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Privacy Policy

At Gluskin Sheff + Associates Inc. (Gluskin Sheff), 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 firm. In pursuit of this commitment, Gluskin Sheff 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.

This Gluskin Sheff Privacy Policy statement sets out in detail why we ask for your personal information, how we manage it and protect it.

Being Accountable

Gluskin Sheff 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 and have appointed a Privacy Officer to administer the process. All employees of Gluskin Sheff must abide by the principles outlined below.

All employees of any sub-advisers retained by Gluskin Sheff are also accountable for safeguarding and maintaining the privacy of all Gluskin Sheff client personal information that is accessible by them during the course of providing their services to Gluskin Sheff. Sub-advisers must enter into formal sub-advisory agreements with Gluskin Sheff and agree to abide by the Gluskin Sheff Privacy Policy.  

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 account applications 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

The Gluskin Sheff Account Agreement contains 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 to be requested and 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 Gluskin Sheff 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. To maintain awareness of our policies and practices in this regard, annually we have all of our employees sign a Confidentiality Agreement affirming their undertaking to faithfully abide by these practices. To satisfy regulatory requirements, personal information will be retained for at least seven years.

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. Gluskin Sheff 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 the central database 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 Gluskin Sheff representative or our Privacy Officer 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, Gluskin Sheff has implemented a number of steps to safeguard the integrity of all client personal information.

  • Hard copies of account documentation for open and recently closed accounts are stored in locked cabinets which are available only to those staff that need to work with this material. Protection of Gluskin Sheff’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

Gluskin Sheff follows a number of procedures to make sure that our clients are aware of how we manage their personal information. A statement about our Privacy Policy is contained in the Account Agreement, which also indicates that a full copy of the Policy is available upon request. Our Privacy Policy is also set out on our website and describes how to gain access to one’s personal information and to whom a request or query should be directed.

Making Personal Information Accessible to Clients

You may access your personal information that we have on file by contacting your client service representative or writing to the Privacy Officer at the address indicated below. Gluskin Sheff 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 Privacy Officer will acknowledge your query, investigate and provide you with a response within 30 days.

Please contact:

Gluskin Sheff + Associates Inc.
Bay Adelaide Centre
333 Bay Street, Suite 5100
Toronto ON M5H 2R2
Attention: Privacy Officer

 

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