CLIENT PRIVACY POLICY & ADVISOR DISCLOSURE

At The Millar Corporation, we respect our clients and the personal information that we obtain in the course of our relationship with them.  We have a professional obligation to keep confidential all information we receive when providing our services.  In addition, we are committed to properly collecting, using and disclosing the personal information we obtain from our clients in accordance with the Privacy Law Act listed below and other laws of Ontario and Canada.  This Privacy Policy outlines how we manage your personal information and safeguard your privacy.


Your Privacy Rights

On January 1, 2004, all businesses engaged in commercial activities must comply with the Personal Information Protection and Electronic Documents Act.  The Act gives all Canadians rights concerning the privacy of their personal information.

The Millar Corporation is responsible for the personal information we collect and hold.  To ensure this accountability, we have developed this policy.  The Millar Corporation’s Chief Privacy Officer ensures that proper personal information procedures and policies are in place, and that all company employees abide by the procedures that are established to protect our clients’ personal information.

Why Does The Millar Corporation Need Personal Information?

The Millar Corporation must collect personal information from our clients to fully understand and address their estate planning/succession, wealth management or life insurance requirements and to provide them with the appropriate services needed to achieve their objectives in each of these areas.  Personal information is collected during the initial client contact as well as on an ongoing basis as we work with our clients throughout the planning and implementation process.  In most cases, the personal information is collected directly from our clients.  However, at times, we may obtain personal information about our clients from other sources that is required to deliver our services, with our clients’ permission:  for example, from lawyers, accountants, physicians, insurance companies or other financial institutions that work with our clients.  All of this information is treated with the same standard of care.

The Use Of Your Personal Information

We limit our collection of personal information to what is required to provide estate planning, investment management/advisory or insurance services for you and future updates of these arrangements.  If you tell us that you no longer wish to receive our services or updates, we will not send any further information to you.  We do not sell, trade or exchange any personal information that we receive from our clients with third parties to market their products.

Disclosure Of Your Personal Information

Any personal information we receive is held in strict confidence. However, we may need to disclose personal information to provide you with the services you have requested, or if we are required to do so by law.  Circumstances that may require disclosure include:

• When we are required or authorized by law to do so, for example if a court issues a subpoena.
• When you have consented to the disclosure.
• When the services we are providing to you require us to give your information to third parties.  For example: as a portfolio manager, to a custodian in order to transact investment business; to other portfolio managers in the case of a referral or to an insurance company in order to underwrite coverage.  In these situations, your consent will be implied, unless you tell us otherwise.
• Where it is necessary to establish or collect fees.
• If we engage a third party to provide administrative services to us (such as computer back-up services or    archival file storage) and the third party is bound by our privacy policy.
• If the information is already publicly known.

Updating Information & Correcting Errors

Since we use our clients’ contact and other personal information to provide services to them, it is important that the information be accurate and current.  Therefore, we ask our clients to inform us of any change in their personal information so that we can update our files and records.  When a client advises us that the personal information we hold is not accurate, complete or current, The Millar Corporation will take all reasonable steps to correct it.

Is My Personal Information Secure?

The Millar Corporation endeavours to take all reasonable precautions to ensure that your personal information is kept safe from loss, unauthorized access, modification or disclosure.  Safeguards in place to protect your personal information include premise security, restricted file access, proper destruction procedures and technological safeguards like security software, firewalls, internal password procedures, a secure portal for electronic document transmission and security policies.

Access To Your Personal Information

You may ask for access to your personal information that we hold at any time.  Requests that require archive or other retrieval costs (i.e., from investment or insurance institutions) may be subject to professional or disbursement fees.  The Millar Corporation, in limited circumstances, may deny access when:

• Denial of access is required or authorized by law (for example, when a record containing personal  information about the requester is subject to a claim of legal professional privilege by one of our other  clients);
• Information relates to existing or anticipated legal proceedings against a client;
• Granting access to a client would have an unreasonable impact on other people’s privacy;
• To do so would prejudice negotiations with a client;
• Protecting The Millar Corporation’s rights and property; or
• The request is frivolous or vexatious.

If we refuse your request for access, or refuse a request to correct information, we will send a letter to you outlining why your request has been denied.

The Client Privacy Policy for The Millar Corporation (which is described in this document), also applies to the affiliated companies of The Millar Corporation: Millar Private Wealth Management Inc. and The Millar & Associates Insurance Agency (Ottawa) Limited (Millar & Associates), which are the corporate entities used for investment advisory services or transaction processing for the investment or life insurance aspects of our business.

Changes To This Privacy Policy

Since The Millar Corporation regularly reviews all of its policies and procedures, we may change our Privacy Policy from time to time.

Requests For Access Or Other Privacy Questions Or Concerns

If you have any questions about The Millar Corporation’s privacy policy, licensing or remuneration practices, or if you wish to request access to the personal information we hold, or wish to file a complaint, please write to our Chief Privacy Officer at: The Millar Corporation, 30 Concourse Gate, Suite 209, Ottawa, Ontario K2E 7V7.

To find out more about federal privacy laws, contact the Privacy Commissioner of Canada at: 112 Kent Street, Ottawa, Ontario K1A 1H3 T: (800) 282-1376, or visit the website at www.privcomm.gc.ca.