At ICM Realty Group Ltd. (“ICM”), we are, and always have been, committed to maintaining the highest level of confidentiality regarding the personal information that our clients share with us. We have always recognized that this is your information, not ours, and we only share it when we have your express permission. Respecting your privacy is a value which is honoured throughout our company. In pursuit of this commitment, ICM is guided and governed by the Personal Information
Protection and Electronic Documents Act (PIPEDA), which regulates the private sector’s collection, use and disclosure of personal information.
ICM recognizes that it is responsible for the personal information which you have imparted to us. We have established practices and procedures to ensure that this information is appropriately safeguarded.
Identifying the Purpose of Collecting Personal Information
Personal information, under PIPEDA, includes, but is not limited to, your name, address and telephone number, birth date, social insurance, passport or driver’s license number and photo, as well as your financial and investment information. This information may be collected through subscription documents or other forms, or through conversations or other correspondence with you. We collect this and other information about you in order to properly identify you, to contact you or your designated representatives, to understand your investment needs, to make appropriate investment decisions on your portfolio, to manage the administration of your account, to inform you of services we offer that may be relevant to you and to satisfy legal, regulatory, custodial and tax reporting requirements.
Obtaining Your Consent
Subscription agreements for ICM funds contain a number of sections in which you are requested to supply personal information about yourself. By completing and signing this agreement or by providing us with personal information by any other means, you are consenting to the collection of your personal information and any subsequent personal information that is collected by us for the purposes which we have set out. You may withdraw your consent at any time, subject to legal and contractual conditions; however, this may have an impact on the services that we are able to provide to you.
Collecting Only Essential Information
Our accounting, compliance and client service personnel are aware that only information necessary for the opening and operating of your investment account is requested and to be collected.
Limiting the Use, Disclosure, and Retention of Your Personal Information
Confidentiality of client information is a fundamental principle of our firm. No employee may release confidential client information, including the fact
that a person either is or is not a client of the firm, unless required by law or with the client’s express consent.
All employees of ICM are accountable for safeguarding and maintaining the privacy of all personal information under their control. Our accounting, compliance, client service and administration personnel have been appropriately instructed and trained to ensure that account information, when requested, is only supplied to people who are expressly authorized by you to receive it. Our systems identify whether there are any such authorized recipients other than yourself for your account.
We will not disclose your personal information to third parties, except to the extent required to fulfill the purposes we have set out. We use service providers in various aspects of the services we provide to you, including, but not limited to, custodians, transfer agents, fund accounting, administrators, storage facilities, information technology providers, auditors, lawyers and other third parties. These third parties are only provided with the information necessary to perform the required services, and we require, under written agreements that these third parties protect the privacy of your information. ICM will not sell your personal information.
We may be required to disclose your personal information to domestic and international governments, and other regulators. We will only do so when required by law.
Ensuring the Accuracy of Personal Information
Staff who are in regular contact understand that they have a responsibility to update our records whenever they learn of changes in your personal information. As well, update forms are circulated periodically to give you the opportunity to revise your personal information. Should you have any concerns about the accuracy of your personal information which we have on file, please contact your ICM representative as indicated at end of this document.
Using Appropriate Safeguards
In the course of establishing a secure environment for the operation of our investment management activities, ICM has implemented a number of steps to safeguard the integrity of all client personal information.
- Hard copies of client documentation are available only to those staff that need to work with this material. Protection of ICM’s premises is secured through limited access only to those in possession of secure pass cards.
- Archival documents are stored with reliable third parties offsite at secure premises.
- Personal information in the form of electronic data is stored within our computer systems using firewalls, passwords and transmission encryption programs.
- All electronic data is backed up daily at an offsite storage facility which maintains industry standard security systems.
Being Open and Transparent about Our Processes Relating to Personal Information
Making Personal Information Accessible to Clients
You may access your personal information that we have on file by contacting your client service representative at the address indicated below. ICM will be pleased to explain how your information is used and correct or amend any information which is determined to be incorrect or deficient. Requests for information will be responded to within 30 days.
Responding to Inquiries and Complaints
Inquiries or complaints will be dealt with promptly. Please direct your communication in writing, to the address indicated below. The appropriate individual will acknowledge your query, investigate and provide you with a response within 30 days.