CI Investments follows the fundamental principles of privacy protection contained in the Personal Information Protection and Electronic Documents Act (“PIPEDA”). We are committed to respecting the privacy rights of everyone whose personal information we have collected.
Questions, concerns or complaints?
If you have any questions, concerns or complaints regarding matters of privacy, please contact CI Investment’s Privacy Office.
2 Queen Street East 20th Floor, Toronto, Ontario, M5C 3G7
We collect personal information for various reasons. Usually, it relates and to meeting our regulatory, legal or contractual requirements relating to providing asset management and administrative services to you.
What personal information do we collect?
We collect personal information that is required to provide fund management and administrative services, which is collected on CI Investment applications and forms including, but not limited to name, date of birth, Social Insurance Number (“SIN”), personal financial information and contact information.
We also collect information about your interactions with us when engaging our services through our website and Client Services department in order to responds to your inquiry and provide you our services. As part of account operations, we also generate information which may include your personal information such as account numbers, market values account statements and tax receipts.
We record telephone calls to our Client Services and Operations groups for evidence of instructions, quality assurance and training purposes.
How do we collect personal information and obtain your consent?
We collect personal information about you: (i) from application forms and other information provided by you or your advisor in writing, by telephone, in person, electronically or by other means; (ii) from your activity on the web site and transactional activity in your accounts, including account balances, investments, withdrawals and fees/commissions; (iii) through your advisor and (iv) from other interactions with us, such as discussions with our staff.
Wherever possible, we seek a person’s consent before we collect their personal information. The form of consent may vary depending on the circumstances and the type of information being requested. Consent can be express or implied, and can be provided directly by the individual or by an authorized representative, such as your financial advisor or their dealership.
The information may be collected via our application form, in which case you will formally indicate your consent for us to collect and use the personal information when you sign the application. The information may also be provided to us by your financial advisor, in which case, by virtue of account opening, your consent is implicitly provided to us to collect and use the information. In this case, at the time of initial collection of your personal information by your financial advisor, you will have provided consent to your advisor to disclose your personal information for the purposes of effecting investment transactions, including the opening of accounts with us.
How do we protect your personal information?
We will maintain the security and confidentiality of personal information under our control by maintaining appropriate technological, procedural and organizational safeguards to protect your personal information against unauthorized access, theft or misuse.
To whom do we disclose your personal information?
Access to personal information within CI Investments will be restricted to those staff members who need the information in order to carry out their job duties. Those employees will maintain the information in the strictest of confidence and will not provide access to the information to anyone who is not authorized.
Third parties that may also be provided with your personal information include:
Third-party service providers;
Your financial advisor and/or their dealership
Your legal representatives;
Other financial institutions, securities dealers and mutual fund companies;
CI Investment’s affiliates;
Canadian, provincial and municipal governments, government agencies and regulators (for example Canada Revenue Agency or the Ontario Securities Commission) as required by law or legal process; and
Authorities investigating (or who could potentially investigate) alleged fraudulent or suspicious transactions in relation to your account or any other account on which you are authorized to act.
We do not sell your personal information to third parties.
Where is your personal information kept?
Your personal information may be kept in electronic or paper format in our offices, in secure off-site storage facilities, or in the offices of our service providers. We may store your personal information via third party entities that reside in foreign jurisdictions. Information may be transferred to, accessed and/or retained by third parties pursuant to data storage agreements that are necessary to provide you services. We and/or a third party may be compelled, by law or otherwise, to provide information to a third party, subject to applicable privacy law. We must abide by applicable privacy legislation in the jurisdiction(s) in which we operate.
How can you access or correct your personal information held by CI Investments?
Individuals do not always need to use their right under PIPEDA to access to or correct their personal information (e.g. informal request) with CI Investments. Clients are encouraged to contact our Client Services department to correct their information. However, subject to certain restrictions, you have the right to formally request access or corrections of your personal information. To make a formal request for access send a written request addressed to our Privacy Officer (contact details below). Please include your full name, address, telephone number and account number(s) on any correspondence to us and provide enough detail to allow us to identify the information you want.
Upon request, we will provide you with access to your personal information we have on record at the time of the request. Please note that we may not be able to provide you with this information in certain circumstances, for example, where such information: contains references to other persons; contains proprietary information confidential to us or your financial advisor; has been destroyed or is too costly to retrieve; is subject to legal or some other form of privilege; or cannot be disclosed for legal reasons or relates to an investigation.
Withdrawing your consent
Subject to certain restrictions and reasonable notice, you may withdraw your consent for the collection and use of your personal information at any time by forwarding a written request to our Privacy Officer. Please include your full name, address, telephone number and account number(s) on any correspondence to us.
In some circumstances, legal requirements may prevent you from withholding consent. In addition, your decision to withhold consent may also limit the products and services that we may provide to you and may require you to close your accounts with us.
How long do we keep your information?
We only keep your personal information as long as it is necessary to do so. The length of time we keep your information will depend upon the product or service and the nature of the information and will be only as long as it is legally necessary for us to retain sufficient information to respond to any inquiries that may arise later.