K.J. Harrison & Partners Inc. (“KJ Harrison”) respects the trust you have placed upon us and we are committed to controlling and safeguarding the collection, use, protection and disclosure of your personal information. Your account is governed by the Managed Account Agreement and by the New Client Application Form. KJ Harrison has contractual agreements with various third parties including our Custodian/Carrying Broker and Fund Administrator where such agreements each contain privacy provisions.
Personal Information Defined
Personal information refers to information that specifically identifies you as an individual and is provided to, or collected by us. It includes, for example, your name and address, age and gender, personal financial records, identification numbers including your social insurance number (SIN), your employment history and banking information.
Collection and Use of Personal Information
When you open an account with us, we will obtain personal information about you that will be kept on file in accordance with industry regulations. Only authorized individuals and entities have access to this information. The information that we collect allows us to identify you, communicate with you in a timely and efficient manner, protect you against possible fraud, assess your potential investment needs, and to comply with legal and regulatory requirements.
Specific Personal Identification
We ask for a variety of information when you open an account with us. Securities industry regulations legally require that we obtain a minimum amount of information about you so that we can provide the proper level of service and supervision to your account.
If you are an individual, KJ Harrison will collect, use and disclose your Social Insurance Number for income tax reporting purposes.
We will collect, use and forward a photocopy of your personal ID to the custodian as proof of residency for U.S. withholding tax purposes.
Personal Information to External Sources
Your personal information will be disclosed to those external sources that provide services to us such as our Custodian, financial institutions and other parties. For example, service providers who we hire to undertake activities, such as processing trades for your account and sending monthly statements to you, will have access to certain account information including your name and address in order to perform their required functions. We require third party service providers to sign a Privacy Agreement to ensure that your information remains confidential.
We are also obliged to provide your information to regulatory bodies within the investment industry. We may also be required to disclose your information to government agencies or law enforcement agencies.
This Client Privacy Agreement also covers our release of your personal information to your personal accountant, as per your instructions.
Finally, KJ Harrison does not disclose your information to any other organization to use for their own purposes. We do not sell client information to, or trade client information with anyone; nor do we share client information with organizations outside of our relationship with you that would use it to contact you about their own products or services.
Your consent is required before we may provide your information to any third parties. The consent that you provide to KJ Harrison with regards to the collection, use and disclosure of your personal information may be cancelled at any time by providing written notice to us. Please be aware that the purposes for which we collect, use and disclose your personal information are central to our being able to provide you with our services. By withdrawing your consent, KJ Harrison will no longer be in a position to provide you with requested products and services. Therefore, by maintaining your account with KJ Harrison, you are providing consent to our collecting, using and disclosing your personal information, as set out in this agreement.
We do not require your consent to the collection, use and disclosure of your personal information where such collection, use and disclosure are reasonably required:
- In the normal course of providing service to your account
- By a law enforcement agency, securities regulatory authority or Self-Regulatory Organization
- By legal counsel for the purpose of obtaining advice.
By opening an account at KJ Harrison you are providing consent to us to collect, use and disclose your personal information as set out in this agreement.
Protection of Personal Information
We will take appropriate procedural, physical and technological safeguards to protect your information against unauthorized access and use. Our employees are required to sign a confidentiality agreement as a condition of employment. We retain your information only as long as we require it to service your account, or as long as industry regulations require.
European Union Clients
If you are a client based in the European Union, the personal information collected from you is transferred and processed in Canada, a country which is not recognized by the European Commission as providing an equivalent level of protection for personal data as provided in the EU. By submitting your personal information to us, you expressly consent to the transfer of your personal data to recipients located outside of the European Economic Area. You may withdraw your consent to such transfer at any time or exercise certain additional rights with respect to the personal data of EU Data Subjects under the EU General Data Protection Regulatory (“GDPR”). Please note, however, that we will not be able to maintain your account without such personal information.
Retention of Personal Information
KJ Harrison will retain your personal information on file after you cease to be a client of ours for as long as we require such information or as long as is demanded by regulatory requirements.
Access and Corrections to Personal Information
You may review the information you have provided to us and make corrections to it in a timely manner. We may request that you provide corrections in writing. We will take reasonable steps to ensure that your personal information is accurate and up-to-date.
Your Right to Withdraw Consent
By opening an account with us, you are providing your consent for us to collect, use and release your personal information. If at any time you wish to withdraw this consent, please advise us.
Addressing Your Concerns
We will address and respond to any of your concerns about our handling of your information. You may address questions or privacy-related complaints to firstname.lastname@example.org or to Compliance, K.J. Harrison & Partners Inc., 60 Bedford Road, Toronto, Ontario, M5R 2K2.