The Personal Information Protection Act (Alberta) regulates the way private sector organizations within Alberta collect, use and disclose personal information. It applies to both corporate and not for profit organizations.
Because Retire First Ltd. (“Retire First”) conducts business in other jurisdictions within Canada and some of the business of Retire First crosses the borders of one or more Provinces, it is also subject to the provisions of the Personal Information Protection and Electronic Documents Act (Federal). The provisions of the Personal Information Protection and Electronic Documents Act and the Personal Information Protection Act (collectively the “Acts”) are substantially similar and the main objective, being the protection of personal information, is the same.
“Personal Information” is defined to mean information about an “identifiable individual”. This includes such things as age, weight, height, medical records, income, education, home address and phone number.
Retire First 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.
The need for Personal Information
To be able to give appropriate financial advice to our clients, we need to collect all relevant facts and information that relate to the services that we provide to our clients. We may also need business and credit information so we can ensure that we will be compensated for our services. This information will necessarily include personal information about our clients and about individuals other than our clients.
Collection, Use and Disclosure of Personal Information
Where practical, Retire First will try to collect personal information directly from the person to whom the information pertains. Where necessary, we will collect personal information from other sources. We will collect only the personal information necessary for the purposes stated in the previous paragraph.
The Acts provide that an individual is deemed to consent to the collection, use or disclosure of personal information about that individual for a particular purpose, if the individual voluntarily provides the information for that purpose, and it is reasonable that a person would voluntarily provide that information.
By retaining our corporation for financial and investment advice, we consider that an individual consents to our collection, use or disclosure of the individual’s personal information as necessary to properly advise and represent the individual in these financial and investment matters.
Where necessary to fulfill our obligations to the client, it is our policy to collect personal information about individuals other than our clients in accordance with the provisions of the Acts.
When we collect personal information about individuals directly from them, except in situations when their consent to the collection is deemed, we will tell them the purpose for which the information is collected, and the name of a person who can answer questions about the collection.
Obtaining consent from the individual after disclosure of the purpose to which the personal information is collected, used and disclosed, is a key element of the Acts. However, this obligation is not absolute. The Acts also permit us to collect, use or disclose personal information about an individual in some circumstances without the individual’s consent. Such circumstances include (but are not limited) to where:
the collection, use or disclosure is clearly in the interests of the individual and consent can not be obtained in a timely way;
collection, use, or disclosure is reasonable for the purposes of an investigation or proceeding;
the personal information is available to the public from a prescribed source;
or the collection, use, or disclosure is required or authorized by a statute or regulation of Alberta or Canada.
When we collect, use or disclose personal information, we will make reasonable efforts to ensure that it is accurate and complete. The Acts also allows us, for legal or business purposes, to retain personal information for as long as is reasonable but also imposes obligations upon us to ensure that procedures are in place to destroy the personal information when it is no longer required.
Security of Personal Information
We recognize our professional and legal obligations to protect the confidential information of our clients. We also recognize our legal obligations to protect the personal information we have gathered about our clients and about other individuals during the course of our business.
Retire First has made arrangements to secure against the unauthorized access, collection, use, disclosure, copying, modification, disposal or destruction of personal information.
Provision of Personal Information through this Website
Retire First does not collect personal information through this website. This website is to be utilized for information purposes only – is not intended to be an interactive method of contacting us and you will not be requested to provide us with personal information through this website. By visiting our website, however, our web server may collect information related to your visit, including the IP address and domain used to access our website, the type and version of your browser, the website that you came from to our website, the page that you entered and exited at, any website page that is viewed by that IP address and what country you are from. This information will be utilized by Retire First to monitor the performance of the website and to allow us to continually upgrade our website.
Links to Other Websites
Our website may contain links to other websites for related products and services which may be subject to less stringent privacy standards. Retire First does not assume any responsibility for the privacy practises, policies or actions of the third parties that operate those websites. Further, Retire First is not liable for how such third parties collect, utilize and disclose your personal information. You are strongly encouraged to view the privacy policies of those providers before you disclose your personal information.
Requests for Access to Personal Information
Pursuant to the Acts, an individual may submit a written request to us to provide them with:
a record of the personal information of the individual under our custody or control;
information about the purposes for which their personal information under our custody or control has been and is being used by us; and
the names of persons to whom and the circumstances in which their personal information has been and is being disclosed by us.
We will respond to requests in the time allowed by the Acts and will make a reasonable effort to assist applicants and to respond as accurately and completely as reasonably possible. Requests may be subject to certain fees and disbursements in accordance with the provisions of the Acts.
An individual’s ability to access his or her personal information under our control is not absolute. The Acts provide that we must not disclose personal information where:
the disclosure could reasonably be expected to threaten the safety or 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; or
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 Acts further provide 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 the 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; or
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 Acts for a complete list.
Requests for Correction of Personal Information
An individual may also submit a written request to us to correct errors or omissions in the personal information of the individual that is in our custody or control. When provided with a written request, Retire First will:
correct the personal information and, if reasonable to do so, send correction notifications to any other organizations to whom we disclosed the incorrect information; or
decide not to correct the personal information but annotate the personal information that 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 access to, or correction of, your personal information under our care and control, please contact our Privacy Officer at:
Retire First Ltd.
#101, 4610 – 49th Avenue, Red Deer, Alberta, T4N 6M6, (403) 314-5553
If you are dissatisfied with our handling of your personal information, we invite you to contact our Privacy Officer in writing, setting out the reasons for your concern. If you remain dissatisfied after our Privacy Officer has reviewed and responded to your concern, you may wish to contact the Office of the Information and Privacy Commissioner at:
410, 9925- 109 Street
Edmonton, AB T5K 2J8
Telephone (780) 422-6860 or Fax (780) 422-5682
We also encourage you to obtain a complete copy of the Acts to further determine the rights and obligations contained within that legislation and to obtain independent legal advice if considered necessary.