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Click here to download Canaccord's Privacy Policy (PDF
- 57KB) Privacy Protection In Canada
Overview
Our Privacy Principles
Questions, Concerns, Complaints
Privacy
Protection in Canada (top)
This privacy policy has been developed to meet the
compliance standards established by Canada's Personal
Information Protection and Electronic Documents Act (PIPEDA),
the CSA Model for the Protection of Personal Privacy and
the Province of British Columbia's Personal Information
Protection Act (PIPA). The Personal Information
Protection and Electronic Documents Act, formerly
referred to as Bill C-6 and the Personal Information
Protection Act Bill 38 are essentially about balance. On
one hand, they respect an individual's right to privacy
while on the other, they recognize the need for industry
and organizations to collect, use and disclose personal
information.
The Acts are based on the
Ten Principles established by the Canadian Standards
Association's Model Code for the Protection of Personal
Information. These principles address the ways in which
organizations should collect, use and disclose personal
information. They also address an individual's right to
access his/her personal information in addition to
his/her right to have it amended where appropriate.
In order to govern the commercial
information-handling practices within provincial
jurisdictions, each province has been encouraged to
enact legislation that is substantially similar to the
federal law. As the provinces enact similar legislation,
organizations conducting commercial activity within a
province will be subject to the provisions of their
provincial laws rather than the Federal Act. However,
the Personal Information Protection and Electronic
Documents Act will continue to regulate cross-border,
inter-provincial and international trade and commerce.
On January 1, 2004, most organizations, regardless of
their size, which collect, use or disclose personal
information in the course of commercial activity will
become subject to the provisions of this Act. For more
information regarding these legislations, please visit
the official web site of the Privacy Commissioner of
Canada at
http://www.privcom.gc.ca/ or the Office of the
Privacy Commissioner in your Province.
Overview (top)
At Canaccord Capital Corporation and its subsidiary
companies (hereafter "Canaccord"), an important part of
our commitment to provide you with service excellence is
our respect for your right to privacy. Since our
inception in 1950, we have been committed to keeping
your information safe and the business you do with us in
the strictest confidence. In any business, keeping
personal information private is important; in financial
services, it is critical. Our ongoing commitment to
respect and protect the privacy and confidentiality of
our clients' personal information, including that of
sole proprietors and individuals carrying on business in
a partnership, is addressed here in our Privacy
Statement. We want you to know, in plain terms, why we
ask for your personal information, how we use your
personal information in establishing and maintaining
your relationship with us, how we keep your personal
information confidential, and how you can inquire about
the personal information we hold about you.
Keeping our clients' information and affairs in
strict confidence is a cornerstone of Canaccord's
business. Canaccord offers our clients a broad range of
financial services including banking, insurance,
investment banking products and solutions, registered
plans, retail trading, and wealth management. This range
of products and services continues to expand, and the
technology we use continues to change. However, no
matter how our business changes, we will always protect
your privacy. Our policies and the procedures that we
practice in order to protect your privacy are in place
across Canaccord.
In the following pages, we describe these policies
and procedures and how we put them into practice so that
you have control over how we collect, use and disclose
your information.
Our Privacy Principles (top)
In relation to our Privacy Principles, "Canaccord"
means: Canaccord Capital Corporation, Canaccord Capital
(Europe) Ltd, Canaccord Capital Corporation (USA) Inc.,
Canaccord Financial Services, Ltd., the Immigrant
Investor program and Pinnacle Correspondent Services.
Canaccord has always been, and will continue to be
committed to maintaining the accuracy, confidentiality,
and security of your personal and financial information.
As part of this commitment, we have established Privacy
Principles to govern our actions as they relate to the
use of client information. Canaccord invites you to
review our principles, which have been built upon the
values set by the Canadian Standards Association's Model
Code for the Protection of Personal Information and
Canada's Personal Information Protection and Electronic
Documents Act.
Principle 1 - Accountability
Principle 2 - Identifying
Purposes
Principle 3 - Consent
Principle 4 - Limiting
Collection
Principle 5 - Limiting Use,
Disclosure and Retention
Principle 6 - Accuracy
Principle 7 - Safeguarding
Client Information
Principle 8 - Openness
Principle 9 - Client Access
Principle 10 - Handling Client
Complaints and Suggestions
Protecting your Privacy Means:
- We keep your information and the business you do
with us in strict confidence
- Your information is not sold
- You have control over how we obtain, use, and
give out information about you
- You have access to the information we have about
you
- We respect your privacy when we market our
products and services.
