Accountability
Forum Asset Management Inc. (“Forum”) acknowledges the importance and necessity of safeguarding non-public personal information (“NPPI”) belonging to clients. Forum’s Chief Privacy Officer has been appointed to ensure compliance with privacy legislation and to inform all Forum staff of the need to use the utmost discretion when dealing with client information. Forum’s Chief Privacy Officer ensures Forum staff receive the appropriate training required under applicable laws. Forum’s Chief Privacy Officer has the responsibility to carefully analyze and alter collection procedures to assure maximum privacy protection.
Identifying Purposes
NPPI is collected in order to determine a client’s identity, establish a client’s eligibility for a product or service, to protect all parties against errors or fraud (e.g., money laundering), to comply with legal requirements (e.g., anti-terrorism legislation) and to communicate with the client (e.g., sending annual financial statements of the funds managed by Forum). Forum commits to using NPPI solely for the purposes identified at the time of its collection.
Consent
Forum will not disclose any NPPI, except as required by law, without first asking for a clients’ informed consent. In most cases, consent is obtained via the subscription agreement process for client investments in funds managed by Forum. If information is required for any use not described at the time of collection, Forum will take the necessary steps to seek additional consent. Consent may be expressed in writing, orally or may be implied directly by the client or the client’s authorized representative. Consent to use NPPI may be withdrawn at any time by contacting Forum’s Chief Privacy Officer. Note however that legal or other requirements may prevent clients from withholding consent and a decision to withhold personal information may limit the services or products that Forum can provide to the client.
Limiting Collection
Forum will only collect NPPI for specific purposes. Forum will do its best to explain in a clear and informative fashion why the collection of personal information is necessary. Forum does not collect any NPPI from visitors browsing its website, although disclosure of some personal information may be required if a visitor chooses to send Forum an email message.
Limiting Use, Disclosure and Retention
Forum may be required to share NPPI with other parties as required by law (e.g., for tax reporting purposes to the government) and with third parties who provide services to Forum (e.g., unitholder registration, administrative services, technological services, client statement preparation and mailing). Forum has agreements with these third-party service providers to ensure the proper handling and protection of personal information. Forum may also be required to provide client information when responding to a search warrant, court order or other legally valid request.
Forum will only retain NPPI for as long as it is needed in order to satisfy the stated purposes at the time of collection. When the information is no longer required, we will take the necessary measures to destroy, dispose of, or erase the information, subject to any other legal or regulatory requirements. If a client decides to terminate their relationship with Forum, we will continue to adhere to the privacy policies and practices outlined in this Policy.
Accuracy
Forum strives to ensure that client information is always accurate. Clients are requested to monitor any information provided to them for errors and advise the Forum Chief Privacy Officer or their Forum representative for prompt correction.
Openness
Forum actively attempts to explain its policies, procedures and methods on managing NPPI to its clients. Forum’s Privacy Policy can be found on our website (https://forumam.com/privacy) or can be requested via email or phone and will be provided at no charge. If clients have any additional questions, the Chief Privacy Officer will do their best to help them understand Forum’s policies and procedures.
Individual Access
Individuals have the right to verify the accuracy and completeness of their personal information and may request that it be amended. When requested, and supported by appropriate identity information, Forum will provide clients with their NPPI maintained in its files. Under certain circumstances, Forum may not be able to provide clients with access to specific pieces of information, if, for example (i) the information contains references to other persons, (ii) the information contains proprietary information confidential to Forum, (iii) the information has been destroyed or (iv) the information is too costly to retrieve.
Safeguards and Reporting of Breaches
Forum has established policies, procedures, guidelines and security measures in order to ensure that NPPI is protected against unauthorized access, theft or improper disclosure. Security measures include controlled access to Forum’s office and records within the office, password requirements to access Forum’s networks and systems and restricted access to information stored in Forum systems. All Forum staff are subject to privacy procedures when dealing with NPPI and are responsible for ensuring the confidentiality of any information that is accessed.
As required by law, Forum will record any breach of security safeguards involving NPPI under its control and will report such a breach to the appropriate regulatory body and/or applicable organization if there is a real risk of significant harm to any affected individual. Forum will also notify affected individuals if the circumstances are such that it is reasonable to believe that the breach creates a real risk of significant harm to the individual. The notification to an individual will contain sufficient information to allow them to understand the significance of the breach and to take steps to reduce the risk of harm that could result from it. The notification will also contain any other information as prescribed by regulation or law.
Questions and Concerns
Questions about this policy or concerns about potential misuse of NPPI should be addressed to Forum’s Chief Privacy Officer and will be dealt with in a timely fashion. If an individual is not satisfied with Forum’s actions, a complaint can be made to the attention of the Canadian federal Privacy Commissioner.
Forum Chief Privacy Officer
Nadia Somani
Tel: 437-518-5994
Email: nadias@forumam.com
Mail:
Forum Asset Management Inc.
181 Bay Street, EP 210
Toronto, Ontario M5J 2T3