The Caldwell Group of Companies has always been committed to maintaining the accuracy, confidentiality and security of your personal and financial information. In accordance with current federal and applicable provincial legislation, and as part of our commitment to you, we have adopted privacy practices to protect your personal information.
Personal information refers to information that identifies you. It may include information such as your age, marital status, employment history, social insurance number, credit history, home address, personal email address and home telephone number.
Principle 1 – Accountability
Each Caldwell Company is responsible for maintaining and protecting the client information under its control. In fulfilling this mandate, each Caldwell Company has designated an individual or individuals who is/are accountable for compliance with applicable legislation and the Caldwell policy.
Principle 2 – Identifying purposes
The purposes for which personal information is collected include:
- Providing you investment management services. Securities law and regulations require us to be informed about your personal financial circumstances and investment objectives.
- Executing securities transactions, with discretion.
- Disclosing your information to securities issuers and other market intermediaries to register securities in your name, generate relevant tax reporting, as applicable, and to ensure segregation of your assets.
- Servicing your account, including but not limited to making tax payments and/or reporting, meeting legal requirements to know our clients and verify your identity, checking your credit history where required, recording beneficiary information and providing you with account statements, confirmations and tax receipts.
- Carrying out our responsibilities under the law and regulations which govern our businesses. From time to time we may be required to provide government agencies or securities regulators with information about our clients (see also Principle 5).
Principle 3 – Consent
Your informed and meaningful consent is required for us to collect, record, maintain, use and disclose, except where required or permitted by law. Caldwell will provide meaningful information as to why we require the information and our intended use of the information at the time of collection. If we do not have the required information or you do not provide consent for its use, we may not be able to provide our services to you.
Principle 4 – Limiting Collection
Any information collected from you, will be limited to the uses disclosed to you and upon which you have provided consent to Caldwell. The primary means for collecting this information is the completion and updating of our New Client Application Form and the accumulation of transaction information in your account. Other information may be provided to Caldwell about you in connection with the servicing of your account, from parties other than yourself. For example, from custodians, securities issuers, credit bureaus and other third parties.
Principle 5 – Limiting Use, Disclosure and Retention
Client information collected may only be used or disclosed for the purposes for which it was collected unless you have otherwise consented, or when it is required or permitted by law. Such information may only be retained for the period of time required to fulfill the purpose for which it was collected or as required by law, whichever is the longer period.
We will not use client's personal information for any purpose other than that for which it was obtained without obtaining consent. (See Principle 2.) We advise our clients that regulators such as the provincial Securities regulators, the Investment Industry Regulatory Organization of Canada and the Canadian Investor Protection Fund and other regulatory and authoritative bodies or courts of law, may require access to personal information of current and former clients, employees (including directors and officers) and others that have been collected by us. These regulatory bodies collect, use or disclose such personal information obtained from us for regulatory purposes, including surveillance of trading-related activities, regulatory audits, investigations of potential violations of rules or laws, enforcement or disciplinary proceedings, and information sharing with other regulatory organizations in connection with any of the foregoing.
If we need to disseminate your personal information in any situation other than those we have described, we will obtain your consent before we do so.
Principle 6 – Accuracy
Client information is maintained by us in as accurate, complete and up-to-date form as is necessary to fulfill the purposes for which it is to be used. We are obligated under securities laws that govern the services we provide to you, to maintain certain personal information current at all times. You also have the right to ensure the information is accurate and to request it be updated in our records.
Principle 7 – Safeguarding Customer Information
Policies, procedures, guidelines, and safeguards have been put in place to ensure your personal information is protected. All of our employees and the service providers we use to support the services we provide you, have access to your personal information to enable them to perform their duties. We use multiple security measures as appropriate in the circumstances to protect your information against unauthorized access, modification, loss, theft or general misuse. These may include the use of passwords, physical restricted access to the location of the records as well as systems and technology housing the information, file encryption protections, and network protections to address potential cybersecurity threats.
Notwithstanding the securities measure put into place, sometimes, beyond our control, there may be breaches in the controls we established to maintain your personal information confidential. In the event of such a breach occurs, Caldwell will take all reasonable measures to secure the personal information, including requiring our service providers to take measures considered necessary to secure and remedy the breach. In the event a detected breach may result in the potential risk of harm, disclosure of sensitive information or risk of theft of identity and/or assets, Caldwell will contact you as soon as possible and provide details of actions taken by us and may recommend actions to be taken by you, to reduce the identified risks. The responsibility of securing your personal information is of important and we commit to take measures we determine appropriate in the circumstances to mitigate any risks to you.
Principle 8 – Openness
The Caldwell Group of Companies will make available to clients information concerning the policies and practices that apply to the management of their information.
Principle 9 – Access
Upon written request, a client will be given access to his or her information. Clients may verify the accuracy and completeness of the information, and may request, in writing, that it be amended, if appropriate.
Principle 10 – Handling Customer Complaints and Suggestions
We are committed to treating you and your personal information with sensitivity and respect in all dealings. From time to time however, a misunderstanding or error may occur, impacting matters of privacy. In such circumstances, Caldwell will act diligently to resolve the problem and will contact you as soon as possible. In the event you notify us of a complaint, we will acknowledge the complaint promptly and within 10 days.
You may lodge a complaint by contacting the privacy officer directly:
Caldwell Investment Management Ltd.
In the event you find proposed solutions unacceptable, you may escalate your complaint to the regulators directly:
The Privacy Commission of Canada
The Commission d'accès à l'information