Principle 1 - Accountability (top)
We Monitor Our Compliance With the Canaccord
Privacy Policies
We have procedures in place to assist our employees in
the practice of the Canaccord privacy policies. Our
auditors will be monitoring the practice of these
policies on a regular basis and will report their
findings to a committee of the Board of Directors.
Principle 2 - Identifying Purposes (top)
Our Privacy Policies Protect All of Our Clients
When you first become a Canaccord client and whenever
you apply for more products and services, we let you
know that, in addition to your name, address and
telephone number we need information to:
- Establish your identification
- Protect you and us from error and fraud
- Understand your needs and eligibility for
products and services
- Recommend particular products and services to
meet your needs
- Provide ongoing service
- Comply with legal and regulatory requirements
Information that is essential for fulfilling most
financial requests and account applications typically
includes your name, a physical and mailing address,
phone number(s), financial information, bank name,
social insurance number and email address. We may
verify some of the information you give us with your
employer or your bank reference. We may offer other
products that we believe are suitable to you.
When opening an interest bearing or investment
account, there are various regulatory requirements. The
Income Tax Act and Securities regulations require us to
ask for your social insurance number and birth date. The
Tax Treaty signed with the US requires a citizenship
declaration and social security number (if applicable).
The federal Proceeds of Crime (Money Laundering) and
Terrorist Financing Act (Bill C17) mandates the need to
verify our clients by way of referring to a person's
driver's licence, provincial health insurance card (if
such use of the card is not prohibited by the applicable
provincial law), passport or any similar record, or by
way of an account held at a recognized Canadian bank.
Provision of certain information, such as a driver's
license, although necessary for federally mandated
identification requirements, is voluntary. Which form
of suitable identification you wish to provide is up to
you. A detailed list of "suitable" identification is
available upon request.
We use your personal and financial information to
communicate with you, process applications and
effectively provide the services you have requested. The
better we know you, the better we can help you achieve
your financial goals. By sharing information with us
about you, we can begin identifying your financial
service requirements ¡V for now and for the future. When
you become a Canaccord client, we make every effort to
establish and maintain a positive relationship with you.
To help us do this, we use the personal information you
have provided to us to communicate with you and to
safeguard your interests.
In the course of daily operations, access to private,
sensitive and confidential information is restricted to
authorized employees who have a legitimate business
purpose and reason for accessing it. For example, when
you call us, visit a branch, or email us, our designated
employees will access your information to verify that
you are our client and to assist you in fulfilling your
requests. The majority of information we retain about
you is in the form of transaction records that reflect
your business dealings with us. We are required by law
to update and maintain this information on an ongoing
basis and we will communicate this information back to
you in the form of regular statements or through trade
confirmations. If you have Internet access, this same
account information reflecting your financial
transactions may also be viewed online. We will keep
you informed about your account activities, authenticate
your identity, send you important notices, and respond
to any special needs or enquiries you may have. With
your consent, we may also send you information about
other products and services in which we believe you
would be interested. We also collect and analyze
information from other sources for the same purposes.
In other words, we collect, use and disclose personal
information only for purposes that a reasonable person
would consider appropriate in the circumstances.
Principle
3 - Consent (top)
Your Information is Obtained or Used Only With
Your Consent
We obtain your consent before we:
- Obtain a credit report
- Offer you other products and services
- Send you information about products and services
by means of direct marketing. This does not include
information on or enclosed with your written or
electronic month end statements, posted at branch
locations or on our web site, or conveyed to you in
person by our employees.
- Share your information in confidence within the
Canaccord group, provided it is legally permitted
- Obtain, use or disclose to other persons,
information about you unless we are obliged to do so
by law or to protect our interests
- Use your information in any way we did not tell
you about previously
We Ask For Your Consent Before Using Your Social
Insurance Number (SIN)
While the law requires us to ask for your SIN when you
open an account that trades or earns income, we need to
get your consent to use it in any other way. If you
choose not to give us your SIN, this by itself will not
prevent you from getting credit or any other service.
Your Consent Can Be Express or Implied
Express consent can be verbal or written. For example,
when you sign an account opening application you are
giving your written consent for us to obtain a credit
report. You imply consent when we can reasonably
conclude that you have given consent by some action you
have taken, or when you decide not to take action. For
example, if we give you an opportunity to tell us you do
not want direct marketing material and you do not tell
us that you do not want us to send it, we can conclude
that you have no objection. We rely on your consent to
use and disclose identifying information about you, such
as your name and address.
