We are committed to respecting and protecting
the privacy and confidentiality of our clients’
personal information. We want you to know why we ask
for your personal information, how we use your
personal information in establishing and maintaining
your relationship with us, how we keep your personal
information confidential, and how you can inquire
about the personal information we hold about you.
This Code applies to the operations of Northwood
Private Counsel Inc. and Northwood Family Office LP.
Any changes to our information handling practices
shall be acknowledged in this Code on a timely
manner. We may add, modify or remove portions of
this policy when we feel it is appropriate to do so
and, if the changes are material, will provide you
with a revised code. Please refer to our website at
www.northwoodfamilyoffice.com to obtain the most
recent version of this Code.
Employee Responsibilities
Each and everyone one of our employees is
responsible for maintaining the confidentiality of
all personal information to which they have access.
As a condition of employment, our employees are
required to sign a confidentiality agreement binding
them to this responsibility which governs their
actions, even if they leave or retire.
We keep our employees informed about our policies
and procedures for protecting personal information
and reinforce the importance of complying with them.
All employees are required, as a condition of their
employment, to conform to this Code.
What is Personal Information
The term “personal information” refers to
information that specifically identifies you as an
individual and is provided to or collected by us. It
includes information that you provide or that we
collect from other sources with your permission, for
example: your name and address, age and gender,
personal financial records, identification numbers
including your social insurance number, personal
references, and employment records.
Why we ask for your Personal Information
We want to work with you to help you achieve your
financial goals, to provide you with value-added
service on an ongoing basis, and to establish a
lasting financial relationship with you that will
grow and change as your financial needs evolve.
The better we know you, the better we are able to
serve you. We therefore ask you for your personal
information for the following purposes:
• to verify you identity and protect against fraud,
• to understand your investment requirements,
• to determine the suitability of products and
services for you,
• to offer you products and services that may be of
interest to you,
• to set up and manage products and services you
have requested, and
• to comply with laws and securities regulations.
Some of the information we will ask for and use,
either at the time of account opening or on an
updated basis is also required to satisfy the legal
or regulatory requirements of federal and provincial
governments and/or other regulatory authorities.
In general, you can choose not to provide us with
some or all of your personal information. However,
please understand that if you make this choice, we
may not be able to provide you with the product,
service, or information that you requested or that
was offered to you, or is typically offered to
clients.
Obtaining, Verifying and Accessing Your Personal
Information
We obtain personal information about you primarily
from you. We may also obtain financially-related
information from other sources with your consent.
If you want to review or verify your personal
information, or find out to whom we have disclosed
it as permitted by this
Code, direct your request to the Compliance
Department.
At that time, we will need specific information from
you to enable us to search for, and provide you
with, the personal information we hold about you. If
we are unable to provide you with access to your
personal information, we will always explain the
reason why.
Keeping Your Personal Information Accurate
We are committed to maintaining the accuracy of your
personal information for as long as it is being used
for the purposes set out in this Code, and provided
that you keep us up-to-date. Prompt notification of
any changes, such as your address or telephone
number, will help us provide you with the best
possible service. Should you discover, upon review
of your personal information, that amendments are
required, please advise us. We will make our best
efforts to advise others of any important amendments
to your personal information that we may have
released to them.
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If
we do not agree to make the amendments that you
request, you may challenge our decision. We will
make a record of this challenge and, if necessary,
disclose the challenge to third parties who also
possess that personal information.
Releasing Your Personal Information
Northwood does not disclose your personal
information to third parties other than in the
following circumstances or for the following
purposes:
1. in connection with normal business operations to
open, maintain, administer, or service your account,
including, without limitation the mailing of product
information materials, the provision of customer
service (including services rendered by third party
agents or affiliates), the provision of back office
administrative services (including clearance and
settlement services, the mailing of account
statements and reports and record-keeping services),
for audit or statistical purposes;
2. to legal counsel for the purpose of obtaining
legal advice;
3. where we are required or permitted to do so by
law, including to any law enforcement agency,
securities regulatory or self-regulatory
organization.
By opening or maintaining an account with us or
using our services, you have consented to the
disclosure of your personal information to a third
party in the circumstances or for the purposes
described above.
Keeping Your Personal Information Confidential
Personal information is protected at Northwood by
safeguards that are reasonable to the sensitivity
against unauthorized access, disclosure, copying,
use or modification. Safeguards include physical
protection (such as locked cabinets and restricted
access to offices), organizational measures (such as
security clearances) and technological measures
(such as passwords and encryption).
In circumstances where we use third parties to
provide services to you on our behalf, such as
administrative functions or trade processing, they
are given only the information needed to perform
those services. We have contracts in place holding
these companies to the same high standards of
confidentiality by which we are governed and require
that any information provided by us must be kept
strictly confidential and used only for the purposes
of the contract.
We have strict procedures in place when destroying,
deleting, or disposing of personal information when
it is no longer required for the purposes set out in
this Code, or by law.
Retention of Your Personal Information
We only keep your personal information for as long
as we need it to meet the purposes set out in this
Code. The length of time we retain your personal
information depends on:
• the type of product or service you have with us,
and
• any legal or regulatory requirements we may have
to meet.
For example, we must be able to respond to any
concerns you may have, even if you are no longer a
client of ours. We have retention policies in place
that govern the destruction of personal information.
Your Options
You can choose not to provide us with some or all of
your personal information. You can also withdraw
your consent to our use of your personal
information, as long as:
-
reasonable advance notice is given, requesting
no further use or communication of personal
information to which the privacy legislation
applies;
-
there are no legal requirements for the use of
your personal information; and
-
we can continue to fulfill our contractual
obligations to you.
Any
questions, requests or complaints can be directed to
the address below.
Northwood Family Office LP/ Northwood Private Counsel Inc.
3650 Victoria Park Avenue, Suite 200
Toronto, Ontario, M2H 3P7
Phone (416) 502-1245
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