Privacy Policy

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.

Employee Responsibilities

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 the Chief Compliance Officer as Privacy Officer. Requests for information or complaints should be directed to the Compliance Department

What Is Personal Information?

The term "personal information" refers to information that specifically identifies you as an individual. It includes information that you provide or that we collect from other sources with your permission. For example: your name, address, age, gender, personal financial records, identification numbers including your social insurance number, personal references, and employment records. It does not include a name, title, business address, business phone number or business email which is publicly available.

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 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.  We will only collect your personal information to perform our duties with respect to our services for you. 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, and
• To comply with all laws and securities regulations.

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.

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, you can ask at our office address below. 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.

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

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:

• In connection with normal business operations to open, maintain, administer, or service your account. This includes the mailing of materials and the scanning of account documentation into customer databases, 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 reviews, and record-keeping services), 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.

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.

Keeping Your Personal Information Confidential

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 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 retain your personal information for as long as required 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 provided;
• 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. We have retention policies in place that govern the destruction of personal information.

Notification of Breach in Safeguarding Your Personal Information

We will notify you, the federal privacy commissioner 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 real risk of significant harm to you.

Your Opinion

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:

• You give us at least sixty (60) days written notice;
• There are no legal requirements for the use of your personal information; and
• We can continue to fulfill our contractual obligations to you.

If you would prefer not to receive offers of other Beutel Goodman products and services that may be of interest to you, you can have your name deleted from these client lists.

Please direct questions, requests or complaints in writing to the attention of:

Compliance

Beutel, Goodman & Company Ltd.
20 Eglinton Avenue West, Suite 2000, P.O. Box 2005
Toronto, Ontario M4R 1K8
compliance@beutelgoodman.com

Beutel Goodman reserves the right to update this privacy code at any time.