You Can Withdraw Your Consent After You Have Given
It
You can withdraw your consent any time after you've
given it to us, by sending us a written request to do
so, provided there are no legal requirements to prevent
this. We do reserve the right to respond to your
instructions within 30 business days. However, in order
to maintain the integrity of the credit reporting
system, we do have to update your credit information
with the credit bureau as long as you have an account
with us. Your consent for this purpose cannot be
withdrawn during this time. If you do not consent to
certain uses of information, or if you withdraw your
consent, we may not be able to provide you with a
particular product or service. If so, we will explain
the situation to you to help you with your decision.
Principle 4 - Limiting Collection (top)
Anonymous/Non-Personal Information
At Canaccord, we routinely collect
anonymous/non-personal information.
Anonymous/non-personal information is information that
cannot be associated with or traced back to a specific
individual or business entity. For example, our web
servers collect some anonymous/non-personal information
automatically when you visit Canaccord web sites.
Gathered electronically, this information may include
the pages you visited, the type of web browser you are
using, the level of encryption your browser supports and
your Internet Protocol address. The
anonymous/non-personal information collected is used for
research and analytical purposes. For example, we are
able to determine how many times our online privacy
policy has been visited but we do not know any specific
information about those visitors.
To help us better understand our markets, we may also
gather information for analytical purposes by conducting
anonymous client surveys, or by extracting demographic
information from existing files and from Statistics
Canada.
Principle 5 - Limiting Use, Disclosure and
Retention (top)
We Ask For Your Consent Before Sharing Information
With Other People
We do not share information about you within the
Canaccord group or release it to anyone outside of the
Canaccord group without your consent. For example, we
give information to a credit bureau only with your
consent. There are some exceptions to the above rules.
For example, we may collect, use or disclose information
without your consent if we:
- Use an outside company to process information
At times we may use the expertise of an outside
company to do work for us involving some of your
information - for example, the printing of month end
statements or the processing of a mutual fund
transaction. When we contract our suppliers to
provide specialized services, they are given only
the information necessary to perform those
services. Additionally, they are prohibited from
storing, analyzing or using that information for
purposes other than to carry out the service they
have been contracted to provide. We select the
company carefully and confirm that it uses security
standards comparable to those of Canaccord.
- Must disclose information for legal reasons
We may be compelled to release certain information
to a court of law or other legal or regulatory
authority. If so, our policy is to release only the
information specifically requested and we take
precautions to satisfy ourselves that the
authorities who are making the request have
legitimate grounds to do so.
- Have to protect the interests of Canaccord
In certain circumstances, Canaccord may have to
collect, use or release information for its
protection. For example, we may do so when
collecting an overdue account, when realizing on
security pledged for a margin account, or to detect
or prevent fraud.
Principle 6 - Accuracy (top)
We Correct Your Information
Whenever possible, we will correct any information which
we may have given to an outside organization.
If a third party, such as a credit bureau, has given
us information which you tell us is wrong, we will give
you the name and address of that party so that you can
correct the information.
Principle 7 - Safeguarding Client Information (top)
We Protect Your Information From Error, Loss and
Unauthorized Access
Each and every one of our employees is responsible for
maintaining the confidentiality of all personal
information to which they have access. As a condition
of employment, our employees are required to sign a
confidentiality agreement binding them to this
responsibility and governing their actions, even if they
leave or retire from Canaccord. We keep our employees
informed about our policies and procedures for
protecting personal information and reinforce the
importance of complying with them. All employees are
also required as a condition of employment to conform to
these policies and procedures.
Canaccord has a designated Privacy Officer who
oversees privacy governance including policy, dispute
resolution, education, and communications. Findings are
reported to our Board of Directors and Senior
Management. The Privacy Officer can be contacted at
Canaccord Capital Corporation, P.O. Box 10337 Pacific
Centre, 609 Granville Street, Vancouver, BC V7Y 1H2.
Electronic client files are kept in a highly secured
environment with restricted access. Paper-based files
are stored in locked fire-resistant filing cabinets.
Access is also highly restricted. Our computer security
specialists build security into all our computer
systems. Through these and other measures, we
endeavour to protect your information at all times;
whether it is stored in data files or handled by our
employees. Our systems also protect your information
when it is transmitted, for example, between our data
processing centres and a Canaccord branch. We manage
our server environment appropriately, and our firewall
infrastructure is strictly adhered to. Our security
practices are reviewed on a regular basis and we
routinely employ current technologies to ensure that the
confidentiality and privacy of your information is not
compromised.
