Privacy Policy
Citadel Securities Inc. (CSI) has procedures in place with respect to the collection, use, protection and disclosure of our clients’ personal and confidential information.
COMPLIANCE COMMITTEE
As part of our requirements, CSI has created a Privacy Committee to be accountable for its compliance with established privacy principles. The committee or any one of its members will review CSI’s Privacy Policy at least annually to determine whether additions or changes are required.
DISSEMINATION OF INFORMATION
CSI may disclose client information to the Carrying Broker and service providers with whom we have entered into business relationships, who have a need to access that client information in the performance of their duties. CSI is also required to comply with requests for client information from all organizations who regulate CSI and its business, including (but not necessarily limited to) the Investment Dealers Association, the Provincial Securities Commissions, the various stock exchanges of which CSI may be a member, Market Regulation Services and Canada Customs and Revenue Agency. CSI may also be required to disclose client information in any civil litigation in which CSI is a participant.
CLIENT CONSENT
CSI is required to obtain client consent to the collection, use and disclosure of personal information.
LIMITATIONS
CSI is limited in the collection of personal information to that which is necessary for the conduct of its business under regulatory requirements and CSI’s own policies. CSI may not use or disclose clients’ personal information for any purpose other than that for which it was collected, except with the consent of the client or as required by law. Personal information may only be retained for as long as it is necessary to fulfill those requirements.
ACCURACY
Clients’ personal information shall be as accurate, complete and up-to-date as necessary for the purposes for which it is to be used.
Clients’ personal information shall be protected by security safeguards which are appropriate to the sensitivity of the information. Safeguards include (but are not necessarily limited to) limiting access to physical storage of client information, using User IDs and passwords to access electronic records, using encryption and other techniques to limit internet access to client information, and educating staff to understand CSI’s policies and procedures with respect to client information, including the importance of protecting clients’ privacy.
ACCESSIBILITY
CSI will make specific information available about its policies and procedures regarding the management of personal information, both in the form of a booklet which explains our privacy policies, and electronically, through the CSI website. Upon request, an individual client will be informed of the existence, use and disclosure of his/her personal information and will be given access to that information within 30 days of the request. An individual has the right to challenge the accuracy and completeness of the information and have it amended if applicable.
CHALLENGING COMPLIANCE
An individual client will be able to address a challenge to CSI’s Privacy Policy concerning compliance with the principles listed above. It will be the responsibility of the Chief Compliance Officer and/or the Privacy Committee to respond to the challenge in a fair and timely manner.
