Policies and procedures to protect personal information
If you have any concern or complaint about our personal-information handling practices, please contact Lucie Larocque at 1-705-424-7979 or by email at email@example.com. Every concern or complaint will be considerate and where it is found to be warranted, we will take appropriate measure and amending our policies and practices, when necessary.
Checklist to ensure that we meet fair information practices:
- What personal information do we collect?
- Why do we collect it?
- How do we collect it?
- What do we use it for?
- Where do we keep it?
- How is it secured?
- Who has access to or uses it?
- To whom is it disclosed?
- When is it disposed of?
All information of our clients financial picture including family dynamics, risk, lifestyle, financial resources, personal and financial goals (investments, insurance, taxation and estate planning documents).
We believe must be obtained in order to properly create a comprehensive wealth plan.
During our appointments with the client at their home or office and clarifications over the phone.
We use our discovery process. During our first and second appointment we ask questions to our clients.
All information is keep in our business computer, that have no access to the internet and back-up are done on a removable disk that is keep in a fire-save. Paper files are locked in a filing cabinet located in our office.
You need a password to enter into the computer and to have access to the information on the removable disk, which is keep in a locked fire-save. You also need a different password to have access to each client file.
Nobody have access to the information other than people who work for LaRocque Wealth Solutions Inc.
The information is only disclosed to the client. This information is disclosed to other professional only with client’s consent.
All information is keep for 7 years as requested by law. Then all paper files are shredded and electronic records are deleted.
2. Identifying purposes
Personal information is collected to ensure that we have all information necessary to accomplish our assignments . We believes in collecting and using personal information responsibly. The information collected will be used only for the purpose outlined in the engagement letter signed by both parties, client and us. We will not use or disclose it for any purpose other than those for which it was collected. We notify our client, either orally or in writing, of the purposes of collecting information. We record all identified purposes and obtained consents for easy reference in case a client requests an account of such information.
The knowledge and consent of the client are required for the collection, use, and disclosure of personal information, except as permitted by law or for security reasons. A client may withdraw consent at any time on providing us with reasonable notice. The implications of withdrawal may prevent us from providing you with the services previously agreed upon. Relying on express consent protects both the client and the organization. Consent can be obtained in person, by phone, by mail, via the internet. All consent received are recorded in note to file or copy of e-mail.
4. Limiting collection
The collection of personal information is only to the extent necessary for the purposes to complete the assignment. The personal information is collected using only lawful means. All information of our clients financial picture including family dynamics, risk, lifestyle, financial resources, personal and financial goals (investments, insurance, taxation and estate planning), need to be collected in order to create a comprehensive wealth plan (comprehensive financial plan).
5. Limiting use, disclosure, and retention
Personal information will not be used or disclosed for purposes other than those for which it was collected, unless the client consents to use or disclosure for another purpose or as required by law. Client information is use to communicate with you, with various government agencies on your behalf and/or with your other professional, with your express consent. As required by law, client information is kept for seven years from the final closing of the client file, or the last service was provided to the client. Every year, we process a verification of client information that need to be destroyed, erase or render. All paper files are shredded and electronic records are deleted. At a minimum we annually check in with our clients to determine if there have been any material changes in their circumstances. Reviews are critical to ensure that our clients are on track to meet their goals. The purpose of these periodic meetings is to identify any event or circumstance that can have an impact on our client’s comprehensive wealth plan, and recommend changes to the plan as necessary.
We have a responsibility to ensure that all personal information is accurate, complete and up-to-date in order for us to complete assignments and to continue communication with you on regular basis. Clients may request that their personal information be modified as appropriate. Each time information is obtained or updated, we record the date.
Our checklist for accuracy:
- List specific items of personal information required to provide a service.
- List the location where all related personal information can be retrieved.
- Record the steps taken to verify accuracy, completeness and timeliness of the information. This may require reviewing your records or communicating with the client.
See each services in LaRocque Wealth Solutions Inc. procedure.
All information can be retrieved from our back-up on the removable disc.
