THE ANTRIM INVESTMENTS LTD. PRIVACY CODE

Table of Contents

  • Introduction
  • Summary of Principles
  • Scope and Application
  • Definitions
  • The Antrim Investments Ltd. Privacy Code in Detail
  • Principle 1 - Accountability
  • Principle 2 - Identifying Purposes for Collection of Personal Information
  • Principle 3 - Obtaining Consent for Collection, Use or Disclosure of Personal Information
  • Principle 4 - Limiting Collection of Personal Information
  • Principle 5 - Limiting Use, Disclosure, and Retention of Personal Information
  • Principle 6 - Accuracy of Personal Information
  • Principle 7 - Security Safeguards
  • Principle 8 - Openness Concerning Policies and Procedures
  • Principle 9 - Clients and Employee Access to Personal Information
  • Principle 10 - Challenging Compliance
  • Additional Information

Introduction

At Antrim Investments Ltd., respecting privacy is an important part of our commitment to our clients and employees. That is why we have developed The Antrim Investments Ltd. Privacy Code. The Antrim Investments Ltd. Privacy Code is a statement of principles and guidelines regarding the minimum requirements for the protection of personal information provided by Antrim Investments Ltd. to its clients and employees. The objective of The Antrim Investments Ltd. Privacy Code is to promote responsible and transparent personal information management practices in a manner consistent with the provisions of the Personal Information Protection and Electronic Documents Act (Canada).


Antrim Investments Ltd. will continue to review The Antrim Investments Ltd. Privacy Code to make sure that it is relevant and remains current with changing industry standards, technologies and laws.

Summary of Principles

Principle 1 - Accountability

Antrim Investments Ltd. is responsible for personal information under its control and shall designate one or more persons who are accountable for Antrim Investments Ltd.’s compliance with the following principles.

Principle 2 - Identifying Purposes for Collection of Personal Information

Antrim Investments Ltd. shall identify the purposes for which personal information is collected at or before the time the information is collected.

Principle 3 - Obtaining Consent for Collection, Use or Disclosure of Personal Information

The knowledge and consent of a client or employee are required for the collection, use, or disclosure of personal information, except where inappropriate.

Principle 4 - Limiting Collection of Personal Information

Antrim Investments Ltd. shall limit the collection of personal information to that which is necessary for the purposes identified by Antrim Investments Ltd.. Antrim Investments Ltd. shall collect personal information by fair and lawful means.

Principle 5 - Limiting Use, Disclosure, and Retention of Personal Information

Antrim Investments Ltd. shall not use or disclose personal information for purposes other than those for which it was collected, except with the consent of the individual or as required by law.

Principle 6 - Accuracy of Personal Information

Personal information shall be as accurate, complete, and up to date as is necessary for the purposes for which it is to be used.

Principle 7 - Security Safeguards

Antrim Investments Ltd. shall protect personal information by security safeguards appropriate to the sensitivity of the information.

Principle 8 - Openness Concerning Policies and Procedures

Antrim Investments Ltd. shall make readily available to clients and employees specific information about its policies and procedures relating to the management of personal information.

Principle 9 – Client and Employee Access to Personal Information

Antrim Investments Ltd. shall inform a client or employee of the existence, use, and disclosure of his or her personal information upon request and shall give the individual access to that information. A client or employee shall be able to challenge the accuracy and completeness of the information and have it amended as appropriate.

Principle 10 - Challenging Compliance

A client or employee shall be able to address a challenge concerning compliance with the above principles to the designated person or persons accountable for Antrim Investments Ltd.’s compliance with The Antrim Investments Ltd. Privacy Code.

Scope and Application

The ten principles that form the basis of The Antrim Investments Ltd. Privacy Code are interrelated and Antrim Investments Ltd. shall adhere to the ten principles as a whole. Each principle must be read in conjunction with the accompanying commentary. As permitted by the Personal Information Protection and Electronic Documents Act (Canada), the commentary in The Antrim Investments Ltd. Privacy Code has been drafted to reflect personal information issues specific to Antrim Investments Ltd..
The scope and application of The Antrim Investments Ltd. Privacy Code are as follows:

