Privacy Policy and Principles
In delivering our investment management services, we collect, use and disclose certain personal information about you. This policy explains what personal information we collect, the purposes for which we collect it, how we protect it, and how you can access it. This policy applies to your account(s) with North Road Investment Counsel Inc (North Road) and your usage of the North Road website, and is in addition to the client or other agreements governing your account(s).
What is personal information?
Personal information is any information that identifies you as an individual, such as your name, address, identification documents, account numbers, age, marital status, employment details and financial information. Personal information does not include contact information used for business purposes. It also does not include information about legal entities, such as corporations or trusts, apart from certain information about individuals associated with legal entities.
What personal information do we collect and use?
The primary purpose for our collection and use of your personal information is to deliver the services you request from us and that are suited to your needs. For this reason, we request information about your financial situation and needs and ask you to update this from time to time. However, we sometimes need your personal information for additional purposes, including:
To verify your identity – We need to request information about you, including your name, date of birth, occupation, and government-issued identification to authenticate you and meet regulatory obligations including anti-money laundering laws.
To determine your eligibility for the services you request – Delivery of our investment management services requires us to have in-depth knowledge about your financial situation, your investment needs and goals.
To determine what additional services we may offer that may assist you – Our staff is trained to meet your financial goals. To this end, we may use your personal information to assess and inform you of additional services that we think may be of interest to you. At any time, you may advise us that you are not interested in additional services and we will honour this request.
To facilitate your relationship with third parties – We work with third parties, such as custodians, to deliver our services to you. From time to time we will request information from you that is needed by these third parties to establish and maintain your accounts with them. Such information may include your social insurance number, which is required for tax reporting purposes.
To comply with securities law requirements – Securities laws require us to collect information about your investment knowledge and experience, investment horizon, risk tolerance, and ownership/involvement with public companies.
To monitor the adequacy and effectiveness of our website – Our website may collect the internet protocol (IP) address of incoming visitors and may use various tracking tools, such as cookies, pixel tags and web beacons. This helps us capture user activity to understand use and effectiveness of our website, enhance user experience, and provide additional security controls. Your browser may give you the options to disable these tracking tools. However, certain features of our website may not work if you disable them.
We only collect and use your personal information for the above purposes. We will not collect your personal information for an additional purpose without first obtaining your consent. We may collect your personal information from other persons, but only with your express consent, or as authorized by law.
When do we disclose your personal information?
We will generally only disclose your personal information to third parties to provide you with our investment and wealth management services. We only disclose your personal information to third parties with your consent, or where required or permitted by law. The following are situations where we would choose or be required to disclose your personal information:
To act on your instructions – With your consent, we may disclose your personal information to your agents (for example, your accountant of attorney) or your legally appointed representatives (for example, an attorney under an enacted power of attorney or the individual you may designate as your ‘trusted contact person’).
To enable our service providers to help serve you better – To deliver our services, we contract with third party service providers (for example, software vendors). We only use reputable third-party service providers and never allow these service providers to use the personal information we share for any reason other than delivering their services to us. While in certain cases a service provider may utilize servers outside of Canada where, under applicable laws, personal information could be accessible to a foreign government, we endeavor wherever possible to use providers that house data in Canadian-domiciled servers under Canadian laws. If you have questions on non-Canadian providers, we are happy to provide timely and specific information.
Where required or permitted by law – Privacy law allows for certain disclosures of personal information without consent. We are required to disclose your personal information to government agencies and law enforcement where we are legally compelled to do so by court order, warrant, or other legislative or regulatory authority. Privacy law also allows us to disclose personal information without consent where it is reasonably necessary to collect debts owed to us, to combat money laundering or fraud, to protect vulnerable individuals, or in an emergency where someone’s health or life is at risk.
Protection of Personal Information
North Road is committed to protecting your privacy. Below are some of the ways we keep this commitment:
We have appointed a Privacy Officer to oversee our privacy program, including developing robust administrative, technical, and physical safeguards.
We store personal information in locations designed to prevent the loss, misuse, unauthorized access, disclosure, alteration, or destruction of that information.
We delete personal information when it is no longer required for the purposes for which we collect it. Please note that regulatory requirements may necessitate keeping account information for a period of time after an account is closed.
We regularly train our staff on privacy requirements and best practices, including only accessing personal information on a need-to-know basis.
We monitor the privacy controls of our material third-party services providers and partners, such as our chosen custodians.
Consent and Accessing Your Information
Consent - By opening an account with us, or using the North Road website, you are indicating your consent to the collection, use and disclosure of your personal information in the manner described above.
Revoking Consent - You may revoke or withdraw your consent to our collection, use or disclosure of your personal information by contacting us in the manner described below. If you wish to revoke or withdraw your consent, we may be unable to provide you with some services, offers or information that may be of value or interest to you. We will be happy to explain any consequences of revoking or withdrawing your consent, and the options available to you.
Accessing Your Information - We make business decisions based on the information we have about you. Therefore, it is important that the information we have about you is accurate. You can access and update your personal information by contacting our Privacy Officer in the manner described below.
Amendments
We may make minor changes to this policy from time to time so we invite you to revisit our current policy by visiting our website at www.northroadic.com. Where we make a substantial change to this policy, such as collecting, using or disclosing your personal information for a new purpose, we will make every attempt to inform you of the change.
Questions, Inquiries or Complaints
If you have any questions or concerns about this Privacy Policy, our privacy practices, or if you would like to review your personal information, please contact our Privacy Officer at:
Privacy Officer
Suite 402, 11523 - 100 Avenue NW
Edmonton, AB T5R 4J8
Phone: 780-638-2490
Email: compliance@northroadic.com
You may also seek advice and direction on any privacy related matter from the Office of the Privacy Commissioner of Canada, the Office of the Information and Privacy Commissioner of Alberta, or another provincial Privacy Commissioner having jurisdiction. However, we encourage you to first give us the opportunity to address any concern by contacting our Privacy Officer.