T.L. COe Financial Ltd.
Privacy Policy
My clients are my business. As an advisor, I am trusted with some of my clients’ most sensitive personal information. I must respect that trust and need my clients to be aware of my commitment to protect the information they provide in the course of doing business with me.
I collect personal information in compliance with applicable laws and ethical business practices, in order to provide services and to conduct business. I limit the information that I collect to that which it is necessary for, or related to, these purposes.
I abide by the Ten Privacy Principles outlined within this brochure. These Principles are based on the federal government’s privacy legislation, the Personal Information Protection and Electronic Documents Act.
I hold my client data in strict confidence and will never share data with other individuals, professionals, companies, or institutions without the express consent of our client, or as required by law.
TEN PRIVACY PRINCIPLES
Based on the federal Personal Information Protection and Electronic Documents Act. “PIPEDA”
1. Accountability: An organization is responsible for personal information under its control and shall designate an individual or individuals who are accountable for the organization's compliance with the following principles.
2. Identifying Purposes: The purposes for which personal information is collected shall be identified by the organization at or before the time the information is collected.
3. Consent: The knowledge and consent f the individual are required for the collection, use or disclosure of personal information, except when inappropriate.
4. Limiting Collection: The collection of personal information shall be limited to that which is necessary for the purposes identified by the organization. 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 individual or as required by the law. Personal information shall be retained only as long as necessary for 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.
8. Openness: An organization shall make readily available to individuals specific information about its policies and practices relating to the management of personal information.
9. Individual Access: Upon request, an individual shall be informed of the existence, use and disclosure of his or her personal information and shall be given access to that information. An individual shall be able to challenge the accuracy and completeness of the information and have it amended as appropriate.
10. Challenging Compliance: An individual shall be able to address a challenge concerning compliance with the above principles to the designated individual or individuals for the organization's compliance.
PRIVACY CHOICES
Clients may request copies of my privacy policies and procedures at any time.
Clients may request access to their information. I must respond to this request as quickly as possible, but no later than 30 days after the receipt of the request.
Clients may withdraw their consent at any time by contacting me as the Privacy Officer. However, they will be made aware that failure to provide adequate information may prevent me from completing the task for which we were engaged.
Clients may file complaints about my privacy procedures as well as a breach in my privacy policy. Complaints should be received in writing and forwarded to the Privacy Officer. The Privacy Officer will contact the client and obtain all details. The Privacy Officer will then review the circumstances of the complaint and determine if there is reason to alter the existing privacy policy. Insurance carriers should be notified of any complaint involving their clients/products.
PROTECTION OF PERSONAL INFORMATION
As an advisor, I am granted access to my client’s information and understand the need to keep the information protected and confidential. My procedures clearly communicate that I am to use the information only for the intended purpose(s).
When hiring, new staff members are required to sign a confidentiality agreement upon commencement of employment.
PRIVACY TRAINING
I require and provide initial and ongoing privacy training for all staff to ensure compliance with the Canada’s Personal Information Protection and Electronic Documents Act “PIPEDA.”
SECURING INFORMATION
My procedures outline the security measures in place for protecting physical copies of my client’s documents and information.
Additionally, there are multiple security measures to protect digital and electronic data kept on our computer database as well as our electronic communications.
REVIEW AND UPDATE OF PRIVACY MEASURES
An annual review of privacy policies and procedures is conducted to ensure that the most current processes are in place to protect all sensitive and confidential data.