IPC’s Personal Information Policy
Our commitment to you
Investment Planning Counsel Inc. and its subsidiaries (“IPC”, “we”, “our”, “us”) are committed to protecting the privacy of all personal information of clients that we collect and maintain in the course of carrying on our business. This Personal Information Policy (“Policy”) describes how we collect, hold, use and disclose your personal information when we do business with you. This Policy is provided in compliance with the Personal Information Protection and Electronic Documents Act (Canada) and, where applicable, similar provincial privacy legislation. Please contact us through one of the means listed at the end of this Policy if you have any questions.
IPC has a Chief Privacy Officer who is responsible for overall privacy governance. All of our employees and representatives across IPC are responsible to maintain your privacy and are available to address any questions or concerns you may have.
What is "personal information"?The personal information collected about you for the purposes identified in this Policy is held in our records. Your “Personal Information” may include your name, address and telephone number, social insurance number, birth date, account holdings, and the name, address and social insurance number of your spouse and any beneficiaries. Depending on the investment products or services you request, additional personal information may be held in our records. For example, if you have established a pre-authorized payment plan, your financial institution account number is also held in our records. Personal Information does not include the name, title or business address or telephone number of an employee of an organization so long as it is collected, used or disclosed for a purpose that directly relates to that individual’s employment.
How are we accountable?
IPC is responsible for your personal information in its possession or custody, including personal information that has been transferred to, or received from, a third party in the course of commercial activities for processing or other purposes for which you have consented.
Collecting, using and disclosing your personal information
What Information Do We Collect?
Most of the information we collect is directly from you when you apply for a product or service, enter a contest, sign-up for special offers or complete a survey. We also collect financial and other information about you from a variety of sources including from: references you have provided to us, transactions you have made with or through us, credit reporting agencies, and other financial institutions.
When you request products or services, we will ask you to provide only the information that enables us to complete your request, to provide better service or to offer you products and services we believe you might be interested in.
Information About You
Information essential for fulfilling most financial requests and applications includes:
- Information establishing your identity, such as your name, address, phone number, title, business phone number, email address, date of birth, social insurance number or social security number (for tax purposes), and account numbers;
- Information related to transactions arising from your relationship with and through us, and from other financial institutions;
- Information you provide on an application for the provision of our products and services, such as your annual income, place of employment, investments, account balance, financial liabilities, transaction history;
- Information about financial behaviour such as your payment history and credit worthiness.
- Information about your health may be collected for insurance products and services.
- Information pertaining to business clients will include your business name, address, phone number, email address, industry type, financial status and detail(s) on the owner(s), operator(s) and director(s).
- Additional information may be requested to help us determine your eligibility for products and services that we offer.
Why do we do it?
We collect, use and disclose personal information in order to provide you with the products and services that will help you to meet all of your financial goals. Knowing you helps us to understand your wealth management needs, communicate effectively with you, and provide you with suitable services and products. Specifically, we collect, use and disclose your personal information to:
- verify your identity;
- determine your eligibility for IPC products and services, and for products that may be of interest to you from business partners with whom we have formed an association, and offering to you these products and services;
- manage our risks and operations; analyze the suitability of our products or services for you;
- analyze the suitability of our products or services for you;
- provide you with ongoing services, establish and maintain communications, and to respond to your inquiries;
- determine prices, fees and premiums;
- investigate and settle claims;
- detect and prevent fraud;
- compile statistics, conduct market research and report to regulatory and industry agencies;
- investigate specific transactions or patterns of transactions to detect unauthorized or illegal activities;
- comply with our legal and regulatory requirements
If we have your social insurance number, social security number we may use it for tax related purposes if you hold a product generating income and share it with the appropriate government agencies. We may also share it with credit reporting agencies as an aid to identify you.
Personal information may be collected, used or disclosed for any of these "Identified Purposes" set out above. If your personal information is not needed for one of the Identified Purposes, we will not use or disclose it without obtaining additional consent from you.
- Where information is captured or stored electronically, for the Identified Purposes set out above, we may rely on third party vendors who are located outside of Canada. IPC is at all times accountable for your personal information and will ensure that security safeguards and appropriate contractual provisions are in place in order to help protect your personal information from unauthorized access.
- IPC is a subsidiary of IGM Financial Inc. (“IGM”). IPC may disclose your personal financial information to IGM, its employees and employees of its subsidiary corporations for the purposes set out above as well as for purposes related to financial reporting, legal affairs, complying with internal audits, facilitating anti-fraud measures and to periodically assist IPC in completing audits of its branch locations.
- We may communicate with you through various channels including telephone, computer or mail using the contact information you have provided.
- With your consent, we may use your information to promote our products and services and those of third parties that we select, which we believe you will be interested in.
- Note that sensitive information such as health records will never, under any circumstances, be shared or used for a purpose other than that of the original intent.
How do we do it?
The collection, use and disclosure of your personal information depends on how you do business with us. We may gather information from the following sources:
- from you, on applications for our insurance, banking and investment products, or on other forms filled out through telephone, email or face-to-face interviews, such as your name, address, telephone number, email address, occupation, financial and banking information, and health information;
- from licensed agents, insurance brokers, intermediaries and financial services representatives with whom you have a relationship, as well as adjusters and inspectors;
- from your interactions with us, such as your transaction history and correspondence;
- from government and other entities, such as your claims history; or
- from consumer reporting agencies, such as your credit history.
If you provide personal information to us or through any of the above sources, you do so with the understanding that your personal information may be disclosed for the Identified Purposes amongst us, the above sources, or third parties and that IPC may verify such information, or obtain additional personal information about you by checking with government agencies, credit bureaus, and other fact collecting and verifying entities to assist us for the Identified Purposes.
