Privacy Statement
Russell Investments Canada Limited
Russell Investments Canada Limited ("Russell Investments") has always been committed to maintaining the confidentiality, integrity and security of all personal information that we collect, use and maintain in the course of carrying on business. We are proud of our privacy practices and want you to know how we protect this information and use it to service your account.
Personal information
In this policy, personal information means any information that identifies an individual directly or indirectly, including information such as home address and telephone number, date of birth, age, marital status, employment history, social insurance number and credit history. It does not include business contact information of individuals that communicate with us in relation to their business, employment or profession.
Collection of personal information
Personal information is collected directly from you or through your advisor when you open an account with Russell Investments. This information is obtained by us when you or your advisor sends us a completed application form or when your advisor transmits information to us electronically. From time to time, we may be required to collect information from a third party who is not your advisor, such as an executor of an estate of a third party who may provide information about you or your account to us. We may also collect other personal information if it is provided to us by your financial advisor or dealer.
Where applicable, consent to the collection of your personal information may be express or implied, depending on the circumstances and the sensitivity of the information collected.
The personal information in your account with us may include your name, birth date, mailing address, social insurance number, phone number(s), account holdings, transactions and statements, tax slips, and the name and address of your beneficiary. Other types of information we may collect and hold in your client account depends on the investment or services you request, and the types of communications that you have with us (for example, to group together individuals in your household to qualify for higher rebates.) At times, we may request independent sources to verify and supplement information that you provide to us.
You are not required to provide us with some or all of the personal information we request. However, this may result in us not being able to provide you with the product, service or information you requested.
In providing information to us and continuing to conduct business with us, you are consenting to the use of your personal information. When you provide us with personal information about another individual (for example, you are an advisor providing information about a client), you represent to us that you are authorized to disclose such information to us on the terms specified in this privacy policy.
Use of personal information
Russell Investments may use your personal information for these stated purposes:
- Communicating with you and your advisor and dealer regarding service offering or products which may be of interest to you
- Establishing and administering your account
- Ensuring the information in our records is accurate
- Executing your transactions
- Meeting legal and regulatory requirements
- Collecting a debt owed to us
- Providing you and your advisor and dealer with account statements and other account related information
- Providing you with financial statements, tax receipts, proxy mailings, transaction confirmations and other information which may be requested or needed to service your account
- Setting-up and managing products and services you have requested
- Verifying your identity and protecting against fraud
- Verifying previously given information when necessary
From time to time, we may use personal information to create aggregated or otherwise anonymized data whose purpose is to help us better provide services or assist with research or educational tasks. We only do this if the anonymized data cannot be used to directly or indirectly identify the personal information of any individuals.
Disclosure of personal information to third parties
Russell Investments discloses your personal information to agents, our vendors or other organizations only for the purposes set out in this Privacy Policy. Third parties who may be provided with your personal information include:
- Entities to whom we are legally obliged or permitted to provide information
- Governments, government agencies and regulators
- Other mutual fund companies, financial institutions and securities dealers when necessary to carry out your instructions such as transferring funds
- Third parties who perform services for us, such as account statement preparation, mailing, courier deliveries, server hosts, imaging and document storage
- Your advisor and dealer
Often the type of information that we must disclose relates to government tax reporting requirements. We may disclose your information to a third party without your consent if we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be causing injury to or interference with (either intentionally or unintentionally) our rights or property, other website users or anyone else that could be harmed by such activities, and if such disclosure is not prohibited by law.
We may disclose user information when we believe in good faith that such disclosure is required or permitted by and in accordance with the law.
When we transfer personal information to third parties, we ensure by contractual means that the transferred personal information is protected to the same degree as if it were in our possession.
We may also disclose your information in connection with a corporate re-organization, a merger or an amalgamation with another entity, or a sale of all or a substantial portion of our assets. In this case, we would ensure that the information disclosed continues to be used only for the purposes permitted by this Privacy Policy and by the entity acquiring the information.
