The Targeted Strategies Group of companies (“TTSG” or “we”) collects the personal and business information of our clients in order to offer a customized insurance-based strategy that addresses their business succession and estate planning needs and objectives. We are committed to protecting the privacy of the personal and business information of our clients and to maintaining the highest standards of security of such information. As required by privacy legislation, we obtain client consent prior to collecting the personal and business information of our clients and we only transfer, share or disclose such personal and business information in accordance with client consent or as required by law. 

TTSG’s Privacy Policy and internal procedures follow the 10 fair information principles set out in the Personal Information Protection and Electronic Documents Act (PIPEDA). The PIPEDA 10 fair information principles form the ground rules for the collection, use and disclosure of personal information, as well as for providing access to personal information. TTSG’s Principles of Privacy are outlined below. 

TTSG’s Principles of Privacy

  1. Accountability – We are accountable for keeping the information we have about our clients safe and secure. Through a series of internal practices, internal controls, and contractual agreements with third party service providers, we ensure the personal information that we collect, transfer, share, disclose and retain is secure and used only for identified business purposes or as required by law. A Chief Compliance Officer has been designated to whom requests for more information on policies and procedures may be made or inquiries regarding our complaints procedure can be directed. 

  2. Identifying Purposes – At TTSG, we collect only the information we need from our clients for the business purposes which we identify to our clients in writing, either before or at the time we collect the information. We collect personal information in order to offer high quality, specialized, and unique business succession and estate planning strategies to our clients. 

  3. Consent – Our goal at TTSG is to be transparent to our clients in the collection and use of their information. We obtain our client’s express consent before we collect, transfer, share or disclose any personal client information, except where the collection, transfer, sharing or disclosing is required by law. 

  4. Limiting Collection – At TTSG, we collect only the personal client information that is necessary to develop specialized and unique strategies for our clients and we do so with our client’s consent, except where authorized by law. We never collect more information about our clients than is needed for the purposes which we identify to our clients. 

  5. Limiting Use, Disclosure and Retention – The client personal information that we collect is not used, disclosed or retained for any purpose other than those expressly identified to our clients or as required by law. We keep our client information only as long as necessary for the fulfillment of the identified business purposes and as is necessary for legal, regulatory and limitation of action purposes. 

  6. Accuracy – We strive to keep our client’s personal information as accurate, complete and up-to-date as possible for the purposes for which it is to be used. We regularly update client information to ensure accuracy and to continue to offer high quality service to existing clients. 

  7. Safeguards – We have in place internal practices and controls to ensure security safeguards that are appropriate to the sensitivity of the personal information which we collect and retain. These safeguards include physical, technological, and organizational measures all designed to limit access to client personal information to a need-to-know basis and to keep the personal information secured against loss, theft, unauthorized access, disclosure, copying use or modification. Our employees are committed and contractually bound to maintain the confidentiality of all client information. We screen anyone who requests client personal information to ensure information is only transferred, shared or disclosed to authorized third parties. 

    We use third party service providers to support our business operations, such as customer relationship management (CRM) applications. We may transfer personal information to such third-party service providers for storage or processing. We require all our third-party service providers to implement appropriate security measures to protect personal information consistent with our policies and obligations. We do not permit our third-party service providers to use personal information for their own purposes and we only permit them to use personal information for the purposes in which we originally collected the personal information.

    Our third-party service providers may be located in a foreign jurisdiction, including Ireland or the Netherlands. In limited circumstances, the courts, law enforcement, regulators, and national security authorities of that country may be able to obtain access to personal information through the laws of the foreign country. We do not transfer personal information to third party service providers located in jurisdictions with privacy laws that are not as comprehensive as Canadian law. Whenever we engage a third-party service provider, we require that its privacy and security standards adhere to our policies and applicable Canadian privacy legislation.

  8. Openness – At our client’s request, we will make available additional information about our policies, internal practices, and internal controls relating to the management and safeguarding of client personal information. 

  9. Access to Information – At any time, a client may request to be informed of the existence, use, and disclosure of their personal information and we will, in most cases, provide access to that information. We encourage our clients to update their personal information with us if there are any changes. If a client challenges the accuracy or completeness of their personal information, we will amend such information as appropriate. There may be limited circumstances in which information cannot be disclosed for legal, security or commercial proprietary reasons. In these cases, if permitted, we will advise our clients of the reasons why they cannot access this information. 

  10. Challenging Compliance – At all times we encourage our clients to express to us any concerns they may have regarding our Privacy Policy. Where clients have questions about the manner in which we safeguard personal information, they may be directed to: 
    Jill Swainson, LL.B
    Chief Legal Officer
    The Targeted Strategies Group of companies
    Email: jswainson@targetedstrategies.com

The collection and use of our client’s personal information is fundamental to the day-to-day business operations at TTSG. Protecting client privacy and maintaining the highest standards of security with respect to client information is a top priority. If you have any questions, we encourage you to contact us.