Kerr Financial Consultants Inc./ Kerr Financial Advisors Inc.
(hereafter referred to as ‘KERR’)
KERR is committed to respecting personal privacy. We recognize and respect every individual’s right to privacy and acknowledge our obligation to preserve the confidentiality of personal information.
The term “personal information” refers to information that specifically identifies you as an individual and is provided to or collected by us. It includes information that you provide or that we collect from other sources with your permission, for example: your name and address, age and gender, personal financial records, identification numbers including your social insurance number, personal references, and employment records.
The Protection of Personal Information
KERR uses and discloses personal information in accordance with all applicable laws and the following 10 principles, which reflect the principles articulated in the Personal Information Protection and Electronic Documents Act (Canada). This Code applies to the operations of Kerr Financial Consultants Inc. and Kerr Financial Advisors Inc.
1 – Accountability
Each and every one of KERR’s employees is responsible for maintaining and protecting the personal information to which they have access. As a condition of employment, our employees are required to sign an agreement which addresses their responsibility for protection of confidential information during and after the term of their employment. Disclosure of your personal information is restricted to individuals who need access in order to provide services to you. We maintain physical, electronic and procedural safeguards that comply with Canadian and U.S. regulations to protect your personal information.
2 – Identifying Purposes
KERR will identify the purposes for which personal information is collected at or before the time it is collected. The purposes for which information is collected depend on the services you engage with us and are those that a reasonable person would consider appropriate in the circumstances.
When you become a client of KERR, we ask for your personal information for the following purposes:
- To verify your identity and protect against fraud;
- To understand and assess your ongoing needs;
- To assess and recommend financial strategies appropriate for your situation;
- Where we are involved with your investment planning and management, to understand your investment requirements, to assess the suitability of products and services for you and to adjust your portfolio if warranted;
- For client communication, service and administration including invoicing and accounting purposes;
- To comply with legal and regulatory requirements;
- To facilitate investment transactions with other financial intermediaries;
- In compliance with the Proceeds of Crime (Money Laundering) and Terrorist Financing Act.
3 – Consent
The Personal Information Protection and Electronic Documents Act (PIPEDA) and an Act Respecting the Protection of Personal Information in the Private Sector (Quebec) requires KERR to obtain your consent to collect, use and disclose information about you.
Consent may be given orally or in writing. The type of consent obtained relates to the sensitivity of the information disclosed. For example, when we collect information relating to your discretionary portfolio, we obtain your express written consent to its collection and use. Please note that if you provide personal information about others (such as employees, dependants, etc.) we assume that you have obtained their consent.
4 – Limiting Collection
KERR will limit the amount and type of personal information collected to that which is necessary for the purposes identified by KERR. The personal information will be collected by fair and lawful means.
5 – Limiting Use, Disclosure and Retention
We do not disclose your personal information to anyone except as permitted or required by law or as expressly authorized by you. Instead, we use your personal information primarily for provision of professional services and to complete transactions that you request. Here are the details:
- To complete certain transactions that you request, such as opening a custodial account, it may be necessary to provide identifying information to non-affiliated third parties.
- We will release your personal information if we are required by law to do so, or in other limited circumstances permitted by law – for example, to protect your account from fraud, or if you give us the permission to do so.
We require written instructions describing the type of personal information you wish us to share and the name, address, phone and fax number and e-mail address of the third party, such as an auditor, accounting firm, consulting firm, etc.
Personal information will be retained only as long as necessary for the fulfillment of those purposes. New uses and disclosure require new consent. We have retention policies in place that govern the destruction of personal information.
If personal information is made anonymous by removing details so that an individual is not identifiable to the user or recipient of that information, it is not governed by this Policy but still will be treated with appropriate safeguards.
Principle 6 – Accuracy
KERR will endeavour to keep personal information as accurate, complete, and up-to-date as is necessary for the purposes for which it is to be used. KERR will minimize the possibility that inappropriate information is used to make a decision about the individual.
Principle 7 – Safeguards
KERR will protect personal information with security safeguards appropriate to the sensitivity of the information to protect it against loss, theft, unauthorized disclosure, copying use or alteration. The methods that we use to safeguard information include physical measures (locked filing cabinets, locked file rooms, locked and insured premises, restricted access) and technological measures (passwords, encryption and policies with respect to the use of electronic information).
Principle 8 – Openness
KERR will be open about its policies and procedures with respect to management of personal information. KERR will ensure that individuals are able to acquire information about KERR’s policies and procedures without unreasonable effort. KERR will make this information available in a form that is generally understandable.
Principle 9 – Individual Access
Upon a client’s request in writing, KERR shall inform a client of the existence, use, and disclosure of his or her personal information and the client shall be given access to that information, except where the law requires or permits KERR to deny access.
Principle 10 – Challenging Compliance
An individual will be able to direct a challenge concerning compliance with the above principles to KERR. Individuals may also make a complaint to the Privacy Commissioner.
Any questions, requests or complaints can be directed to the address below.
Kerr Financial Consultants Inc./ Kerr Financial Advisors Inc.
150 York Street, Suite 1212
Toronto, ON M5H 3S5