Your knowledge and consent are required before we may collect, use or disclose your personal information, except in special circumstances, such as during a fraud investigation, an investigation by the police, or in situations otherwise permitted by the law. If any of the personal information that we collect is sensitive, such as health information, we will obtain additional written or oral consent from you before collecting, using or disclosing the information.
How do you provide us with your consent?
We accept any of the following as your consent for IPC’s existing use and future collection, use and disclosure of your personal information for the Identified Purposes:
- your receipt of this Personal Information Policy, unless you advise IPC, either orally or in writing, that you do not agree with the terms stated in this policy, and that you wish to opt out of all or portions of it;
- your unrestricted provision of information to IPC, either directly or through licensed agents, insurance brokers, adjusters or financial services representatives;
- your express written or oral consent as obtained through an application process; or
- your consent as provided by your authorized representative, such as a legal guardian or power of attorney.
In some circumstances, your consent may be implied. For instance:
- If you obtain products and/or services for your family or anyone else, you represent that you have obtained consent from them to the collection, use and disclosure of their personal information for the Identified Purposes, even though they might not be present during the application process.
- If you have existing products and services with us and you request amendments to them, it is assumed that the consent which you gave to us when buying the original products and services remains in effect.
How can you withdraw your consent?
You may withdraw your consent at any time upon reasonable notice, subject to legal or contractual restrictions. Please note, however, that withdrawing your consent may affect our ability to continue to provide you with the products and services that you have or would like to receive.
If you wish to withdraw your consent to this information sharing or discuss the implications of such a withdrawal, please contact our Privacy Officer at the address or telephone number listed below. Unless we hear otherwise from you, you are giving to us your consent for the collection, use and disclosure of personal information as provided in this Policy for the Identified Purposes.
Keeping and protecting your personal information
How long do we keep your personal information?
Your personal information is retained only so long as we need it to effectively provide products and services to you, and for a reasonable length of time thereafter in case we need to meet any potential obligations or legal or government requirements. IPC shall use care when storing or destroying your personal information in order to prevent unauthorized access.
How do we protect your personal information?
Whether in electronic or paper-based format, IPC maintains strict security systems to safeguard your personal information from unauthorized access, disclosure or misuse. As well, when we no longer need your personal information, we take as much care to destroy it as we do when storing it.
IPC may transfer your personal information for the purposes identified in this Notice to our service providers, such as account statement preparation and mailing companies, courier companies, imaging companies, and document storage companies. When IPC transfers personal information to our service providers, we ensure by contractual means that the transferred personal information is used only for the purposes for which the service provider is retained and is protected to the same degree as it is when in our possession. We may use service providers located outside of Canada, and where we do, personal information may be disclosed in accordance with the laws of the jurisdiction in which the service provider is located, including to the government in that jurisdiction and its agencies.
Your right to access your personal information
You have a right to access your personal information that we have in our possession or control. You also have a right to know which third parties have received your information from IPC.
In order to access your personal information, please make your request in writing to IPC’s Privacy Officer, stating as specifically as possible which personal information you are requesting. We try to respond to such requests as soon as possible, and will advise you if for some reason we cannot respond right away. IPC may charge you a reasonable fee for providing access to your personal information, but only after first advising you of the approximate cost.
In providing you with a list of the organizations to whom we have disclosed any of your information, we will try to be as precise as possible. When it is not possible to provide an exact list of such organizations to which we have actually disclosed your personal information, IPC shall provide a list of organizations to which we may have disclosed the information.
IPC has the right to refuse your request for access to personal information if:
- the information is protected by solicitor-client privilege;
- granting access would reveal confidential commercial information;
- doing so would reasonably be expected to threaten the life or security of another individual;
- the information was collected for purposes related to the detection and prevention of fraud;
- the information was generated in the course of a formal dispute resolution process; or
- the information would likely reveal personal information about another individual.
Keeping your information accurate
IPC strives to ensure that the personal information we have on file for you is as accurate and up-to-date as necessary for the Identified Purposes for which it is to be used. If any information needs to be updated or amended to reflect a change in your situation, we make every effort to update our records. IPC shall amend personal information that is materially inaccurate or incomplete and, where appropriate, shall endeavour to advise other parties having access to the information in question.
How to contact us
Updated versions of this Personal Information Policy are posted on IPC’s website at www.ipcc.ca, or you can direct any queries about the policy to IPC’s Privacy Officer at the telephone, e-mail address, or mailing address listed below.
If you have a complaint related to the Personal Information Policy or any of our procedures, contact our Privacy Officer. If your complaint is justified, we will take the steps necessary to resolve the issue, including amending our policy and practices, if necessary.
If we are not able to resolve your concern, or if you have any other concerns about IPC’s Personal Information Policy and procedures, you may contact the Office of the Privacy Commissioner of Canada or, if applicable, the provincial privacy commissioner. IPC’s Privacy Officer will provide you with this contact information upon request.
For more information, to file a complaint, to make enquiries, or to opt out of all or parts of this Policy, please contact IPC’s Privacy Officer:
For more information about privacy, you may contact the Office of the Privacy Commissioner of Canada or the Office of your provincial Privacy Commissioner if you are resident in Alberta, British Columbia, Ontario or Quebec as follows:
- Office of the Privacy Commissioner of Canada: www.privcom.gc.ca
- Office of the Information and Privacy Commissioner of Alberta: www.oipc.ab.ca
- Office of the Information and Privacy Commissioner for British Columbia: www.oipc.bc.ca
- Information and Privacy Commissioner of Ontario: www.ipc.on.ca
- Commission d’accès à l’information du Québec: www.cai.gouv.qc.ca
Updated: November 10, 2015