Purpose

Creaghan McConnell Gould (CMG) collects information from clients and the marketplace in general in order to provide the best possible fit of its services. The collection and retention of this information falls under both CMG’s confidentiality policy and legislated privacy regulations (PIPEDA).

Scope

This policy applies to all CMG staff, vendors, agents, and the business platform. It applies to all client and business information stored or maintained within the CMG business.

Personal Information is information about an identifiable individual. It includes identification information such as your name, address, age, gender, family relationships, and personal financial information, possibly including wills and business relationships and medical information, as necessary.

Policy

CMG shall take commercially reasonable steps to ensure that it meets all applicable legislated privacy requirements and complies with its own Confidentiality policy.

The Chief of Staff is designated to act as the Privacy Officer.

The following shall be published publicly on the CMG website and provide to clients as requested, and serves as CMG’s policy.

Why do we collect personal information?

We collect personal information

• to understand each situation, needs and objectives
• to provide information about our products and services that may support your objectives
• to help determine the suitability of our products and services for you
• to set up and manage products and services that you have requested
• to verify identities in order to contact and communicate with you including online inquiry
• to satisfy the regulatory obligations of our industry
• to obtain best pricing and design options to meet your objectives

How do we collect personal information?

• We only collect personal information by legal and legitimate means. Virtually all of the personal information we collect is provided by you in the course of discussing our services and products and their suitability to your unique situation. Our website, www.cmgpartners.ca, only collects personal information if you voluntarily supply it by email or by completing the Contact Us form.

Sharing your personal information

• In order to provide you with the services and products we offer, it may be necessary to share some personal information. Such sharing is done strictly on a need-to-know basis, and where appropriate with your written consent. Examples of this include: submission of medical reports to insurance companies for pricing and underwriting processes; reviewing financial information with mutually acceptable professionals such as the accountants or lawyers whose services are retained to support your objectives.

CMG Platform Security & Privacy Policy

Creaghan McConnell Gould’s use of social media serves as an extension of our presence only. We do not share personal information via our website or social media. If you choose to contact CMG via a social media service, you should be aware of that service privacy policies.

Note that social media accounts are public and not hosted on our server.

We do not, under any circumstance, make our lists of clients, potential clients, client advisors, business managers or any family members, available to any third party. We do not use social media information to create individual profiles.

Safeguarding and keeping your personal information

Some of the personal information we collect is stored electronically; other information is stored as hard copy. We employ safeguards appropriate to protect against theft, loss, unauthorized access, disclosure, copying or modification. These include but are not restricted to individual password access to computer files, network firewalls, employee confidentiality agreements, locked alarm-protected offices, document shredding, and formal staff communications. You should know that like many companies we utilize third-party service providers to support our data systems and operations, and that some of these service providers may be located in countries other than Canada. Any data held by our service providers remains subject to commercial security standards.

Consent

In order to provide our services you consent to the collection, retention and use of personal to the extent necessary to permit us to perform services and to manage and administer your files. As one component of our client meeting, we will seek formal consent to collect your personal information, for use and protection as described in this policy.

Accuracy

We use reasonable efforts to ensure that personal information is accurate and complete for the purposes for which it is to be used. We do not continually update personal information that we hold unless this is necessary to achieve the purposes for which the information was collected.

Retention

Personal information is retained for as long as required to satisfy industry regulatory guidelines. It may also be retained to support future opportunities to provide our services. An example of this might be providing services to or for grandchildren of an existing client, who may no longer require direct services for themselves.

Openness

Our Privacy policy and guidelines are available to clients and the public. Upon written request addressed to the Privacy Officer, we will provide a copy of these guidelines and respond to inquiries about our practices relating to personal information.

Individual access An individual may ask to be informed of the existence, use and disclosure of personal information pertaining to him or her. We will ask for sufficient information to properly identify applicants to prevent fraud or the unjustified transmission of personal information to third parties.

We will process applications for access to personal information within an agreed upon deadline. This deadline might be extended if the circumstances or the scope or of the application make it difficult to meet this deadline.

In general, there will be no charge for processing access requests. However, fees may be charged when the application for access or rectification is unusual or complex.

A individual’s right to access their personal information is not absolute. CMG may deny access under the special circumstances such as when granting access would unreasonably impact other people’s privacy or the request is deemed to be frivolous or vexatious. If we deny access, we will explain why.

The purpose of our privacy policy

You should be aware that we collect certain limited information about the way in which you use our website. By using our website you consent to the collection of this data and agree to the terms of our privacy policy.

This data is used only by our employees for analytical purposes to improve your experience with our website and it’s performance. The data we collect is anonymous. We do not sell this data or use it for advertising purposes. This data is not sent to any other country. We will not disclose it to third parties unless compelled by a court of law, to protect our legal rights, or for audit purposes.

Our employees responsibilities

Each and every employee is responsible for maintaining the confidentiality of all personal information to which they have access. As a condition of employment, our employees are required to sign a confidentiality agreement binding them to this responsibility, which governs their actions, even if they leave or retire from CMG. We issue employee directives to remind them of their obligations to this Policy. We also conduct training sessions to ensure employees understand the importance of private personal information, and how to protect it.

Non-employee responsibilities

We require every individual or organization that provides us with administrative, information processing, accounting, office cleaning, transportation or other support services to comply with this Policy and with the privacy protection rules it contains. Such third party compliance is achieved through a contract or certificate of compliance.

Privacy Officer

We have appointed a Privacy Officer who oversees privacy governance, including policy, education, and communication activities.

Complaints

All requests for access to personal information on our files, policy queries or complaints should be addressed in writing to:

Privacy Officer, Creaghan McConnell Gould 70 Richmond St. E. Suite 400, Toronto ON, M5C 1N8