  • The Antrim Investments Ltd. Privacy Code applies to personal information collected, used, or disclosed by Antrim Investments Ltd. in the course of commercial activities.
  • The Antrim Investments Ltd. Privacy Code applies to the management of personal information in any form, whether oral, electronic or written.
  • The Antrim Investments Ltd. Privacy Code does not impose any limits on the collection, use or disclosure of the following information by Antrim Investments Ltd.:
    (a) an employee’s name, title or business address or telephone number;
    (b) information that Antrim Investments Ltd. collects, uses or discloses for journalistic, artistic or literary purposes and does not collect, use or disclose for any other purpose; or
    (c) other information about the individual that is publicly available and is specified by regulation pursuant to the Personal Information Protection and Electronic Documents Act (Canada).
  • The Antrim Investments Ltd. Privacy Code will not typically apply to information regarding Antrim Investments Ltd.’s corporate clients. However, such information may be protected by other Antrim Investments Ltd. policies and practices and through contractual arrangements.
  • The application of The Antrim Investments Ltd. Privacy Code is subject to the requirements and provisions of the Personal Information Protection and Electronic Documents Act (Canada), the regulations enacted thereunder, and any other applicable legislation or regulation.

    • Definitions

    collection: The act of gathering, acquiring, recording, or obtaining personal information from any source, including third parties, by any means.


    consent: Voluntary agreement for the collection, use and disclosure of personal information for defined purposes. Consent can be either express or implied and can be provided directly by the individual or by an authorized representative. Express consent can be given orally, electronically or in writing, but is always unequivocal and does not require any inference on the part of Antrim Investments Ltd.. Implied consent is consent that can reasonably be inferred from an individual’s action or inaction.


    client: An individual who purchases or otherwise acquires or uses any of Antrim Investments Ltd.’s products or services or otherwise provides personal information to Antrim Investments Ltd. in the course of Antrim Investments Ltd.’s commercial activities.


    disclosure: Making personal information available to a third party.


    employee: An employee of or independent contractor to Antrim Investments Ltd..


    personal information: Information about an identifiable individual, but does not include the name, title, business address or telephone number of an employee of an organization.


    third party: An individual or organization outside of Antrim Investments Ltd..


    use: The treatment, handling, and management of personal information by and within Antrim Investments Ltd. or by a third party with the knowledge and approval of Antrim Investments Ltd..

    The Antrim Investments Ltd. Privacy Code in Detail

    Principle 1 - Accountability

    Antrim Investments Ltd. is responsible for personal information under its control and shall designate one or more persons who are accountable for Antrim Investments Ltd.’s compliance with the following principles.


    1.1 Responsibility for compliance with the provisions of The Antrim Investments Ltd. Privacy Code rests with the Antrim Investments Ltd. Privacy Officer who can be reached at 1-604-530-2301 or via will@antriminvestments.com. Other individuals within Antrim Investments Ltd. may be delegated to act on behalf of The Antrim Investments Ltd. Privacy Officer or to take responsibility for the day-to-day collection and/or processing of personal information.


    1.2 Antrim Investments Ltd. shall make known, upon request, the title of the person or persons designated to oversee Antrim Investments Ltd.’s compliance with The Antrim Investments Ltd. Privacy Code.


    1.3 Antrim Investments Ltd. is responsible for personal information in its possession or control. Antrim Investments Ltd. shall use contractual or other means to provide a comparable level of protection while information is being processed or used by a third party.


    1.4 Antrim Investments Ltd. shall implement policies and procedures to give effect to The Antrim Investments Ltd. Privacy Code, including:
    (a) implementing procedures to protect personal information and to oversee Antrim Investments Ltd.’s compliance with The Antrim Investments Ltd. Privacy Code;
    (b) implementing procedures to receive and respond to complaints or inquiries;
    (c) training and communicating to staff about Antrim Investments Ltd.’s policies and procedures; and
    (d) developing information materials to explain Antrim Investments Ltd.’s policies and procedures.

    Principle 2 - Identifying Purposes for Collection of Personal Information

    Antrim Investments Ltd. shall identify the purposes for which personal information is collected at or before the time the information is collected.


    2.1 Antrim Investments Ltd. collects personal information only for the following purposes:
    Mortgage underwriting.

    • Preparation of financial statements including compilation, review and audit engagements.
    • Preparation of T1 personal income tax returns as required by Canada Revenue Agency.
    • Preparation of T2 corporate tax returns as required by Canada Revenue Agency.
    • Preparation of T3 estate returns as required by Canada Revenue Agency.
    • Preparation of GST, PST, T3’s, T4’s, T4A’s, T5’s, NR4’s, T5018 subcontract information and WCB.
    • Submission of data to other government departments such as the Ministry of Health, Ministry of Education,
    • Foreclosure proceedings.
    • Sale of Real Estate due to Foreclosure.
    • Social Services and local health boards.
    • Estate and tax planning at the request of our clients.
    • Preparation of projections such as future cash flows and pro-forma operating statements.
    • Analyzing financial data to assist clients with purchase and / or sale of a business.

    Further reference to “identified purposes