Why we collect, use and retain personal information:
We obtain client information with their consent, in order to provide services and access to providers’ products. Our policies must meet the standards our providers establish in their own privacy policies. The personal information we collect from clients and provide for submission to providers is essential information that we use to provide administrative services providers, which in turn require this same information to provide services and products that clients have requested. This information is used to determine insurance risk, assess eligibility for products, to administer those products once purchased and to fulfill certain regulatory requirements. This can include health information, financial information and history, information about avocations, Anti-money laundering and terrorist financing requirements, Know-Your-Client, and Investor questionnaires. We retain some of this information in order to be able to administer business, provide ongoing service to clients and providers and when we are required to do so by law.
We may use anonymous data to manage our business, identify products and services that will benefit our advisors and our clients and to prepare reports about our business.
We collect only the information we need to fulfill our contracts with insurers and to meet our regulatory obligations. We will use only fair and lawful means to collect this information. We will collect information only with implied or expressed consent, depending on the information and the purpose for collection.
How we collect clients’ information:
Wherever possible, we collect clients’ information directly from their advisor. Information may be obtained through government agencies, other insurers and financial institutions. We may collect any required health information about clients from their advisor or directly from the client. Our third party service providers and other advisors may also collect this information on our behalf.
The client consent that providers receive includes consent to provide personal information to us, which allows us to fulfill our contractual obligations to the provider. We also operate under the client consent that their advisor receives in order to support their services. When a client requests or uses any of the products or services we make available, we will transfer whatever information is necessary by implied consent. If we receive notice from a provider that a client has withdrawn consent for the continued use and retention of personal information, we will take whatever steps are necessary to adhere to the Act. We will act on whatever instructions we receive from the provider regarding the client’s status. If a client obtains insurance for a family member or other third party or otherwise provide personal information concerning a third party, including a family member, for example by naming him/her as a beneficiary, the client represents that they have obtained any necessary consent to our collection, use and disclosure of his/her personal information for the purposes described above.
Limits on use and disclosure:
We will use and disclose personal information to perform our contractual duties [by conveying the information through a Managing General Agency (MGA) to the insurers they are contracted with to provide administrative services; or through a Mutual Fund Dealer to mutual fund companies; or through third party system provider to Financial Institutions which we are contracted through], to provide you with information and when we are required to do so by law. We may disclose this personal information to our employees or service providers so that they can perform their duties or assist advisors with their duties, to insurers and any person or organization to which consent has been given and where authorized by law. Where personal information is provided to service providers, we require them to protect that information consistent with our policies and practices.
We may also use personal information to offer products and services that we believe will interest clients but we will never give or sell personal information to third parties for marketing purposes. These products or services may be through MBI Financial or one of our affiliated companies, or our Mutual Fund Dealer.
Limits on retention of information:
We will retain personal information in our records only as long as it is needed for the purposes identified, or as legally required or permitted. Once the retention period has ended, we will destroy and/or erase all personal client information in a secure manner. Client information is only retained upon expressed consent from the client.
Accuracy of information:
It is the advisor’s responsibility to keep personal information about the client as accurate and up-to-date as possible. Both the provider and the advisor are responsible for providing us with notices of changes that they receive directly. An individual may challenge the completeness and accuracy of his/her personal information that we hold. We will make any necessary corrections to information about a client that is shown to be incomplete or inaccurate and we will notify any third parties, including insurers, if we make such corrections.
Clients may gain access to their personal information we hold by making an access request to the advisor and/or provider on whose behalf we hold the information. In situations where a client seeks corrections to information we hold, we will act on the instructions of the provider (s) whose products are held and/or your advisor, depending on the corrections required. Any disagreement or discrepancy regarding accuracy will be documented.
Protecting personal information:
We will protect personal information from unauthorized access or use by ensuring that safeguards are in place, including physical security measures for our locations, operational policies, procedures and access protocols and technological measures for our computer systems. We will use safeguards to prevent unauthorized access to personal information during the destruction process.
If you have any questions or concerns regarding this Policy or how we manage your personal information, please contact our Privacy Compliance Officer. Please note that a complaint should be directed in writing. We will not respond to complaints via email.
If our responses to your queries, concerns or complaints are unsatisfactory, you may contact the Privacy Commissioner of Canada at:
Office of the Privacy Commissioner of Canada
30 Victoria Street
Phone: (819) 994-5444
Fax: (819) 994-5424
TTY: (819) 994-6591