Privacy Policy

Protecting Clients’ Privacy

At Manitou protecting our clients’ privacy and the confidentiality of their personal information is fundamental to the way we do business. We recognize that we must be transparent and accountable in how we treat the information clients share with us.

How Do We Define Personal Information?

Personal information refers to information that specifically distinguishes clients as individuals and is provided to or collected by us. It includes, for example, name and address, age and gender, social insurance number, banking information, as well as investment and financial information.

How and Why Do We Ask for Personal Information?

We obtain most of our information about clients directly from them. This information is gathered, primarily through our detailed Client Profile form, which we use in managing clients’ account(s). This information is necessary for a number of reasons, including:

To fully understand clients’ investment needs and objectives in order to manage clients’ investment portfolios
To verify clients’ identity and protect against fraud
To establish custody accounts that clients’ have requested for the safekeeping of the securities that we manage
To comply with the regulatory obligations of the securities industry
To comply with the Canada Revenue Agency’s income reporting requirements.
To comply with Canadian legislation aimed at the prevention of money laundering.

We limit the information we collect to what we need for these purposes, and we use it only for these purposes.

In order to provide our products and services to clients we may provide information to other persons:

Where we have client consent
Where the other parties are agents or suppliers who assist us in serving our clients (e.g. custodians)
Where we are required or permitted to do so by law (e.g. CRA)

Specifically, we are required to advise clients that we will be disclosing client name, address and details of pooled fund purchases to the applicable provincial securities commissions. This information is collected by the various securities commissions under the authority granted to them in securities legislation for the purposes of the administration and enforcement of the securities legislation. If clients have any questions about the collection of this information they may contact the Administrative Assistant to the Director of Corporate Finance at the Ontario Securities Commission at 416-593-8086.

How We Protect Clients’ Information

We protect client information with appropriate safeguards and security measures. We have security standards to protect our systems and clients’ information against unauthorized access and use.

All of our employees, agents and suppliers, as part of their agreements with Manitou, are bound to maintain client confidentiality and may not use the information for any unauthorized purpose.

We monitor and review our procedures and security measures regularly to ensure that they are being properly administered and that they remain effective and appropriate.
We make every reasonable effort to keep clients’ information accurate and up- to-date. We retain clients’ information for only as long as we require it for the reasons it was collected. When it is no longer required we will destroy or delete it in an appropriate manner.

Questions or Concerns

If clients have any questions or concerns about the privacy and confidentiality of personal information, or if they would like access to the personal information that we have on file they may contact Deborah O’Reilly, Privacy Officer of Manitou Investment Management Ltd. at 416-628-6523.