Privacy Policy
As of January 1, 2004, organizations in Canada that collect, use or disclose personal information in the course of commercial activities will have to comply with the federal Personal Information Protection and Electronic Documents Act ("PIPEDA"). As required by the legislation, ZBM Financial Planning and Sterling Mutuals Inc. (Sterling) have put in place policies and procedures to effectively safeguard any confidential information that we have on file or collect going forward. To meet our obligations, we closely follow the ten fundamental principles set out under PIPEDA.
1. Accountability
Zaid Mohammed is ultimately responsible for personal information under the control of ZBM Financial Planning. In addition, Sterling Mutuals Inc. is accountable for compliance with the terms and procedures of its’ Privacy Policies. Any individual that wishes to challenge ZBM Financial Planning's procedures, or wishes to make a complaint about ZBM Financial Planning's personal information handling practices should contact him directly at 1-866-880-9166 ext. 3351 or by email. Every complaint will be investigated and where a complaint is found to be justified, Zaid Mohammed will take appropriate measures, including amending policies and practices, when necessary.
2. Purpose of Collecting Personal Information
ZBM Financial Planning will identify the purposes for which we collect the personal information before or when we ask for the information. We will not use or disclose this information for any other purpose other than those for which it was collected, unless required by law or regulation.
We collect personal information to ensure that we have all information:
- to operate an account
- to provide additional services requested by the client
- to properly report account status back to the client
- to provide all required tax reporting
- to properly discharge my regulatory responsibilities with respect to suitability assessment and other investing and insurance rules
- to properly discharge my obligations under federal anti-money laundering and suppression of terrorism legislation
- to meet our obligations of standards of practice as a members of professional organizations
For regulatory purposes, self regulatory organizations, including the Mutual Fund Dealers Association of Canada, and the Canadian Investor Protection Fund (collectively, "SROs") require access to personal information of current and former clients, employees, agents, directors, officers, partners and others that has been collected or used by Regulated Persons. SROs collect, use or disclose such personal information obtained from Regulated Persons for regulatory purposes, including:
- Surveillance of trading-related activity,
- Sales, financial compliance, trade desk review and other regulatory audits,
- Investigation of potential regulatory and statutory violations,
- Regulatory databases,
- Enforcement or disciplinary proceedings,
- Reporting to securities regulators, and
- Information-sharing with securities regulatory authorities, regulated marketplaces, other self-regulatory organizations and law enforcement agencies in any jurisdiction in connection with any of the foregoing.
3. Client Consent
A Privacy consent form is provided to every new client. Consent may also be required for certain products or services subsequent to account opening. An authorized representative of the client (such as a legal guardian or a person having power of attorney) can give consent. A client may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice.
4. Limiting Collection
We collect personal information only to the extent that is necessary for the purposes identified above. The personal information is collected using policies and procedures that are fair and lawful.
5. Limiting Use, Disclosure and Retention
ZBM Financial Planning will use or disclose personal information only for the reasons it was collected, unless a client provides consent to use or disclose it for another reason, or law requires it. Client information on file will be kept for the standard period of seven years from the final closing of the client file, or the date the last service was provided to the client.
The type of information we collect is limited to the following
- the fundamental "know your client" information contained in the Sterling New Client Application Form
- standard information contained in Life Insurance applications
- information required for tax reporting purposes
- information required to meet anti-money laundering and suppression of terrorism requirements
- other information required to meet obligations imposed by securities regulations, SRO rules or other laws
This information may be made available to related companies or third-party service providers to fulfill the purposes for which it has been collected.
The information may also be disclosed to SROs, which may use the information to review, monitor, audit or investigate Zaid Mohammed's compliance with rules. The information provided to the SROs may, in turn, be reported to other regulators, regulated marketplaces, other SROs or law enforcement agencies.
6. Keeping Information Accurate
ZBM Financial Planning has a responsibility to ensure that all personal information on file is accurate, complete and up-to-date. Clients may, in writing, request that their personal information be amended as appropriate.
7. Safeguarding Personal Information
All reasonable attempts have been made to ensure security safeguards are in place to protect personal information against loss or theft, as well as unauthorized access, disclosure, copying, use, or modification regardless of the format in which it is held.
8. Openness
ZBM Financial Planning ensures that clients have access to information regarding the policies and practices we use to manage their personal information.
9. Access
Clients may request in writing access to their personal information. ZBM Financial Planning will inform the client whether the organization holds personal information and provide an account of the use that has been made of this information, as well as identify any third parties to which the information has been disclosed. When a client demonstrates the inaccuracy or incompleteness of personal information, the information will be amended as required.
10. Complaints and Suggestions
If you would like to make an inquiry, suggestion or complaint regarding ZBM Financial Planning's personal information practices, please contact Zaid B. Mohammed at 1-866-880-9166 ext. 3351 or by e-mail.