Burgundy Asset Management Ltd. (Burgundy) is committed to protecting our Clients’ privacy and the confidentiality of their personal information in our possession, whether regarding the information such as name, address, tax identification number, etc. of its Clients or their directors, officers, beneficial owners, employees, agents, or representatives (personal information). Burgundy also complies with the personal information Protection and Electronic Documents Act (PIPEDA) in Canada, U.S. Securities and Exchange Commission (SEC) Regulation S-P, and other applicable regulations, which require us to adopt policies and procedures to protect personal information of Clients and to disclose to the Clients such policies and procedures. Here are the ways we fulfill these commitments.
All of our forms and the information obtained from the Clients are designed to obtain only information needed for contractual, income tax reporting, and regulatory requirements, including but not limited to, social security numbers, financial information, know-your-client requirements, identification questions or documentation that allow us to fulfil our anti-money laundering obligations which are applicable to us as an adviser and fund manager. In addition, we use the information Clients provide to us to thoroughly understand the Client’s investment goals and objectives. This helps us to determine the appropriate investments for the Client.
To help us keep our records accurate and complete, we ask Clients to notify us of any personal information changes or corrections.
We keep Clients’ personal information in a computer system, which can only be accessed by authorized employees using secure passwords. We have installed anti-hacking hardware to prevent unauthorized access to the computer system. For disaster recovery purposes, we maintain a duplicate computer system in an offsite location. This system has the same privacy and security measures as are in our main offices. We may also keep paper copies of personal information in filing cabinets in our office. When we need to store information offsite, the storage firm is under contract to adhere to our privacy and security measures.
We do not directly provide all the services related to your relationship with us. We may use service providers to perform specialized services on our behalf including, but not limited to, issuing cheques, preparing your income tax slips, storing of personal information, processing transactions or other data processing. These service providers are not affiliated with us and the outsourcing does not require client consent under applicable regulations. Our service providers may at times be responsible for handling personal information. Some of these third parties may be located outside of Canada or the U.S. and/or may house some of the personal information outside of Canada or the U.S. As a result, your personal information may be accessible to foreign regulatory authorities and subject to foreign laws. However, our service providers are given only the information necessary to perform the required services. In addition, we require them to protect the information in a manner that is consistent with our privacy policies and security practices of their country of jurisdiction.
All Burgundy and Beaujolais (a division of Burgundy) personnel are trained to keep Clients’ personal information private and confidential. We require all of our staff to sign our Code of Conduct, which contractually obliges them to respect and protect Clients’ personal information. We prohibit disclosure of any Client’s personal information to a third-party without the Client’s explicit consent, or unless Burgundy is, by law, required or permitted to do so. We shred paper documents containing Clients’ personal information before discarding such documents. When electronically stored personal information is no longer required for contractual or regulatory purposes, we delete the information from our computer systems.
If you use the internet to communicate with us or you access our website, certain information about your computer may automatically be generated, collected and logged by web servers. This information may include the internet protocol address assigned to your computer by your internet service provider, the type of browser you are using, the general location of your computer, and web pages visited. We may use this information to monitor website usage, resolve technical issues, improve functionality and evaluate website popularity.
The internet is not a secure medium and complete privacy, security and confidentiality cannot always be assured. While Burgundy implements reasonable and effective security controls to protect its assets, Clients who have been provided access to a Client Portal should acknowledge that any improper use of the Client Portal or failure to protect any related usernames and passwords may lead to unauthorized access or disclosure of the Client’s information. Burgundy shall not be responsible or liable for any harm that you or any other person may suffer in connection with any such breach of confidentiality or security.
Burgundy has implemented a number of security measures and processes to help protect against the loss, theft and unauthorized access of the personal information under our control. Only Burgundy employees and authorized third parties who have a legitimate business need or legal requirement to access and/or process your personal information will be permitted to do so. General entry to our offices is secured and cannot be accessed by unauthorized personnel.
Please exercise care and judgement whenever sending personal information to us or any other parties via email. Because of the inherent risks associated with the electronic transmission of information on the internet or otherwise, Burgundy does not guarantee the security and integrity of any electronic communications sent or received in relation to the services provided to you.
We may be required to disclose your personal information to domestic and international governments, government agencies, law enforcement agencies and regulators, and will only do so when required by law.
We may be required to provide certain contact information of Canadian pooled fund investors to the Ontario Securities Commission (OSC) and other securities regulators under the authority granted in securities legislation. This information is collected only for the purposes of administration and enforcement of the securities legislation. If you are an investor in a Burgundy Canadian pooled fund and you object to Burgundy’s filing of your information, you may contact our Privacy Officer.
If you have any questions about the collection and use of this information in Ontario, you may contact the OSC at the following address:
Ontario Securities Commission
Suite 1900, Box 55, 20 Queen Street West
Toronto, ON M5H 3S8
Telephone: (416) 593-8314
Facsimile: (416) 593-8122
Public official contact regarding indirect collection of information:
Administrative Support Clerk
Telephone: (416) 593-3684
Regulations require all investment advisers to provide consumers with initial and annual privacy notices that describe in general terms the firm’s information sharing and collecting practices. Burgundy provides initial notices to Clients upon opening the accounts and annually thereafter.