Canaccord web sites use Secure Socket Layer (SSL) and
128 bit encryption technologies to enhance security when
you visit the secured areas of these sites. SSL is the
industry standard tool for protecting and maintaining
the security of message transmissions over the
Internet. When you access your accounts or send
information from secured sites, encryption will scramble
your data into an unreadable format to inhibit
unauthorized access by others.
To safeguard against unauthorized access to your
accounts, you are required to "sign-on" using an
encrypted password to certain secured areas of Canaccord
web sites. If you are unable to provide the correct
password, you will not be able to access these
sections. Your password information is encrypted which
is presently the most effective way to secure data. To
protect your Online Account Information, the systems are
designed to automatically terminate if extended
inactivity is detected. If your session is terminated,
you will be required to sign-on again to continue.
A cookie is a small text file containing a unique
identification number that a web site sends to your
computer's web browser. While you visit a particular
site, a cookie may be used to track the activities of
your browser as well as provide you with a consistent,
more efficient experience. Cookies may be used by
Canaccord web sites to improve functionality and in some
cases, to provide visitors with a customized online
experience.
The following section describes how cookies may be
used by Canaccord web sites:
- To Improve Functionality
Canaccord web sites may use non-persistent cookies
to improve operations and functionality. For
example, these cookies improve navigation, maintain
connectivity and ensure online service sessions are
secured. They do not contain personal or financial
information and they are not permanently stored for
future use.
- Site Personalization
Some Canaccord web sites use persistent cookies as a
means of offering visitors a personalized
experience. For example, Canaccord Capital
Corporation uses cookies to allow visitors to create
and save stock portfolios that may be retrieved
during future visits. On Canaccord web sites,
cookies are used to increase the robustness of these
sites and to provide more efficient navigation.
These cookies are intended to enhance navigation and
the security of your session. Our cookies may view
or retrieve data from other cookies; they may also
capture files and data stored on your computer to
provide us with information regarding the
effectiveness of our web site and the information
provided through it. Canaccord does not associate
any of the information collected via cookies with
your financial information.
How You Can Protect Your Information
At Canaccord, we do our utmost to protect and safeguard
your personal and financial information. We believe
there are measures you should take as well. The
following is a list of things you can do to protect
yourself against fraud and uninvited intrusion.
- Passwords - Passwords are necessary to
identify you and authenticate your permission to
access your accounts. When you enrol in online
services such as "CC Access" the passwords you use
are encrypted. Encryption is presently the most
effective way to achieve data security. Just as it
is important for us to employ strict procedures to
safeguard your information, you also should take
precautions in handling your passwords. When
selecting a password, we suggest that you use a
combination of letters and numbers and do not use
words that can be easily associated with you such as
the name of a family member, a pet or the street on
which you live. We also suggest that you change
your password regularly.
- Personal Information - You should not
share personal or financial information such as your
personal identification number, social insurance
number or credit card number with others unless you
clearly understand the purpose of their request and
you know with whom you are dealing.
- Online Security - To make sure your
connection to the proFtected areas of Canaccord web
sites is secured look for either a 'closed lock' or
an 'unbroken key' icon located at the bottom right
hand side of your browser's task bar. You may also
check the Address bar to determine if SSL (Secure
Socket Layer) is active by looking at the beginning
of the address. If it starts with "https" rather
than the standard "http", then SSL is operating.
- Suspicious Solicitation - From time to
time, Canaccord will engage in promotional campaigns
via telephone, mail and email. If you are unsure of
the information you receive from us, please call us
at 1-800-663-1899 (Canada) or 1-800-663-8061 (USA)
to verify that the campaign is a legitimate
Canaccord activity.
Your Information Is Destroyed When It Is No Longer
Needed
We keep your information only as long as we need it for
the products and services you are using, to offer you
products and services when you are a client and for a
reasonable time thereafter, or to meet any legal
requirements. We have industry regulated retention
standards, which we must also meet. We destroy your
information when it is no longer needed, or we remove
your name from the information.
We Protect Other People's Privacy When We Make
Information Available to You
There may be files that include information about you
and other clients or that have information confidential
to Canaccord or are the property of Canaccord. As we
must protect everyone's confidentiality and legal
rights, we cannot make these files available to persons
outside of the Canaccord group. However, we will make
available to you any factual information about you
contained in such files.
Principle 8 - Openness (top)
You Can Find Out to Whom We Have Given Information
About You
If you ask, we will let you know the names of outside
companies or organizations we have given information to,
unless otherwise prohibited by law. This will not
include information given to outside companies we have
used to do work for us, such as statement printers. It
will not include T5 reports to the Canada Customs and
Revenue Agency or regular updates of credit information
to the credit bureau.
