Protecting Client Information

Succession Strategies Group Inc. considers protection of its clients’ information an important part of its business. Ensuring that it holds confidential all information respecting its clients’ financial affairs is an operational imperative. Succession Strategies Group Inc. has long-standing security measures in place to preserve the confidentiality of sensitive information, including personal information received on behalf of its clients.

Background

The federal government has passed legislation dealing with the collection, use and disclosure of information about any identifiable individual. This legislation is called the Personal Information Protection and Electronic Documents Act or PIPEDA, and applies to commercial activities across Canada that collect, use and/or disclose personal information, except in those provinces that have passed substantially similar legislation. In those jurisdictions, the substantially similar provincial legislation will apply.

Scope of this Policy

This policy sets out ten principles that will be observed by Succession Strategies Group Inc. in the collection, use and disclosure of information of clients. If personal information is made anonymous by removing details so that an individual is not identifiable to the user or recipient of that information, it is not governed by this Policy but still will be treated with appropriate safeguards. Succession Strategies Group Inc. collects personal information for the purpose of providing its clients with investment and financial counseling services. It obtains consent at the time of gathering of the information.

Accountability

Succession Strategies Group Inc. is responsible for all personal information under its control and its Personal Information Protection Officer (“PIP Officer”) is accountable for Succession Strategies Group Inc. compliance with the principles described in this Policy. The PIP Officer for Succession Strategies Group Inc. may be contacted at 905-456-0649.

Identifying Purposes

Succession Strategies Group Inc. will identify the purposes for which personal information is collected at or before the time the information is collected. Succession Strategies Group Inc. will also document the purposes for which personal information is collected.

Consent

The knowledge and consent of the individual, express or implied, are required for the collection, use or disclosure of personal information. Consent may be given orally or in writing. The type of consent obtained relates to the sensitivity of the information disclosed. For example, when we collect information relating to your discretionary portfolio, we obtain your express written consent to its collection and use.

Limiting Collection

Succession Strategies Group Inc. will limit the amount and type of personal information collected to that which is necessary for the purposes identified by Succession Strategies Group Inc. . The personal information will be collected by fair and lawful means.

Limiting Use, Disclosure and Retention

Succession Strategies Group Inc. will not use or disclose personal information for purposes other than those for which it was collected, except with the consent of the individual or as required or permitted by law. For example, you have authorized us to place orders with brokers, investment dealers, banks, trust companies and other financial institutions for the purchase and sale of securities. Personal information will be retained only as long as necessary for the fulfillment of those purposes. New uses and disclosure require new consent.

Accuracy

Succession Strategies Group Inc. will keep personal information as accurate, complete, and up-to-date as is necessary for the purposes for which it is to be used. Succession Strategies Group Inc. will minimize the possibility that inappropriate information is used to make a decision about the individual.

Safeguards

Succession Strategies Group Inc. will protect personal information with security safeguards appropriate to the sensitivity of the information to protect it against loss, theft, unauthorized disclosure, copying use or alteration.

Openness

Succession Strategies Group Inc. will be open about its policies and procedures with respect to management of personal information. Succession Strategies Group Inc. will ensure that individuals are able to acquire information about Succession Strategies Group Inc.’s policies and procedures without unreasonable effort. Succession Strategies Group Inc. will make this information available in a form that is generally understandable.

Individual Access

Upon a client’s request in writing, Succession Strategies Group Inc. shall inform a client of the existence, use, and disclosure of his or her personal information and the client shall be given access to that information, except where the law requires or permits Succession Strategies Group Inc. to deny access.

Challenging Compliance

An individual will be able to direct a challenge concerning compliance with the above principles to the designated individual or individuals accountable for Succession Strategies Group Inc’s compliance, including the Succession Strategies Group Inc. Privacy Officer. Individuals may also make a complaint to the Privacy Commissioner.