At a minimum, we updated (verify accuracy) our file one a year. We have 30 days to complete a comprehensive wealth plan or any component of a plan. We follow our action step on our calendar for timeliness.
Security safeguards are in place to protect personal information. All staff are required to follow procedures with respect to maintaining confidentiality of our clients’ non-public information. Also we maintain physical, electronic, and procedural safeguards to protect the information.
Our security policy to protect personal information.
Our physical measures: Locked filing cabinets and restricted access to offices
Our technological tools: Passwords to open the computer, to open programmes, to open client’s files. We have firewalls to prevent virus.
Organizational controls: Employees are aware of the importance of maintaining the security and confidentiality of personal information. Staff are aware that personal information should not be left displayed on their computer screens or desktops in their absence. Also that client’s file should not be left on their desk in their absence. Staff are aware that they should properly identify individuals and establish their right to access the personal information before disclosing it. Staff are train on procedures and sign agreements. Each year our procedures are reviewed and updated with our staff. Staff are not permitted to delete personal information without my request. If staff add or change personal information, we record the date.
When transferring personal information to third parties, we ensure that they:
- Name a person to handle all privacy aspects of the contract.
- Limit use of the personal information to the purposes specified to fulfil the contract.
- Limit disclosure of the information to what is authorized by your organization or required by law.
- Refer any people looking for access to their personal information to your organization.
- Return or dispose of the transferred information upon completion of the contract.
- Use appropriate security measures to protect the personal information.
For third party transfers, we make sure personal information that has no relevance to the transaction is either removed or blocked out when providing copies of information to others. We also included a letter limiting the third party’s use of information to purposes necessary to fulfil the assessment.
We will make available to clients specific information regarding the policies and practices used to manage their personal information. This information is available in person, in writing, by telephone, on our Web site. We do not disclosed to other organizations any information, we are completely independent. If we need to contact other professional, we request the client consent first.
Person accountable: Lucie Larocque
Requests or complain should be sent to: 45 Nottawasaga dr. Angus ON L0M 1B0 or e-mail firstname.lastname@example.org
9. Individual access
Clients may request in writing access to their personal information. We will provide a copy of the information requested. We will inform the client of the existence, use as well as identify any professional to which the information has been disclosed. When a client is able to challenge the accuracy and completeness of personal information, the information will be amended as appropriate. We will note any disagreement on the file and advise third parties where appropriate.
We provide any help the individual needs to prepare a request for access to personal information (see template request to personal information). We will respond to the request as quickly as possible and no later than 30 days after receipt of the request. The normal 30-day response time limit may be extended for a maximum of 30 additional days, according to specific criteria set out at Subsection 8(4) of the Act:
- if responding to the request within the original 30 days would unreasonably interfere with activities of your organization
- if additional time is necessary to conduct consultations
- if additional time is necessary to convert personal information to an alternate format.
If we extend the time, we notify the individual making the request within 30 days of receiving the request. There is no cost if it take less than an hour to gather the information, otherwise it’s a fee of $25.00 which the client will be notify before processing the request and confirm that he/she still wants to proceed with the request. We never disclose personal information unless you are sure of the identity of the requestor and that person’s right of access. We record the date of receipt of the request for the information.
10. Challenging compliance
If you would like to make an inquiry, suggestion or challenge our compliance regarding our personal information practices, please contact us at 1-705-424-7979 or by e-mail at email@example.com.
- Record the date a complaint is received and the nature of the complaint (e.g. delays in responding to a request, incomplete or inaccurate responses, or improper collection, use, disclosure or retention).
- Acknowledge receipt of the complaint promptly.
- Contact the client to clarify the complaint, if necessary.
- We investigate all complaints received.
- Record all decisions.
- We handle a complaint fairly and appropriately to preserve or restore the client’s confidence.
- We take appropriate measures to correct information handling practices and policies.
- Notify clients of the outcome of investigations clearly and promptly, informing them of any relevant steps taken.
- Correct any inaccurate personal information or modify policies and procedures based on the outcome of complaint, and ensure that staff in the organization are aware of any changes to these policies and procedures.