Our Commitment to Privacy
At MacDougall Investment Counsel Inc. (‘MIC’) we respect your privacy and the confidentiality of your personal information. We are committed to keeping your personal information you share with us confidential. To provide the highest possible protection to you, we maintain standards designed to protect and prevent any misuse of your personal information. This policy is an explanation of how we collect, use, disclose and protect your personal information.
What is Personal Information?
For individuals, ‘Personal Information’ is information that identifies you as an individual. This includes information with respect to your name and address, age, gender, marital status, finances, employment, trading history and personal identification numbers such as your social insurance number (‘SIN’).
For business clients, information includes the above data plus names of officer, directors, beneficial owners and ownership structure, shareholders, financial information and jurisdiction of incorporation.
Why is Personal Information Collected?
Collecting and retaining personal information about you is essential to our ability to adhere to our industry’s ‘Know Your Client’ rule. Personal information obtained from you will be used to protect and administer your accounts, records and funds; to comply with certain laws, regulations and regulatory policies; to help us improve our products and services offered to you; and to understand your financial needs. The information we ask for depends on the products or services you request and in most cases are required by law or Canadian securities regulatory authorities to which we are subject. For example, your social insurance number is required for products that earn investment income, in order to comply with the Canada Revenue Agency’s income reporting requirements.
With your consent, we may share your personal information, where not prohibited by law, with existing or future subsidiaries or affiliated companies of MIC for the purpose of insurance, tax or estate services. Sharing such information will be for the sole purpose of serving you better and determining whether any products or services we provide through our subsidiaries or affiliated companies are suitable for you. This consent is optional and you can decide to withdraw it at any time. Please refer to the Right to Withdraw Consent section.
How We Collect Personal Information About You
We collect most of our information about you directly from you. With your consent, we may also obtain personal information about you from third parties. For example, for credit or margin purposes we may need to determine your creditworthiness through contact with an independent credit-reporting agency.
Privacy on the Internet
We recognize that you may have privacy concerns regarding our services provided on the Internet. We share your concerns and we are committed to protecting the misuse of client information on the Internet. Remember, email over the Internet is generally unencrypted. Therefore, we recommend that you do not send us sensitive or confidential information by ordinary email.
MIC uses ‘cookies’, a standard technology that installs information on a visitor’s computer to permit our website to recognize future visits by that computer. Cookies enhance the convenience and use of website. For example, MIC uses information provided through cookies to recognize you as a previous user of the site, offer customized web pages for your use, track your activity at our website to respond to your needs, and otherwise facilitate your web experience. The cookie is not used to retrieve any information from your computer that you have not already provided. You may choose to disable the cookies option on your browser; however doing so may affect your use of our website and your ability to access certain parts of our website.
Sharing Your Personal Information
MIC will not sell, trade or lend your personal information to any third parties unless we have your express permission to do so. We will disclose your personal information with your prior consent.
There are times when disclosure of your personal information is necessary. For example, service providers that we hire to do things like process your trades or send your month end statements to you will have access to certain account information including your name and address in order to perform their required functions. However, all such parties are required to sign agreements to help ensure that they will protect the confidentiality of your personal information.
Situations in which we may disclose your personal information without your consent include:
- To regulatory bodies within the investment industry;
- To a government institution which has identified its lawful authority to obtain the information;
- To law enforcement agencies or when we are in receipt of a valid subpoena, court order or warrant;
- To outside sources to help us collect a debt owed to us by you.
As well, we may disclose your information as a result of a transfer of our business, should we decide in the future to sell all or part of our business or to merge with another financial institution.
Protection of Personal Information
We maintain security standards and procedures to protect our systems and your personal information against unauthorized access and use. If you access your account through electronic means, we use passwords that you alone should know. We use our best efforts to ensure our service providers, suppliers and agents, as part of their contracts with us, are bound to maintain your confidentiality and may not use the information they obtain for any unauthorized purpose.
We retain your personal information only as long as it is required for the reasons it was collected or as required by law. The length of time we retain information varies depending on the product or service and the nature of the information.
This period may extend beyond the end of your relationship with us but only for so long as it is necessary for us to have sufficient information to respond to any issue that may arise at a later date. When your personal information is no longer needed or required, we have procedures to destroy, delete, erase or convert it to an anonymous form.
Right to Withdraw Consent
When you sign the documentation required to open your account, you will see that within that document is our Privacy Agreement. By opening an account with us, you are providing your consent for us to collect, use and release your personal information. If at any time you wish to withdraw this consent, please advise us. However, please note that withdrawing consent may mean that we will be unable to provide certain products or services to you. In certain circumstances, withdrawal of consent may cause us, by regulation, to be unable to administer your account. Upon request, we will explain the consequences of withdrawing consent should you choose to do so.
Your Right to Access Your Personal Information
We will provide you with access to your information upon your request. Most of your information is in the form of account documentation and transaction records. Although every effort will be made to accommodate your request, please note that we may refuse access in certain circumstances prescribed by law such as: where the information contains the personal information of other persons, where disclosure of your information to you would reveal our confidential commercial information or violate our legal privilege, or where we are otherwise required or permitted by law to refuse access.
Accuracy of Information
Having accurate information about you will enable us to give you the best possible service. You can help by keeping us informed of any changes such as if you move, if there is a change in your contact numbers or if there is any other material change in your personal information. If you find any errors in our information about you, let us know and we will make the corrections needed as soon as reasonably possible and make sure they are conveyed to anyone we may have misinformed. For information that remains in dispute, we will note your opinion in the file.
Addressing Your Concerns
If you have any questions about privacy and confidentiality, or any concerns about the way a request for personal information was handled, you should first contact your Portfolio Manager at the office that handles your account. In most cases, your Portfolio Manager will be able to resolve the matter for you. If your concerns remain unresolved, you can contact the MIC Privacy Officer at the coordinates below:
MacDougall Investment Counsel Inc.
Attn: Privacy Officer
1010 de la Gauchetiere West, Suite 2000
Montreal, Quebec H3B 4J1
Tel: (514) 394-3000
Fax: (514) 871-1481