COLLECTING PERSONAL INFORMATION: When you complete account documentation you are providing personal information and thereby providing consent to collect, hold, disclose and use personal information to Montcalm and Associates including, where applicable, information concerning your spouse and beneficiary in order to:
- open a new insurance or investment account;
- assist your financial advisor to determine your insurance requirements;
- apply for additional insurance coverage or amend existing insurance coverage;
- assist your financial advisor in the creation of a financial plan for you;
- make a new investment or contribute to an existing investment;
- transfer or redeem monies from an existing investment.
Each company with whom you open an account collects this personal information, holds it in your client record, uses it and, when needed, discloses if for the purposes identified in this Privacy Policy. Personal information may also be collected by your financial advisor and/or one of their employees for the purposes stated in this section.
COLLECTING, HOLDING, USING AND DISCLOSING PERSONAL INFORMATION IN YOUR CLIENT RECORD: Montcalm and Associates (or one of its employees) may collect, hold and use the personal information in your client record as well as collect personal information from or disclose your personal information to third parties identified in section 4 for the following purposes:
- identifying you and ensuring the accuracy of information contained in your client record;
- assisting your financial advisor in the creation of a financial plan; assisting your financial advisor in determining the suitability of your investments or life policy;
- assisting a mutual fund company or life insurance company in establishing and administering your account;
- facilitating a transaction with a mutual fund company, financial institution or insurance company;
- correcting errors on your accounts at Montcalm and Associates, a mutual fund company or an insurance company;
- providing you and your financial advisor with investment account statements, life insurance policy details, transaction confirmations and other information which you or your financial advisor may request as needed to service your accounts;
- meeting legal and regulatory requirements;
- verifying information you have previously given to any other organizations when necessary for the purposes provided in this Privacy Policy.
THIRD PARTIES: Montcalm and Associates (or one of its employees), may disclose your personal information for the purposes identified in this Privacy Policy to third parties such as other financial institutions, mutual fund companies, insurance companies, paramedical companies or any related administrative firms with whom you require service i.e. government agencies such as the Canada Customs and Revenue Agency, Human Resources Development Canada and securities regulatory bodies such as the Provincial Securities Commission and Financial Services Commission of Ontario, and self- regulatory bodies such as the Mutual Fund Dealers Association and any legal authority. If you wish to withdraw consent to the continuation of this information sharing or discuss the implications of such a withdrawal, please call 1-800-565-9219 and ask for the Privacy Officer. In some circumstances, legal requirements may prevent you from withholding consent. Your decision to withhold consent may also limit the products and services that Montcalm and Associates and your financial advisor is able to provide you because the disclosure to third parties is a necessary part of making the product or service available to you.
EMPLOYEES WHO HAVE ACCESS TO YOUR CLIENT RECORD: Employees of Montcalm and Associates may have access to your client record provided they have a specific need to know in connection with the purposes identified in this Privacy Policy and access is permitted only to the extent necessary for such purposes.
LOCATION OF CLIENT RECORD: Your client record may be kept in electronic format at Montcalm and Associates. Paper records forming part of your client record may be kept at Montcalm and Associates and/or at a related mutual fund company or life insurance company. Client records may also be kept in offsite storage and these may be transferred to other locations for disaster recovery purposes.
RIGHT TO ACCESS AND AMEND PERSONAL INFORMATION RECORDS: Except in limited circumstances prescribed by the Protection of Personal Information and Electronic Documents Act and similar provincial privacy protection legislation, you are entitled to access, through a written request, the personal information contained in your client record. Please contact your financial advisor to obtain personal information in your client record. You may verify this information and request that any inaccurate information be corrected.
CHANGES TO YOUR PERSONAL INFORMATION: Please inform Montcalm and Associates of any change to your personal information that you have provided by contacting our office at (613) 538-2424.
