At IA Clarington Investments Inc. ("IA Clarington") we take the
issue of privacy seriously. We are committed to providing investors
with excellent service while respecting the privacy of personal
information. Each IA Clarington employee is responsible for
ensuring the confidentiality of all personal information to which
they have access.
Personal Information
Personal information is information that identifies an
individual. It includes information such as age, marital status,
social insurance number, home address and telephone number.
How do we use personal information?
Obtaining personal information allows us to:
- Establish the identity of investors;
- Ensure our records are accurate;
- Establish and administer accounts;
- Execute transactions;
- Maintain account holdings and transaction records;
- Verify information previously given;
- Provide investors and their investment advisers account
information and statements;
- Provide investors with financial statements, tax receipts,
transaction confirmations, proxy mailing and other information that
may be required to service accounts;
- Provide customer service; and
- Meet legal and regulatory requirements.
How do we obtain personal information?
In order to ensure that your investment in an IA Clarington
investment product is administered efficiently, we will
collect personal information from you or from your dealer. We may
collect the information in various ways, including electronic
transfers and telephone calls, and may retain copies of documents,
or recordings of telephone calls, that contain personal
information.
To whom do we disclose personal information?
In order to provide the best possible client service, we may be
required to disclose personal information to third parties in the
normal cause course of business. These third parties include:
- Your investment advisor;
- Other financial institutions, securities dealers, and mutual
fund companies, for example, when you move your investments from
one firm to another;
- Affiliates of IA Clarington;
- Contracted third-party service providers;
- Canadian government, government agencies and regulators;
and
- Any other entity as required by law.
IA Clarington may be required to provide personal information in
response to a search warrant, court order or other legally valid
request.
Obtaining Consent
If you have completed an investment application with us, you
have provided us with personal information. Notice of IA
Clarington's use of personal information is disclosed on the back
of the IA Clarington investment application under the heading of
"Your Personal Information". By signing an application form you are
consenting to the use of your personal information. IA Clarington's
Privacy Notice explains how we collect, hold, use and disclose
personal information. This Notice may also be sent to you. By
continuing to do business with us, you are consenting to the use of
your personal information, as described under the heading "To whom
do we disclose personal information?"
Some investors may have completed an investment application form
through a dealing representative or other party that is unrelated
to IA Clarington, thereby providing personal information. Any
personal information which may be disclosed to us through an
unrelated party is also subject to IA Clarington's Privacy
Policy.
How can you withdraw your consent?
You may withdraw your consent to IA Clarington's use of your
information by contacting us. In some circumstances, legal
requirements may prevent you from withholding consent. The decision
to withhold information may also limit the products or services we
are able to provide.
How can you access your personal information?
Upon written request IA Clarington will provide you with access
to your personal information. Please note that we may not be able
to provide you with your information in certain circumstances, for
example: where information contains references to other persons;
where information contains proprietary information confidential to
IA Clarington, or where information cannot be disclosed for legal
reasons.
How can you ensure your information is accurate?
The accuracy of your personal information is essential to
providing you with excellent service. If you wish to change or
update your personal information, please contact us. Please inform
us of any errors regarding your personal information right away, so
that we may correct our records.
Where is your personal information kept?
Your personal information may be kept in electronic or paper
format in our offices, in secure off-site storage facilities, or in
the offices of our service providers, such as International
Financial Data Services (Canada) Limited. Your personal information
may also be held in the offices of U.S.-based third-party service
providers that provide IA Clarington with data hosting and imaging
services, for example. U.S. laws regarding the protection of
personal information may afford you lower protection than that of
Canadian laws.
How do we protect your personal information?
Policies, procedures and safeguards have been put in place at IA
Clarington to ensure your personal information is protected. Our
employees and service providers have access to your personal
information to enable them to provide necessary services to you.
Any personal information collected from you will only be used for
the purposes identified at the time of collecting the information
and will be retained for as long as is necessary to fulfill the
service, or as required by law.
Security measures including passwords, restricted access to our
offices and records and physical access security, have been put in
place to protect your information against unauthorized access,
modification, loss, theft or general misuse.
Questions, Concerns and Complaints
If you have any questions, concerns or complaints regarding
matters of privacy please contact us. In most cases concerns can be
resolved by discussing it with one of our Client Service
Representatives.
Phone: 800-530-0204 or 416-860-9880
Email: privacy@iaclarington.com
If your concern has not been resolved to your satisfaction, please
contact our Privacy Officer.
Phone: 1-888-860-9888 or 416-860-9880
Email: privacy@iaclarington.com
Write to: Privacy Officer
IA Clarington Investments Inc.
522 University Avenue, Suite 700
Toronto, ON M5G 1Y7
If after contacting our Privacy Officer your concern remains
unresolved, you may contact the Privacy Commission of Canada:
The Privacy Commission of Canada
112 Kent Street
Ottawa, Ontario
K1A 1H3
Phone: 613-995-8210 or 1-800-282-1376
Or in Quebec:
The Commission d'accès a l'information
575, rue St. Amable, Bureau 1.10
Québec, Québec
G1R 2G4
Phone: 418-528-7741 or 1-888-528-7741