Protecting your personal information and respecting your privacy is important to us. As a provider of financial products and services, the collection and use of personal information is fundamental to our business. Equally important is your trust in our handling of your personal information.
At ShaCole Brokerage, we are committed to providing the highest quality financial products and services in a manner that fosters trust and confidence among our customers, employees and representatives. That commitment includes protecting the privacy of all the personal information in our care. Therefore, we have established this Privacy Policy to govern how we collect, use, retain and disclose personal information. In handling customer and employee personal information, we abide by the following principles:
Privacy Principles
Information we collect
We collect personal information in compliance with applicable laws and ethical business practices, in order to provide products and services and to conduct business. We limit the information we collect to that which is necessary for, or related to, these purposes.
For online visitors, we may collect information, such as your IP address, the type of operating systems, the time and duration of your visit to our sites and the web pages you visit within our sites in order to track usage and improve our websites and to improve your experience.
How we use Personal Information
We may use or disclose your personal information for the purposes for which it was collected, other purposes you consent to, or as required or permitted by law. For example, subject to those limitations, we may share personal information with reinsurers, with our agents or representatives or with our service providers.
We will not share your personal information, without your consent, with any organization outside our group of companies for the purpose of that organization marketing its products or services to you.
We will keep your personal information only as long as needed to satisfy the purposes for which it was collected or as required or permitted by law.
We aim to keep our records of your personal information as accurate and up to date as is necessary to fulfill the purposes for which it is used.
Safeguards
We will protect personal information with security safeguards that are appropriate to the sensitivity of the information, in order to protect it from unauthorized access, release or use.
Our Privacy Commitment
We are committed to handling the personal information under our control with care. We have designated individuals who are responsible for monitoring our ongoing compliance with the Privacy Principles.
We will make information about our privacy policies and practices for managing your personal information available to you.
Upon your written request, we will provide you with reasonable access to your personal information and a description of its use or disclosure, as required or permitted by law. You may also verify the accuracy and completeness of your information, and request that it be amended, if appropriate.
ShaCole Brokerage abides by the following privacy principles. These Principles are based on the federal government’s privacy legislation, the Personal Information Protection and Electronic Documents Act. In addition to our Policy, our Online Privacy Statement and our practices and procedures to manage your personal information, define the high standards we set for ourselves to manage and protect your personal information.
Accountability: We are responsible for personal information under our control. We have designated individuals who are responsible for monitoring our ongoing compliance with the Privacy Principles.
Identifying purposes: The purposes for which personal information is collected, will be identified by us, or through our, or your, authorized representatives.
Consent: Your consent is required for the collection, use and disclosure of personal information, subject to certain exceptions. Such exceptions are set out in the law and include where legal, medical or security reasons make it impossible, or impractical, to seek consent. Your consent may be expressed in writing. It may also be given verbally, electronically, or through our, or your, authorized representatives. In certain circumstances, it may also be implied.
Limiting collection: The collection of your personal information must be by fair and lawful means, and be limited to that which is necessary for the purposes identified.
Limiting use, disclosure and retention: Your personal information may only be used or disclosed for the purposes for which it was collected, other purposes you consent to, or as required or permitted by law. It may only be kept for as long as is necessary to satisfy the purposes for which it was collected, or as required or permitted by law.
Accuracy: Any personal information that is collected, used or disclosed should be as accurate, complete and as up-to-date as is necessary for the purpose for which it is to be used.
Safeguards: Personal information shall be protected by security safeguards that are appropriate to the sensitivity of the information, in order to protect your personal information from unwarranted intrusion, release or misuse.
Openness: Information about our privacy policies and practices for managing your personal information shall be made available to you.
Individual access: Upon written request, you will be informed of the existence, use and disclosure of your personal information and you will be given access to it, subject to certain exceptions, as permitted by law. You may also verify the accuracy and completeness of your information, and request that it be amended, if appropriate.
Inquiries and concerns: You may contact us if you have any inquiries or concerns about our privacy policies and practices.
The information we collect
Personal information is information about an identifiable individual.
We will use fair and lawful means to collect your personal information. We will only collect information that is pertinent and consistent with the purposes of the collection. We may collect the required information directly from you, or from your advisor or an authorized representative(s), in completed applications and forms, through other means of correspondence, such as the telephone, mail or the Internet or other electronic means, and through your business dealings with us.
We may collect your personal information through public sources such as the Internet or through other third party service providers. In some cases, and with your consent, we may need to ask an independent source to verify or provide supplemental information. These sources could include, for example, service providers we retain, other insurance companies or financial institutions, your employer or credit reporting agencies. In the case of your medical or health-related information, additional sources could include your doctor(s), other healthcare providers or facilities.
If your information is being collected by telephone, the call may be recorded or monitored for the following reasons:
to establish a record of the information you provide,
to take or verify instructions from you,
to maintain quality service levels,
to assist in staff training
If you are not comfortable with having your telephone calls recorded, you have the option of communicating with us in writing instead. Where you have chosen to only communicate with us in writing, your written communications should request that any response to you be in writing, as well.
What we need to know and why
The type of personal information we gather will depend on the type of product or service involved. For example, it would depend on whether the product or service is banking, insurance or investment-related. The information gathered may be financial, which would include such information as place of employment, annual income, assets and liabilities. It may be investment or advice-related, requiring information on such things as your financial goals and retirement plans. If you are applying for insurance or group insurance benefits, it may also include health information or lifestyle-related information, such as your occupation, travel history and plans, driving record or criminal record.
