Policies and Disclosures
Code for the Protection of Personal Information
We are committed to respecting and protecting the privacy and confidentiality of our clients' personal information. We want you to know, in plain terms, 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 Beutel, Goodman & Company Ltd. and its affiliates and to all of the services and products Beutel Goodman provides to its clients. Reference throughout this Code to "we", "our" and "us" means Beutel, Goodman & Company Ltd.
Each 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 an agreement binding them to this responsibility.
We keep our employees informed about our policies and procedures for protecting personal information and we reinforce the importance of complying with them.
Beutel Goodman has designated a Privacy Officer. Requests for information or complaints should be directed to the Privacy Officer as listed below.
What Is Personal Information and What Personal Information Do We Collect?
The term "personal information" refers to information that can be used to directly or indirectly identify you as a person. It includes information that you provide or that we collect from other sources with your permission (for example, for anti-money laundering compliance purposes), or where required or permitted by law. We collect your personal information for the purposes detailed in the following section.
Where applicable, consent to the collection of your personal information may be express or implied, depending on the circumstances and the sensitivity of the data collected.
The types of personal information that we may collect include, for example: your name, address, age, gender, personal financial records, identification numbers including your social insurance number, personal references, and employment records, and banking information.
Personal information concerning the performance of your duties within an enterprise, such as your name, title, business address, business phone number, or business email are subject to this Code only as required by applicable law.
Why We Ask For Your Personal Information
We want to work with you as a client to help you achieve your financial goals, to provide you with value-added services 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 as a client. We will only collect your personal information to perform our duties with respect to our services for you. We identify the purposes for which we use your personal information, as well as the means by which we collect it, at the time we collect it from you (and subsequently upon request) and obtain your consent prior to such use.
We obtain personal information about you primarily from you. We may also obtain financially-related information from other sources with your consent (for example, for anti-money laundering identification.)
Personal information is required for the following purposes:
- To verify your identity and protect against fraud.
- To understand your financial service 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.
- To comply with applicable laws and securities regulations.
- To access your account on our website.
- For other purposes for which we have obtained your consent, or as otherwise permitted or required by applicable laws.
- To process payments or withdrawals to and from your bank account.
For example, in the case of discretionary investment management accounts, we ask for detailed personal information to ensure that the investment products you are invested in are appropriate for you and suitable for your circumstances. 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 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.
Your Rights and How to Exercise Them
In accordance with applicable laws and where applicable, you have the following rights:
- To access: you may access information relating to the collection, use or disclosure of your personal information and obtain a copy of your personal information, the categories of persons who have access to your personal information, and the duration of the period of time your personal information will be kept.
- To rectify: if you believe your personal data we have on file is inaccurate, incomplete or unclear, or that our collection, communication or keeping of your personal information is not legal, you may ask us to correct your personal information.
- To withdraw your consent: where you provided consent to our use or disclosure of your personal information, you have the right to withdraw such consent at any time.
To exercise any of these rights, please contact our Privacy Officer by mail or by email. We may further request proof of your identity in order to process your request. Any such information will be used exclusively for this purpose. As noted above, if you withdraw your consent to use or disclosure of your personal information, 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.
In the event that we refuse your request for access or correction of your personal information, we will provide you with a written explanation not later than 30 days after the date the request is received, which will include reference to any applicable laws, remedies available to you and relevant time limits. On your request, we will assist you in understanding our response.
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. Where appropriate, we will advise others of any important amendments to your personal information that we may have released to them.
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, where lawful and necessary, disclose the challenge to third parties who also possess that personal information. If you successfully prove that the personal information we have on file is inaccurate, incomplete or unclear, or that our collection, communication or keeping of this information is not legal, we will amend your personal information as requested. Where appropriate, we will also provide the amended information to third parties who have access to your personal information.
Where applicable, you may also file a complaint with the competent supervisory authority in your jurisdiction.
Releasing Your Personal Information
Beutel Goodman does not sell your personal information to third parties nor will we disclose your personal information to third parties other than in the following circumstances or for the following purposes (and with your consent, where required):
- In connection with normal business operations to open, maintain, administer, or service your account. This includes the delivery of materials and the storage of account information and documentation in databases (including in the cloud), 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 delivery of account statements and reviews, and record-keeping services), or for audit or statistical purposes.
- To inform entities within the Beutel Goodman group of affiliated companies, in order to offer and provide you a wider range of services and better service your customer service expectations, to ensure that any updated contact information you provide is processed efficiently, and to engage in surveillance, compliance, and reporting activities required by applicable law.
- To advise legal counsel for the purpose of obtaining legal advice.
- Where we are required or permitted to do so by law, including to any law enforcement agency, securities regulatory authority or self-regulatory organization.
