National Bank Financial Wealth Management (NBFWM) is committed to protecting its clients' personal information. This policy sets out our practices for collecting, using and disclosing personal information pertaining to our clients, as well as the measures taken to ensure that such information is properly handled.
Our policies and practices comply with Canada's Personal Information Protection and Electronic Documents Act and all other applicable provincial standards and legislation.
"Personal information" means any information identifying you, including your name, address, telephone number, email, fax number or other contact information, financial information concerning you and your spouse, information concerning your occupation or that of your spouse, as well as your credit information and your investment instructions.
NBFWM's policies and practices regarding protecting your personal information are governed by the following principles:
1. We are accountable to our clients
We are responsible for all personal information we manage, including all information entrusted to a third party for processing, storage or other purposes. We've developed and implemented specific policies and procedures to protect your personal information, which include appointing a Privacy Officer.
As a condition of employment, all our employees must sign a code of ethics. One of the basic principles of that code is to maintain the confidentiality, security and privacy of the information in each client's records. We also provide our employees with ongoing training on company policies and procedures with regard to handling and protecting personal information and make sure they are regularly updated on new developments.
2. We'll let you know why your information is being collected
Before opening an account for you at NBFWM, your investment advisor must collect certain personal information to comply with legal and regulatory requirements Your file may include information about your investment expertise, annual income and profession, as well as your social insurance number.
When or before we collect personal information about you, we'll let you know why we need it. The account opening documentation you'll receive when you become a NBFWM client will explain why we need to collect, use and disclose your personal information.
3. We'll obtain your consent to collect, use and disclose your personal information
When you open an account with NBFWM, you'll be asked to sign the Agreements and Acknowledgements form attached to the Terms and Conditions document. By doing so, you agree to the collection, use and disclosure of your personal information as set out in the Collection, Use and Disclosure of Personal Information section.
You may refuse to agree to the collection, use and disclosure of your personal information. You may also withdraw your consent at any time, subject to legal and contractual restrictions and reasonable notice. Your consent to the collection, use and disclosure of your personal information may be necessary to enable us to manage and administer your accounts or provide services to you. Should you withdraw your consent, we may be obliged to close your account or cease to provide services to you.
4. We'll only ask you for the information we need
We'll collect personal information as permitted by law. For example, we'll collect personal information about you when opening or administering your account(s). This is generally information provided by you or by your investment advisor when you completed the documents required to open or maintain an NBFWM account.
5. We'll limit our use, disclosure and storage of your personal information
NBFWM uses your personal information as permitted by law. More specifically, NBFWM uses your personal information for the purposes set out in the Terms and Conditions document.
We may share your personal information with third parties, in particular under the following circumstances:
When we have obtained your consent to do so
When we share personal information with other organizations, including credit agencies, guarantors and third parties with whom NBFWM maintains business relationships, in accordance with the Your Relationship with National Bank Financial pamphlet.
When requested by a securities regulator or other regulatory organization
As required or permitted by law
We will only keep records containing your personal information as long as required by our business relationship, in accordance with our internal information retention policies or in compliance with legal and regulatory requirements. These records will be kept at the NBFWM branch you normally do business with, at the NBFWM Compliance Department or with one of our service providers.
We apply strict procedures to the storage of your personal information and delete any personal information that NBFWM no longer requires for the purposes specified.
6. We'll update your personal information and ensure its accuracy
We will take all reasonable measures to ensure your personal information is accurate, complete and up to date. You may at any time make a written request to access or examine your personal information held by NBFWM to ensure that it is correct and complete and make any necessary corrections, as permitted by law. Should you want to access your personal information, correct it, make a request for information or lodge a complaint, please contact your investment advisor.
7. The security of your personal information is a priority for NBFWM
We use rigorous security measures to protect your personal information from unauthorized access, regardless of the format used to store the information We continually update our security measures in line with technological developments.
The methods we use to protect your information include:
Physical security measures, such as controlled-access offices and locked filing systems
Electronic and technical security measures for computerized personal information, such as requiring passwords, encrypting databases and using personal information numbers
Organizational processes, such as restricting access to your personal information to a select group of persons
Contractual obligations with third parties who have access to your personal information, which require them to ensure the confidentiality and security of your personal information
8. Our policy on protecting your personal information is transparent
We're committed to offering you clear, easily accessible information about our personal information policies and practices. These policies and related information are accessible at all times on our website. They are also available upon request from our Privacy Officer.
9. We'll let you access your personal information stored at NBFWM.
When you make a request in writing, we'll inform you within 30 days regarding what personal information about you we have on file or under our control, the use made of such information and whether it is shared with third parties, and we allow you to contact them, as permitted by law.
10. We'll answer your questions and address your concerns regarding the protection of personal information
NBFWM will promptly and accurately respond to your questions and concerns about the confidentiality and security of your personal information and our personal information management policies.