Privacy

10 privacy principles

Principle 1: Our responsibility to the customer

We are responsible for all personal information under our control, including any information transferred to a third party for processing, storage or other purposes. Accordingly, we are required to protect the confidentiality of the personal information to which we have access. We have strict policies and procedures to protect this information and have designated individuals who are accountable for compliance with these policies and procedures. All of our employees have adhered, as a condition of employment, to ethical principles, a fundamental principle of which is to maintain the confidentiality, security and privacy of each client’s file at all times. Also, on an ongoing basis, we ensure that our staff receives adequate and relevant training and is regularly informed of changes to our company’s procedures for managing and protecting your personal information.

Principle 2: Identifying Purposes

When you deal with one of our advisors (life and health insurance) or one of our broker representatives (group savings), they ask you for personal information for various purposes:

• To verify your identity and prevent fraud;
• To ensure that we understand your financial services needs;
• To check if a product or service is right for you;
• To establish your eligibility for products or services in order to offer them to you;
• To register for and administer any product or service you have requested;
• And finally, to meet legislative or regulatory requirements.

Principle 3: Your consent

When you open a group savings account or sign an application for life and health insurance, by signing the appropriate documents, you certify that you consent to the collection, use and disclosure of personal information.

You have the right to refuse the collection, use and disclosure of your personal information, if you so choose. You may also withdraw your consent at any time thereafter, subject to legal or contractual restrictions and reasonable notice. In many cases, the collection, use and disclosure of personal information is necessary for the proper management or administration of your records or the provision of ongoing services related to your file. In these circumstances, you should be aware that we may be forced to close your file or discontinue providing you with a product or service.

You may terminate your consent at any time if:

• you provide reasonable written notice to that effect;
• we are not legally required to obtain, use or disclose personal information;
• this does not prevent us from performing our contract with you;

Principle 4: Limiting Collection of Your Personal Information

We collect only the information we need to process your case. We may ask you for the following information:

• Social Insurance Number (SIN) – For income tax reporting and other government purposes, including opening an income producing account and registered retirement income investment, to meet Canada Revenue Agency requirements. We may use your SIN for administrative purposes, including matching your personal information, or as an internal identification number to distinguish you from customers with similar names.
• Financial information – To ensure that the advice we provide and the investments you purchase are right for you so that we can get to know you.
• Health Information – To determine your eligibility for certain insurance products. In some cases, you may choose not to give us certain information. However, in such a case, we may not be able to provide you with the product, service or information you request where we are required to obtain such information by applicable regulations.

Principle 5: Limiting Use, Disclosure and Retention

Your personal information shall not be used or disclosed for purposes other than those for which it was collected, except with your consent or as required by law. We shall retain personal information only as long as necessary for the fulfillment of those purposes. Personal information is destroyed in a secure manner to respect the privacy of the information.

Under no circumstances do we sell or give lists of our customers to other companies for their own use.

In order to properly carry out the mandate entrusted to us, we may transfer to third parties the personal information obtained about you, in particular in the following cases

• We have obtained your consent to do so;
• We share your personal information with any other organization with whom we have a business relationship in order to respect and fulfill your requests;
• A securities regulatory authority or other regulatory body has required it;
• We are required or permitted by law to do so.

We maintain records containing your personal information only as long as it is required for our business relationship, in accordance with our internal record retention policies or legal and regulatory standards. These records will be retained by your advisor or mutual fund dealer representative with whom you normally do business, by PPTA’s Compliance Department or by our service providers.

Strict procedures for the retention of your personal information are followed and we will dispose of personal information that is no longer required for the identified purposes.

We may disclose personal information to legal or regulatory authorities where we suspect money laundering, insider trading, manipulative or deceptive business practices or other criminal activity, to detect and prevent fraud, or to comply with legal or regulatory requirements of governmental authorities, regulatory bodies or other self-regulatory organizations. We may also need to disclose personal information to comply with a legal obligation (e.g., court order) or to protect our assets (e.g., to collect overdue accounts). When we need to disclose personal information for these reasons, we keep a record of what information has been disclosed, when, to whom and why.

Principle 6: The accuracy of your information

We are committed to maintaining the accuracy of personal information and ensuring that it is complete and up-to-date. We try to take all reasonable steps to maintain its accuracy. If you become aware of any errors in our data or if your information changes, you should immediately notify your advisor or PPTA so that we can make the necessary changes. We will make the necessary changes to your file if you determine that your personal information is incomplete, inaccurate or ambiguous.

We will do our best to inform those to whom we have provided information of these changes as soon as possible.

If we do not agree to make the changes you request, you may dispute our decision. Please see Principle 10 below for information on how to make a complaint.

To access your personal information, to correct personal information, to make an inquiry or to make a complaint, please contact us in writing by sending your request to the address indicated in Principle 10.

Principle 7: Our priority: the security of your personal information

We maintain strict security measures to protect your personal information from unauthorized access, regardless of the format in which we hold it. We strive to adapt our security measures to technological advances.

Protection methods include:

• Physical security measures, such as controlled access offices and locked filing cabinets;
• electronic and technical security measures for computerized personal information, such as the use of passwords, database encryption and personal identification numbers;
• organizational processes such as restricting access to your personal information to a select group of individuals;
• contractual obligations with third parties who need access to your personal information, requiring them to protect the confidentiality and security of your personal information.

We have established a comprehensive set of security controls to protect personal information from unauthorized use, access, modification, copying, destruction and disclosure, and from loss or theft.

On our websites, cookies or other information tracking mechanisms may be used to enhance the functionality or security of the sites or to provide the user with a more personalized experience. Please note that cookies cannot, under any circumstances, access your computer’s files or data.

Principle 8: transparency

We shall make information available to you about our policies and practices relating to the management of your personal information.

From time to time, we may make changes to our privacy practices or to the measures we have in place to protect the security of your personal information. We will notify you of any such changes as required by law.

We invite you to read our “Statement on Internet Tools” found on this site.

Principle 9: You have access to your personal information

You may have access to your file if you make a written request to the Privacy Officer at PPTA’s head office. This right of access and modification includes, but is not limited to:

• The right to consult your file free of charge;
• The right to obtain a copy of your file for a reasonable fee;
• The right to have incomplete, inaccurate or misleading information corrected.

If you want to review or verify any personal information or find out to whom we have disclosed it, you may ask us. We may ask you for specific information to enable us to search for and provide you with that information. Depending on the nature of your request, you may also be required to pay a small reproduction or search fee, but we will advise you of this first. In some cases, we may not be able to provide you with certain information we hold about you in accordance with applicable legislation. In such cases, we will inform you of the reasons why we are unable to provide you with access to that particular information.