We need to collect personal information from you and prospective clients in order to properly fulfill our responsibilities to clients like you. Understanding your needs and wants, financial position and family circumstances ensures that all of our investment recommendations are suitable for you. This is both a good business practice and a regulatory requirement. We are required to collect personal information in order to meet our obligations under securities laws and anti-money laundering regulations. We are committed to protecting your privacy and the confidentiality of your personal information in our possession. This policy explains the measures we take to fulfill these commitments.
We ask you for no more personal information than necessary.
The “Know Your Client” information we collect from you includes only the information we need to fulfill our contractual, regulatory and income tax obligations. The information we request will include
- Information to establish your identity (e.g. name, address, date of birth, citizenship etc.);
Information required to establish your financial situation (e.g. income, investments, debts, marital status, dependents etc.) and your personal background; and
Information required to comply with our tax reporting obligations (e.g. your social insurance number)
Our application forms for registered retirement accounts elicit only the information needed to register these accounts with the government.
We will confirm with you that the personal information we have about you is accurate from time to time. Most of the information will be collected from you directly. We may however, collect additional information from other sources, including, without limitation, credit reporting agencies, other investment dealers or other financial institutions. We do not disclose any non-public personal information to any third party except as required by law or as outlined in this policy.
We do not sell, trade or rent our clients’ personal information.
We limit access to your personal information.
We record clients’ personal information electronically on computer servers to which only authorized persons have access, and only by means of secure passwords. We authorize employees to have access to clients’ personal information only on a “need to know” basis. We have installed hardware and software security to keep our servers clean and secure. We maintain a duplicate copy of our data at an offsite location for disaster recovery purposes. This data is password protected. If we retain paper copies of clients’ personal information, we store it in locked filing cabinets. We keep the computers and filing cabinets in which such information is stored in areas of our business premises locked when not in use.
We retain your information for no longer than necessary for the purposes set out in this policy or to meet our legal and regulatory requirements.
We prevent unauthorized disclosure of your personal information.
We train our employees to keep clients’ personal information strictly private and confidential. We require all of our staff to certify that they will follow our policies and procedures which obliges them to respect and protect clients’ personal information. We ensure that departing staff understand they remain contractually obliged to respect the privacy of clients’ personal information. We shred paper documents containing clients’ personal information before discarding such documents.
Your online access to certain of your personal information is protected with a password that you select. We strongly recommend that you do not disclose your password to anyone.
We expect similar safeguards from our service providers.
When you open an account with us, you will open an account and sign an account agreement with a custodian. The custodian provides safekeeping of your securities as well as trade execution, clearing and other services. We will share personal information with our custodians. The information we share will ensure that we can provide you with the services and information that you expect from us and that we are required to provide under applicable regulations.
You can review what personal information we have about you
You may obtain access to the personal information we hold about you at any time and review its content and accuracy and have it amended as appropriate. We may have to restrict the information we provide as required by law. To request access, you should send a written request to your advisor or to the Chief Compliance Officer of Harness Investment Management.
We take privacy seriously.