At Raymond James Investment Counsel Ltd., (“Raymond James”) we recognize how important personal privacy is to you. To provide the highest possible level of protection to you, we maintain standards designed to protect your privacy and prevent any misuse of your personal information. We have adopted the following principles and procedures which outline how we gather, protect and use personal information, and how we will hold ourselves accessible and accountable to you.
"Personal information" is any information that identifies you as an individual and includes information with respect to your name, address, age, gender, income, marital status, finances, employment, trading history and website use information, together with your personal references and identification numbers (such as a social insurance number).
Collecting and retaining personal information about you is essential to our ability to adhere to the "Know Your Client" rule. That rule is fundamental to the investment industry. It means that your Portfolio Manager must know the relevant information about your personal finances, employment status, investment knowledge and objectives, risk tolerance, age, and family situation to assess the suitability of your investment portfolio.
We also use personal information 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 is required by law or Canadian securities regulatory bodies. 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 also share your personal information where not prohibited by law, within the Raymond James group of companies, for the purposes of referring life insurance, disability insurance, annuities and other specific insurance products and services to you.
We limit the collection of your personal information and its disclosure to third parties to what is necessary to offer you the services requested or for the other reasons for which you have provided consent (such as receiving information on other products or services).
We collect most of our information directly from you, primarily through our account opening forms which you complete with your Portfolio Manager. With your consent, we may also obtain personal information about you from third parties such as lenders or credit reporting agencies to give us information on your credit history. We may also contact employers or other personal references to verify information provided by you.
It is always your choice whether or not to provide your personal information or to consent to our obtaining personal information about you from third parties. You may refuse or withdraw your consent at any time. However, if you choose not to provide requested personal information or consents, we may not be able to provide certain or any products or services to you. For example, we cannot open an investment account without certain personal information as we would be in breach of our legal and regulatory obligations. If you choose to withdraw your consent to us using certain personal information, we might have to close your investment accounts. To clarify any questions you may have about providing personal information, please feel free to contact your Portfolio Manager or the Raymond James Privacy Officer at the contacts set out below. We will be pleased to explain your options and any consequences of refusing or withdrawing your consent.
We recognize that many clients may have some privacy concerns regarding our services on the Internet. We share your concerns and are committed to protecting the misuse of client information on the web.
Our website may contain links to other websites. Always remember that when you click on one of those links, you are contacting another website for which Raymond James has no responsibility or control.
Raymond James will not sell, trade or lend your personal information to any third parties unless we have your express permission to do so.
However, there are times when disclosure of your personal information is necessary. In certain circumstances, disclosing information to a third party may be required to help complete a transaction initiated by you or the disclosure is otherwise lawfully permitted or required. For instance, we may disclose information to legal authorities to protect against fraud, money laundering or other criminal activity. We may also, from time to time, be requested to disclose information to securities regulators to which we are subject to for the purposes of an audit or investigation relating to specific accounts or our business generally.
Sometimes it is necessary to provide personal information about you to a party outside our affiliated companies, such as to a vendor or service company that we hire to do our data processing or prepare your account statements or to provide support or services for one or more of our products. We will seek agreement from these vendors and service companies to safeguard confidential information about you and your products and services with us.
Some of our vendors and service companies mentioned above may be located or may have servers outside of Canada. If a service provider or its systems server is located in a foreign jurisdiction, it is bound by the laws of that jurisdiction and may disclose your personal information under those laws.
There are several ways we strive to protect your personal information:
We maintain security standards and procedures to help prevent unauthorized access to confidential information about you. Our security standards and procedures are updated and tested regularly to improve the protection of our information about you and to assure the integrity of our personal information.
We have procedures that limit employee access to personally identifiable information to those employees with a business need to know such information about you. We educate our employees about the importance of confidentiality and customer privacy through standard operating procedures and training programs. We take appropriate measures to enforce employee privacy responsibilities.
Our technological systems are monitored 24 hours a day, 365 days a year, for signs of tampering or unauthorized activity. We employ the use of encryption, virtual private networks, penetration/vulnerability testing, and the latest firewall and antivirus technology. Email monitoring is also utilized for regulatory and compliance purposes in order to protect our clients. We also maintain strict controls to limit and monitor employee access to our systems.
Our information technology professionals constantly research and develop enhancements to keep us at the vanguard of data security. A team of independent auditors reviews our technological systems quarterly.
Our suppliers and agents, as part of their contracts with Raymond James, are bound to maintain your confidentiality and may not use the information for any unauthorized purpose. When we provide information in response to a legal or regulatory inquiry or order, we ensure that the order is valid and we disclose only the information that is required otherwise we will seek your consent prior to disclosing any information.
We retain your personal information only as long as it is required for the reasons it was collected or as required by law or regulation. 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 required by regulation or necessary for us to respond to issues that may arise at a later date. When your personal information is no longer needed for the purposes explained to you, we have procedures to destroy, delete, erase or convert it to an anonymous form.
You may request access to your personal information on record with Raymond James Investment Counsel Ltd. and information about the use and disclosure of that information by contacting the Raymond James Privacy Officer as follows:
Tel: 416 777-6438 Fax: 604 654-7238 Email: [email protected] Address: Suite 2100-925 West Georgia Street, Vancouver, BC V6C 3L2
We will ask you for specific details such as the name of your Portfolio Manager and your account number and we will respond to your request promptly. Please note that we may not be able to provide information about you from our records if it contains references to other persons, is subject to legal privilege, contains information proprietary to Raymond James, or cannot be disclosed for other legal reasons. Also, we do not maintain disclosure records for regular or routine actions.
Raymond James attempts to keep its records as accurate and complete as possible. You can help us maintain the accuracy of your information by notifying us of any changes to your personal information. If you find any errors in our information about you, let us know and we will make the corrections immediately 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.
If you have any questions about privacy and confidentiality - or any concerns about the way a request for personal information was handled, please contact the Raymond James Privacy Officer directly at the contacts listed above.