“Personal Information” is defined as information about an “identifiable individual”. This includes such things as income, assets, education, home address, phone number, and age. It does not cover general contact information such as business address, business phone number…etc. which may otherwise be publicly available.
As a result, the Personal Information that ZLC collects for completion of the Know Your Client Form and other documents related to your account is subject to the requirements of the Act. ZLC recognizes the importance of privacy and recognizes the sensitivity of personal information received by it in the conduct of its business. This policy has been prepared with this objective in mind.
What personal information we collect:
We collect the following types of information:
- Identification and contact information such as your name, address, telephone, cellular, and fax numbers, email address, date of birth, social insurance number, and other identification information required for anti-money laundering and income tax compliance purposes.
- Personal information such as your citizenship, residency, marital status, and spousal information.
- Financial information such as your income, net worth, and investment profile.
- Employment information, such as your employer, industry, and occupation.
- Information pertaining to any legal entity accounts such as Trust Deeds, Articles of Incorporation, Shareholder Registries, Partnership Agreements, or other documents which are pertinent based on the account being opened.
- Information about your accounts with other financial institutions from which we may transfer assets to your account with ZLC or external banking information when you have requested this information be linked to your ZLC account.
- Other information which may be related to your account(s) or specific transaction(s) you request for your account.
Why we need access to personal information
To provide financial services to our clients, we need access to accurate facts and information related to their personal and business finances. As a regulated entity, ZLC is required by law or regulation to obtain certain information about you while providing products and services to you. We ask you for your financial, employment, and other information to fulfill our “Know Your Client” obligation which is a key principle under all provincial securities regulations. We also collect transactional and other information to meet our securities regulatory gatekeeper obligation and obligation to report suspicious transactions to anti-money laundering and anti-terrorist financing authorities.
How we collect, use and disclose personal information
Wherever practical, we collect personal information directly from the person to whom the information pertains. If necessary, we may collect personal information from other sources. By using ZLC’s services, you consent to our necessary collection, use, or disclosure of your personal information to properly serve you as our client.
The choice is always yours as to whether to provide us with your information, however, if you decide to withhold certain information, we may be unable or restricted in our ability to provide the products, services, or information you have requested.
We do not rent or sell your personal information to third parties, but in limited circumstances, your personal information may be shared with third parties with whom we have a business relationship. For example, we share your personal and account information with third parties who provide services to ZLC such as our client account custodian, and portfolio management software providers. Our third-party service providers only have access to the information necessary to perform their services. The third-party service provider will also be subject to the privacy laws of the jurisdiction in which they are located. In addition, we may share your personal information with our affiliated entities if necessary to
Personal and account information may be shared with product providers such as securities issuers including fund companies with whom we transact on your behalf.
BC’s Privacy Act deems you to have consented to our collection, use, or disclosure of your personal information if our purpose at the time would be considered obvious to a reasonable person. In these circumstances, we will collect use, or disclose personal information without obtaining your written or verbal consent. The Act also permits us to collect, use or disclose personal information in some circumstances without an individual’s consent.
These include, but are not limited to, circumstances where:
- The personal information is available to the public from a prescribed source.
- The collection, use, or disclosure of personal information is required or authorized by law.
- When we collect, use or disclose any personal information, we make reasonable efforts to ensure that it is accurate and complete.
Protecting the security of personal information
We recognize our professional and legal obligations to protect the confidential or personal information our clients provide to us while conducting business with ZLC. To ensure we meet these obligations, we have implemented policies and procedures to secure against the unauthorized access, collection, use, disclosure, copying, modification, disposal, or destruction of personal information.
Requesting access to personal information
BC’s Privacy Act permits you to submit written requests to us to provide you with:
- A record of the personal information under our custody and control.
- Information about how we are using, or have used, personal information under our control and the purposes for which it was used.
- The names of individuals and organizations to whom we have disclosed personal information under our control and the circumstances under which the personal information was disclosed.
The Act provides that we must not disclose personal information where:
- The disclosure could reasonably be expected to threaten the safety, the physical or mental health of an individual other than the individual who made the request.
- The disclosure would reveal personal information about another individual and consent is not obtained.
- The disclosure would reveal the identity of an individual who has, in confidence, provided us with an opinion about another individual, and the individual providing the opinion does not consent to the disclosure of his or her identity.
The Act further provides that we may choose not to disclose personal information where:
- The personal information is protected by any legal privilege.
- The disclosure of the information would reveal confidential commercial information, and it is not unreasonable to withhold that information.
- The personal information was collected by us for an investigation or legal proceeding.
- The disclosure of personal information might result in similar information no longer being provided to us when it is reasonable that it would be provided.
- The personal information was collected or created by a mediator or arbitrator in the conduct of a mediation or arbitration for which he or she was appointed to act under an agreement, under an enactment, or by a court.
- The personal information relates to or may be used in the exercise of prosecutorial discretion.
The above examples are not exhaustive, and you are encouraged to examine the provisions of the Act for a complete list.
Requesting corrections to personal information
An individual may submit a written request to us to correct errors or omissions with respect to their personal information that is in our custody or control.
Upon receiving a request to correct your personal information, we will:
- Correct the personal information and, if reasonable, send correction notices to any other organizations to whom we disclose the incorrect information
- Decide not to correct the personal information but annotate the personal information to indicate a correction was requested but not made.
Contacting or Communicating with Us
If you have any questions with respect to our policies concerning the handling of your personal information, or if you wish to request ZLC to provide a copy of, or make a correction to, your personal information under our care and control, please contact ZLC’s Chief Compliance Officer at: