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 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 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.