Principle 9 - Client Access (top)
You Can See and Verify the Accuracy of Your
Information
It is important that your personal and financial
information is accurate and complete as decisions are
often made based on it. As a client, you can check the
information held in your personal and financial files to
verify, update and correct it, and to have any obsolete
information removed. We encourage you to amend
inaccuracies and make corrections as often as necessary.
Despite our best efforts, errors sometimes do occur.
Should you identify any incorrect or out-of-date
information in your file(s), we will make the proper
changes and provide you with a copy of the corrected
information. Where appropriate, we will communicate
these changes to other parties who may have
unintentionally received incorrect information from us.
Most of this information is available in the form of
transaction records. Account statements and trade
confirmation slips are generally the best source for
this type of information. If you are a subscriber to "CC
Access", you can also obtain much of your account
information through that avenue. Additional
transactional details about your accounts may be
acquired through your branch. There is no charge for
verifying or correcting your information. We ask you to
put your request in writing. There may be a charge if
you want a duplicate copy of records that we have
already given you - for example, a historical month end
statement or trade confirmation. We will let you know
in advance if there is a charge. You can check much of
your information routinely - for example, by keeping
track of the buy and sell orders you place or by
carefully examining your account statements.
If we have obtained information about you from other
people, upon your request, we will let you know the
person we received it from. In some cases we may be
prohibited from sending certain information directly to
you.
Principle 10
- Handling Client Complaints and Suggestions (top)
We Respond to Your Request Promptly
We will deal quickly with your request to see your
information, and always respond to you within 30 days.
If we need to extend the time, or we have to refuse your
request, we will tell you why, subject to any legal
restrictions, and we will notify you of the new
deadline, the reasons for the extension, and your rights
under applicable legislation respecting the extension.
We Are Committed to Upholding the Canaccord
Privacy Policies
If you have any questions or complaints about our
privacy policies or about how we are living up to them,
let us know right away. Resolving your concerns is
important to us; Canaccord is committed to treating you
with the greatest respect and consideration, and
providing the highest level of service. Even so, from
time to time, something may go wrong. There may be a
misunderstanding or you may feel you have been dealt
with unjustly. Whatever the circumstances, resolving
the problem for you is our primary concern.
Questions,
Concerns, Complaints (top)
How to Resolve Concerns and Complaints at
Canaccord
Talk to us! In most cases, simply telling us about
it and discussing it with us resolves a complaint.
If a problem is not resolved to your satisfaction,
you can contact our Privacy Officer, Dianne R. Jackson
via email at
privacy@canaccord.com or in writing to Canaccord
Capital Corporation, P.O. Box 10337 Pacific Centre, 2200
- 609 Granville Street, Vancouver B.C. V7Y 1H2
If after following the procedures your concerns have
not been resolved to your satisfaction, feel free to
contact your Provincial Privacy Commissioner directly by
telephone or in writing. For example in British
Columbia you may call the Office of the Provincial
Ombudsman at: 1-800-308-6859, or in Victoria at (250)
861-3313. Fax the Office of the Provincial Ombudsman
at: 1-800-308-6861, or in Victoria at (250) 980-3754.
Email inquiries to
http://www.OIPC@gems5.gov.bc.ca/ or write to:
Information and Privacy Commissioner for British
Columbia, P.O. Box 9038, Stn. Prov. Govt., Victoria, BC
V8W 9A4
The Provincial Ombudsman's office will acknowledge
your complaint; then, providing legal action has not
been taken on the matter, the Provincial Ombudsman
immediately goes to work. In most cases, you will
receive a response within five working days. Should you
not be able to accept the conclusion of the Provincial
Ombudsman, you may contact the Ombudsman for Banking
Services and Investments for a further independent
review. Email inquiries to
http://www.obsi.ca/ or write to Ombudsman for
Banking Services and Investments, P.O. Box 896, Station
Adelaide, Toronto, ON, M5C 2K3. Call: 1-888-451-4519
(in Toronto (416) 287-2877) Or Fax: 1-888-422-2865 (in
Toronto (416) 225-4722)
If the above steps fail to resolve your concern to
your satisfaction, you may contact the Privacy
Commissioner of Canada by writing to: The Privacy
Commissioner of Canada, Place de Ville Tower B, 3rd
Floor, 112 Kent Street, Ottawa, ON, K1A 1H3 or call:
1-800-282-1376 or fax: (613) 947-6850
Last updated: 17/08/2005 |
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