Generally, we collect, use and disclose your personal information to:
Confirm your identity, and to protect both you and us against errors, fraud or other misrepresentations,
Evaluate your financial needs and determine the suitability of our products and services for you,
Determine your eligibility for products and services,
Properly administer the products and services we provide, including the assessment of claims,
Comply with a variety of legal requirements, such as provincial and federal tax reporting, anti-money laundering and unclaimed property obligations,
Assist us to understand the current and future needs of our customers, for example, to conduct customer surveys and other forms of market research and analysis
YOUR SOCIAL INSURANCE NUMBER
There are a number of reasons why we may ask for your Social Insurance Number (SIN).
Where there may be interest income or other income to be reported, your SIN is required by law in order to meet tax-reporting requirements.
With your consent, we may also use your SIN as a unique identifier, to keep your personal information separate from that of other customers, or individuals with a similar name, and to help maintain the integrity and accuracy of your personal information. For example, where it is appropriate to verify your credit history, we may use your SIN to ensure that the credit information we are asking for — and receiving — is about you, rather than someone else with the same or similar name.
You may elect not to have your SIN used for purposes other than as required by law; however, as explained earlier, this may affect our ability to fully ensure the accuracy and integrity of your personal information.
Your consent
Your consent may be expressed in writing, or it may be given verbally, electronically, or through our, or your, authorized representative(s), such as your financial services advisor.
Your consent may also be implied or inferred from certain actions. For example, if you present your benefit identification card to your healthcare provider, instead of paying for the prescription or procedure directly, it is understood that you are giving your consent for the healthcare provider to provide your personal information to us, in order for us to process the claim payment.
You may withhold or withdraw your consent for us to collect, use and disclose your personal information, as long as there are no legal or contractual reasons preventing you from doing so. Depending on the circumstances, however, withdrawal of your consent may impact our ability to continue to provide you with the products and services you have requested, or, in the case of insurance and group insurance benefits, it may prevent us from keeping your coverage in force, or properly evaluating and processing any claims.
How we share and destroy your information
Generally, the disclosure of your personal information will be restricted to those who have a need for, and the right to, the information.
Your personal information will only be provided to, or be accessible by:
Our employees, agents and representatives, who need the information in the performance of their duties for us,
Our affiliates, to:
resolve your concerns about any related products and services with us
assist in other required investigations
Service providers, who need the information in the performance of their duties for us, and to satisfy their obligations to us,
Any person or organization to whom you gave consent, and,
Anyone who is otherwise authorized by law
In some cases, your personal information may be provided to these people, organizations and service providers in other provinces or jurisdictions outside Canada, and would therefore be subject to the laws of those provinces or jurisdictions.
Due to the nature of our products and services, we are required to keep your information for extended periods of time. Personal information that is no longer required will be destroyed, erased or made anonymous.
When we destroy personal information, we will use safeguards to prevent unauthorized access to the information during the destruction process.
Service Providers
We may use service providers to provide us with various services such as, printing, mail distribution, information technology, data storage, administration, marketing, (which would include market research and promotional services), paramedical, claims adjudication, investigation and reinsurance. Where personal information is provided to our service providers, we will require them to protect the information in a manner that is consistent with our privacy policies and practices.
Accessing and amending your information
We will make all reasonable efforts to ensure that any personal information we collect and keep is as accurate, complete and as up-to-date as required for the identified purposes. To do so, we will rely to a large extent on you to provide us with accurate information and to inform us of changes, such as changes in your contact information. You have the right to access and verify your personal information maintained in our files, and to request that any factually inaccurate personal information be corrected, if appropriate. Depending on the circumstances, we may not always be able to give you access to all information, or there may be a charge for personal information that you request. Should this happen, we will let you know.
We are committed to protecting your information
We are committed to protecting your personal information from unauthorized access or use, by ensuring that the necessary physical, organizational and technological safeguards are in place, that are appropriate to the sensitivity of the information. Essentially, this means that personal information is protected:
Physically, by building security measures and physical barriers,
Organizationally, by our policies, procedures and access levels, and,
Technologically by, for example, where appropriate, the use of passwords, encryption, firewalls, anti-virus and anonymizing software
All of our employees, representatives, agents and service providers, who act on our behalf, are required to abide by our privacy policies and practices.
If we receive a request to release your personal information, we will only do so upon satisfactory identification and proof of entitlement of the requestor, or as required or permitted by law.
Offers from other Service Providers and/or Affiliates
Some of our business areas may, from time to time, offer or promote their other financial products and services, or those of our affiliates and select third parties, that we believe may be of interest to you.
We will share personal information with our affiliates for these purposes, only if the law permits it.
Please note that we do NOT give your personal information, without your consent, to any organization outside of our member companies, for the purpose of that organization marketing their own products or services directly to you.
If you do not wish to receive our marketing offers or special promotions, you may choose to “opt out”, by simply contacting us, and we will remove your name from our mailing lists. This means you will not be eligible to receive addressed, direct mail offerings. This opt-out will not extend to:
Information included in, or with, periodic statements, which relates to any ShaCole Brokerage product or service that you currently have with, or receive from, us, or
General product and service information and updates included in, or with, client statements
To remove your name from any special mailing list that we maintain, please contact us by telephone or mail. Please note: When you contact us to remove your name and address from our marketing mailing lists, we will use all reasonable efforts to do so in a timely fashion. If you are applying for a new product or service, we will process your request immediately. Otherwise, if you have an existing product or service with us, we will generally require a reasonable period of time, which may vary, depending upon the product or service, to process your request.