- In connection with offers made to Beutel Goodman customers or prospective customers, or other promotional activities or service offerings engaged in by Beutel Goodman where (A) third party product or service providers assist Beutel Goodman or otherwise participate in fulfillment of the offer or provision of the service; (B) Beutel Goodman has contracted with a third party for the fulfillment of the offer or provision of the service or otherwise has an ongoing business relationship with such third party; (C) fulfillment of the offer or provision of the service requires disclosure of certain limited personal information for fulfillment purposes only to such third party; (D) the disclosed personal information is to be used for fulfillment purposes only and the third party agrees not to disclose the personal information to others, or (E) in an aggregated form for the purpose of analyzing statistics and metrics about Beutel Goodman’s business and operations.
- To protect our operations or those of any of our affiliates or subsidiaries.
- To protect our rights, privacy, safety or property, and/or those of our affiliates, you or others.
Our third party service providers will access your Personal Information solely to carry out their respective mandates. In particular, we require that third party service providers maintain the confidentiality of your Personal Information and keep your Personal Information secure. We also require that they only use your Personal Information for the limited purposes for which it is provided.
When our third party service providers no longer need your personal information for those limited purposes, for example upon expiry of their mandate, subject to any applicable retention requirements, we require that they dispose of the personal information. We do not authorize the third party service providers to disclose your personal information to unauthorized parties or to use your personal data for their direct marketing purposes.
The third parties to whom we may disclose your personal information as part of our business operations include: custodians of client accounts; for the Beutel Goodman Managed Funds, RBC Investor Services Trust as custodian, registrar and fund accountant; PriceWaterhouseCoopers LLP as firm and fund auditors; third party dealers; tax, securities or other relevant regulatory authorities; in connection with brokerage and trading; and legal advisors. If you would like more information about our third party service providers, please contact our Privacy Officer.
By opening or maintaining an account with Beutel Goodman 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. If we otherwise intend to disclose your personal information to a third party, we will identify that third party and the purpose of the disclosure, and obtain your consent.
Transfers of Personal Information Outside Canada
For Quebec residents: as a result, your personal information may be communicated outside Quebec.
Keeping Your Personal Information Confidential and Secure
Personal information is protected at Beutel Goodman by safeguards to protect against loss or theft, 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, we provide 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 confidential and used only for the purposes of the contract.
We have 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.
We also apply the terms of this Code to any personal information you provide in connection with use of our website Portal to view your account information. However, you are solely responsible for ensuring the secrecy of your login credentials, including your username, password and other account information. Please do not disclose or share your username or password.
Despite these measures, no method of information transmission or information storage is 100% secure or error free, and we cannot guarantee security. If you have reason to believe that your interaction with us is no longer secure (for example, if you believe that the security of any information that you provided to us has been compromised), please contact us immediately.
Retention of Your Personal Information
We retain your personal information for as long as required to achieve the purposes for which it was collected, and as permitted or required by law, or until you exercise your right to withdraw your consent to the use, disclosure or retention of your personal information. The length of time we retain your personal information depends on: the type of product or service provided; and applicable legal and/or regulatory requirements.
For example, we must be able to respond to any concerns you may have, even if you are no longer a client. To the extent permitted or required by law, we will remove personal information from our records in a manner consistent with applicable regulatory requirements.
Confidentiality Incidents Concerning Your Personal Information
In the event of a confidentiality incident concerning your personal information, we take reasonable measures to reduce the risk of injury and to prevent new incidents from occurring.
We will notify you, the federal privacy commissioner or applicable provincial privacy authority and, in some cases, counterparties, regulators or others, if required by law or if we believe that a breach in safeguarding your personal information has occurred that creates a risk of serious injury to you or a real risk of significant harm. We may not notify you of a confidentiality incident if doing so could hamper an investigation conducted by a person or body responsible by law for the prevention, detection or repression of crime or statutory offences.
We may also notify any person or body that could reduce the risk from an incident. If so we will communicate only the personal information necessary for that purpose and will apply the safeguards and recordkeeping described in this Code.
If you have any questions, comments, concerns or complaints regarding our use of your personal information under this Code, or you wish to submit a written request to access or update your personal information or otherwise exercise your legal rights, you can contact our Privacy Officer at:
Beutel, Goodman & Company Ltd.
20 Eglinton Avenue West, Suite 2000, P.O. Box 2005
Toronto, Ontario M4R 1K8
Beutel Goodman reserves the right to update this privacy code at any time. We invite you to regularly consult this Code to ensure you are aware of any changes. Changes take effect from the moment we publish the revised Code. Your continued use of our website and our interactive functions will be subject to the Code then in effect.
DATE OF LAST UPDATE: September 22, 2023