At Raymond James Investment Counsel Ltd., (“RJIC”) we recognize the importance of protecting the privacy of our clients. To provide the highest possible level of protection, we maintain standards designed to protect and prevent any misuse of your personal information. We have adopted the following principles and procedures which outline how we gather, protect and use personal information, and how we will hold ourselves accessible and accountable to you.

What is Personal Information?

"Personal information" is any information that identifies an individual and includes information with respect to name, address, age, gender, income, marital status, finances, employment, trading history and website use information, together with personal references and identification numbers (such as a social insurance number).

Why is Personal Information Collected?

Collecting and retaining personal information is essential to our ability to adhere to the "Know Your Client" rule. That rule is fundamental to the investment industry. It means that a Portfolio Manager must know the relevant information about personal finances, employment status, investment knowledge and objectives, risk tolerance, age, and family situation to assess the suitability of any investment portfolio.

We also use personal information to protect and administer accounts, records and funds; to comply with certain laws, regulations and regulatory policies; to help us improve our products and services and to understand changing client financial needs. The information we ask depends on the requested products or services and in most cases is required by law or Canadian securities regulatory bodies. For example, a social insurance number is required for products that earn investment income, in order to comply with the Canada Revenue Agency's income reporting requirements.

With consent, we may also share personal information where not prohibited by law, within the Raymond James group of companies, for the purposes of referring life insurance, disability insurance, annuities and other specific insurance products and services to clients.

We limit the collection of personal information and its disclosure to third parties to what is necessary.

How We Collect Personal Information About You

We collect most of our information directly from clients, primarily through our account opening forms. With your consent, we may also obtain personal information from third parties such as lenders or credit reporting agencies to give us information on credit history. We may also contact employers or other personal references to verify information provided.

What Are Your Options?

It is always a client’s decision whether or not to provide personal information or consent to our obtaining personal information from third parties. Consent. can be withdrawn or refused at any time. However, in some cases we may not be able to provide certain or any products or services to clients who to not provide personal information. For example, we cannot open an investment account without certain personal information as we would be in breach of our legal and regulatory obligations. If consent is withdrawn, we might not be able to work with clients on investment accounts. To clarify any questions about providing personal information, please feel free to contact a Portfolio Manager or the Raymond James Privacy Officer at the contacts set out below. We will be pleased to explain options and any consequences of refusing or withdrawing consent.

Privacy on the Internet

We recognize that many may have privacy concerns regarding our services on the Internet. We share your concerns and are committed to protecting the misuse of client information on the web.

RJIC uses cookies, a standard technology that installs information on a user's computer to permit the secure Raymond James website to recognize future visits by that computer. Cookies enhance the convenience and use of our website. For example, we use the information provided through cookies to recognize a previous user of the site, offer customized web pages, track your activity at our website, and otherwise facilitate your web experience. The cookie is not used to retrieve any information from a computer that has not already been provided. Disabling the cookie option on a browser may affect the ability to access certain parts of our website.

Our website may contain links to other websites for which Raymond James has no responsibility or control.

Disclosure of Personal Information

Raymond James will not sell, trade or lend personal information to any third parties without express permission to do so.

However, there are times when disclosure of personal information is necessary. In certain circumstances, disclosing information to a third party may be required to help complete a transaction initiated by a client or the disclosure is otherwise lawfully permitted or required. For instance, we may disclose information to legal authorities to protect against fraud, money laundering or other criminal activity. We may also, from time to time, be requested to disclose information to securities regulators to which we are subject to for the purposes of an audit or investigation relating to specific accounts or our business generally.

Sometimes it is necessary to provide personal information to a party outside our affiliated companies, such as to a vendor or service company that we hire to do our data processing or prepare account statements or to provide support or services for one or more of our products. We will seek agreement from these vendors and service companies to safeguard confidential information.

Data Location

Some of our vendors and service companies mentioned above may be located or may have servers outside of Canada. If a service provider or its systems server is located in a foreign jurisdiction, it is bound by the laws of that jurisdiction and may disclose your personal information under those laws.

Protection of Personal Information

There are several ways we strive to protect your personal information:

We maintain security standards and procedures to help prevent unauthorized access to confidential information. Our security standards and procedures are updated and tested regularly to improve the protection of our information.

We have procedures that limit employee access to personally identifiable information to those employees with a business need to know such information. We educate our employees about the importance of confidentiality and customer privacy through standard operating procedures and training programs. We take appropriate measures to enforce employee privacy responsibilities.

Our technological systems are monitored 24 hours a day, 365 days a year, for signs of tampering or unauthorized activity. We employ the use of encryption, virtual private networks, penetration/vulnerability testing, and the latest firewall and antivirus technology. Email monitoring is also utilized for regulatory and compliance purposes in order to protect our clients. We also maintain strict controls to limit and monitor employee access to our systems.

Our information technology professionals constantly research and develop enhancements to keep us at the vanguard of data security. A team of independent auditors reviews our technological systems quarterly.

Our suppliers and agents, as part of their contracts with Raymond James, are bound to maintain confidentiality and may not use the information for any unauthorized purpose. When we provide information in response to a legal or regulatory inquiry or order, we ensure that the order is valid and we disclose only the information that is required otherwise we will seek consent prior to disclosing any information.

We retain personal information only as long as it is required for the reasons it was collected or as required by law or regulation. The length of time we retain information varies depending on the product or service and the nature of the information. This period may extend beyond the end of a relationship with us but only for so long as it is required by regulation or necessary for us to respond to issues that may arise at a later date. When personal information is no longer needed, we have procedures to destroy, delete, erase or convert it to an anonymous form.

Your Access to Personal Information

You may request access to your personal information on record with Raymond James Investment Counsel Ltd. and information about the use and disclosure of that information by contacting the Raymond James Privacy Officer as follows:

Tel: 416 777-6438
Fax: 604 654-7238
Email: privacy.officer@raymondjames.ca
Address: Suite 2100-925 West Georgia Street, Vancouver, BC V6C 3L2

We will ask you for specific details such as the name of your Portfolio Manager and your account number and we will respond to your request promptly. Please note that we may not be able to provide information about you from our records if it contains references to other persons, is subject to legal privilege, contains information proprietary to Raymond James, or cannot be disclosed for other legal reasons. Also, we do not maintain disclosure records for regular or routine actions.

Keeping Your Personal Information Accurate

RJIC attempts to keep its records as accurate and complete as possible. Clients help us maintain the accuracy of information by notifying us of any changes to personal information. If you find any errors in our information about you, let us know and we will make the corrections immediately and make sure they are conveyed to anyone we may have misinformed. For information that remains in dispute, we will note your opinion in the file.

Resolving Privacy Issues

If you have any questions about privacy and confidentiality—or any concerns about the way a request for personal information was handled, please contact the Raymond James Privacy Officer directly at the contacts listed above.