This document complies with the requirements of the Personal Information Protection and Electronic Documents Act (“PIPEDA”) and any applicable provincial/territorial legislation.
This policy will be reviewed annually and updated on a regular basis.
Personal information means any information that specifically identifies you as an individual, such as your home address, telephone numbers, social insurance number, birth date, assets and/or income information, employment history and credit history
The policy does not encompass personal information about you that may be accessed in the public domain, for example, your business address that can be found in public documents such as telephone or professional directories.
Personal information is gathered directly from you with your consent in order to:
Personal information is collected from various sources such as:
We may transfer your personal information, when necessary, to our third party service providers and to our agents in connection with the services we provide related to you; however they will not share this information with others. Such information is only used for the purposes identified above. REIC will use contractual or other means to provide a comparable level of protection while the information is being handled by a third party service provider or agent. The following is a list of such third party providers and agents:
The choice to provide REIC with personal information is always yours. However the decision not to provide personal information may limit the products and services we are able to offer. If REIC is unable to accommodate your request based on the personal information provided, we may ask for additional details in order to identify other alternatives.
Electronic client files are kept on a highly secured network with restricted access. The network resides at 150 King Street West, Suite 801, Toronto, ON, M5H 1J9. Other safeguards utilized by REIC include multi-level network security, virus protection and regular secure backup of all relevant electronic data.
We also utilize a portfolio management system that is hosted offsite on a highly secured sever, which is backed by PEER 1 Network Enterprises, Inc. The server is located within a secure building that is a dedicated hosting facility. Only a limited number of authorized users have access to the physical server. Any and all measures are taken to protect the data that is stored on this server.
Paper-based documents are stored in secured areas within the office and may be held at a restricted offsite facility.
Personal information collected from you will only be used for the identified purposes and will be retained for as long as is necessary to fulfill the service or as required by law. We regard confidentiality and privacy as a foundation of our business. Employees of REIC are required to acknowledge and sign the Code of Conduct Policy annually. Unauthorized access to and/or disclosure of clients’ personal information by an employee is strictly prohibited. All employees are expected to maintain the confidentiality of client information at all times and failing to do so will result in appropriate disciplinary measures, which may include suspension or dismissal
You may verify the accuracy and completeness of your personal information, and you may request that it be amended as required. Should you identify any incorrect or out-of-date personal information, we will make the appropriate change in accordance with your instructions. Where appropriate, including where required by law, we will communicate these changes to other parties who may have incorrect information about you.
REIC may be unable to provide you with full access to your personal information if we are prohibited by law or regulatory reasons or it has been destroyed. REIC will provide you with a valid explanation if we are unable to fulfill your access request.
Upon request, REIC will provide you with access to your personal information. You may also withdraw your consent for the use of your personal information by contacting REIC at any time subject to reasonable notice. Legal and other requirements may prevent you from withdrawing consent and your decision to withdraw personal information may also limit the services or products we are able to provide to you.
You may direct any questions or inquiries you have with respect to the policy or about the way we manage your personal information by contacting us at:
Evans Investment Counsel
Attn: Don Barber, Vice President, Portfolio Manager & Chief Compliance Officer
150 King Street West
Suite 801 – P.O. Box 55
Toronto, ON M5H 1J9
For more general inquiries, contact the Information and Privacy Commissioner of Canada (IPC). IPC oversees the administration of the privacy legislation in the private sector. The Commissioner also acts as a kind of ombudsman for privacy disputes. Information and the Privacy Commissioner can be reached at:
The information on this web site is provided by Evans Investment Counsel to help individuals, families and business owners understand what we do to protect and grow their invested assets. We attempt to keep information on this web site accurate and current.