Definition of Personal Information
Personal information is defined under the Privacy Act as any factual or subjective information, recorded or not, about an identifiable individual. This includes information such as:
A person’s age;
Name (unless related to a business);
ID number (such as a driver’s license or passport number);
Ethnic origin;
Social status, disciplinary action, credit files, loan records;
Income, assets, and other information specific to a person.
Exception: Information, such as a person’s name, title, and contact information as a partner/ employee is not private information. Likewise, any personal information which is publicly available is not covered by the Act.
Principals of Privacy Legislation
Eight Capital is subject to the Canadian federal government policy on privacy, the Personal Information Protection and Electronic Documents Act (“PIPEDA”). All Canadian privacy acts are based on the following ten principals:
Accountability
This requires an organization to comply with all 10 principles of PIPEDA;
Appoint an individual to be responsible for privacy;
Protect all personal information held at the organization;
Develop and implement personal information policies and procedures.
Identify Purposes
Before or when any personal information is collected, we will identify why it is needed and how it will be used;
We document why the information is collected;
We will inform the individual from whom the information is collected why it is needed.
Obtain Consent
We will inform the individual the purpose of collecting, using, or disclosing their personal information, and;
Obtain the individual’s consent before or at the time of collecting the information, or whenever a new purpose for the information is identified.
Limit Collection
We do not collect information which is not required;
We do not mislead individuals about reasons for collecting personal information.
Limit Use, Disclosure and Retention
We use or disclose the personal information only for the purposes for which it was collected, unless the individual has consented to other uses of the information;
We keep personal information only as long as necessary to satisfy the purpose;
We maintain guidelines and procedures for retaining and destroying personal information;
We keep personal information used to make a decision about a person for a reasonable time period;
We destroy, or erase information that is no longer required after the information retention limits.
Accuracy
Accurate information is vital to providing financial services, accordingly, to minimize the possibility of using incorrect information, we advise you to periodically review and update the information which you have provided to Eight Capital.
Safeguards
We maintain physical, electronic and procedures to protect your personal information against loss, disclosure, unauthorized access, copying or modification;
We protect personal information regardless of the format in which it is held;
Our clients’ information is accessible only to employees who need it to conduct our clients’ financial affairs or provide services to them. Our employees, and our account management practices, are governed by extensive regulatory procedures, and by Eight Capital’s internal procedures. Staff is reminded on a regular basis of their obligations with regard to the confidentiality of client information through employee training, or by operating procedures.
Openness
Eight Capital publicly discloses how personal information is handled. This information is readily available through its privacy policy, on its website or by contacting Eight Capital’s Privacy Officer.
Individual Access
Following your request, we shall inform you, the client of:
The type of personal information we have collected;
How Eight Capital have used such personal information in the past, and how we may use it in the future;
Any organizations (third parties) to whom your personal information has been disclosed, and the content of such disclosure;
You may verify the accuracy and completeness of your personal information at any time, and may request that it be amended, if appropriate. Prior to correcting any inaccuracies in connection with the personal information collected, we shall verify the identity of the individual making the request. When requested, inform individuals if you have personal information about them.
Challenging Compliance
You may challenge Eight Capital’s compliance with this policy by contacting the designated Privacy Officer. Eight Capital shall review all complaints received. Upon receipt of a complaint. If the complaint is deemed justified, Eight Capital will take appropriate measures to ensure compliance is achieved, and will make the necessary procedural changes to ensure compliance in the future.
Should you still have any questions or concerns in regards to the principles listed above or about how your personal information is treated, you may address complaints to:
Eight Capital
100 Adelaide Street West
Suite 2900
Toronto, Ontario
M5H 1S3
Attention: Privacy Officer
Email: privacy@viiicapital.com
The Firm has in place the following procedures to ensure
compliance with PIPEDA:
Upon the opening of a client account in which personal information is required
(such as for non-registered institutional clients), Eight Capital will provide
a summary of the Firm’s privacy policy and will ask the individual to
acknowledge their consent in writing.
Handling of Private Information
Eight Capital partners and employees are not to use the Firm’s private client information for any use other than that which is disclosed to the client. Private information is not to be disclosed to anyone outside of the Firm unless it is required to be by contract and business function, such as the Firm’s carrying broker, or a regulator to whom Eight Capital is subject.
Storage of Private Information
Client’s private information must be kept secure at all times. This means that after hours, it must be kept in a locked filing cabinet, and only Eight Capital partners and employees with a need to know should have access to this information. As with all documents related to Eight Capital’s business, personal information is required to be kept for seven years. If it relates to account opening documentation, which it likely will be, it must be kept for the life of the account, and seven years after the account has been closed.
Privacy Officer
Eight Capital’s Chief Compliance Officer will be the Firm’s Privacy Officer. As the Privacy Officer, they are responsible for the oversight of the Firm’s privacy policy, ensuring that any private information held by the Firm is secure. The Privacy Officer will also deal with any client complaints regarding privacy.