We do not sell your personal information to any third party.
Communication of personal information outside Canada and Quebec
Personal information that we collect from you is stored on our servers in the United States. As a result, the personal information of Quebec residents may be communicated outside Quebec.
At times we may use third parties and/or our affiliates in the United States, the United Kingdom and India to perform services for us involving some of your personal information. This may require transfer of information to those third parties. This information is subject to both the laws of Canada and the laws of the third party's jurisdiction, including laws with respect to disclosure of such information, and may be accessible by regulatory authorities in other jurisdictions.
However, our practices regarding your personal information will at all times be governed by this Privacy Policy.
Your rights and how to exercise them
In accordance with applicable laws and where applicable, you have the following rights:
- To access: you may access information relating to the collection, use or disclosure of your personal information and obtain a copy of your personal information, the categories of persons who have access to your personal information, and the duration of the period of time your personal information will be kept.
- To rectify: if you believe your personal data we have on file is inaccurate, incomplete or unclear, or that our collection, communication or keeping of your personal information is not legal, you may ask us to correct your personal information. Except under limited circumstances, you may ask us to amend or update your personal information at any time.
- To withdraw your consent: where you provided consent to our use or disclosure of your personal information, you have the right to withdraw such consent at any time. However, you may limit the services or products we are able to offer you. In some circumstances, legal requirements may prevent you from withdrawing consent.
In providing information to us, directly or through your advisor, and continuing to conduct business with us, you are consenting to the use of your personal information. When you provide us with personal information about another individual, you represent to us that you are authorized to disclose such information to us on the terms specified in this privacy policy.
Russell Investments will provide you with access to your personal information on your written request. Our verification procedures help to minimize risk that such information is released to anyone not authorized to receive it. We will provide you with the requested information within 30 days of receipt of your written request, unless prohibited by law. You may ask us to amend or update your personal information at any time. Access to your personal information is free. However, we may charge reasonable costs we incur (for example, photocopies, postage, etc.) We will always provide you with an estimate prior to charging you any amounts. Russell Investments reserves the right to charge you for our costs incurred in providing the information requested.
Russell Investments may not be able to provide you with full access to your information if:
- It contains references to other persons
- It has been destroyed
- It is too costly to retrieve
- It cannot be disclosed for legal or regulatory reasons
- We would have to disclose proprietary information confidential to Russell Investments or its affiliates
If we are unable to provide you with access to your personal information or rectify it, we will provide you with a written explanation in our response to your request.
Please inform us promptly of any change in the personal information that you have provided, or if you become aware of any errors in the personal information that we have in respect of you.
If you wish to exercise any of these rights, please contact our Privacy Officer as listed in the “Contact Us” section below.
Protection of personal information
We have taken all appropriate measures and put in place controls aimed at safeguarding data. These measures include restricting physical access to our offices and records, passwords and data encryption for on-line activities. We have policies and procedures, training programs and monitoring in place to ensure that these measures are followed.
Our employees and service providers have access to your personal information only for the purposes set out in this policy to enable them to perform their duties in servicing your account.
Despite these measures, no method of information transmission or information storage is 100% secure or error free, and we cannot guarantee security. If you have reason to believe that your interaction with us is no longer secure (for example, if you believe that the security of any information that you provided to us has been compromised), please contact us immediately.
Retention of personal information
We only keep your personal information for as long as it is required (whether to provide you with services or as required by law or regulations). Once it is no longer needed, it is destroyed in accordance with our records management and destruction policies. How long we keep your information depends on the reasons for which it was collected. The type of product or service and the kind of information also affects the length of time we retain information. Your information may be kept even if you are no longer a client with us so long as it is legally necessary for us to have sufficient information to respond to any issues that may arise at a later date.
Change of Russell Investments' privacy policy
If we find it necessary or desirable to change our Privacy Policy in the future, we will post changes on our website as soon as they go into effect. Any change to this policy will become effective on the date the change is posted on our website. You will be able to clearly see the effective date at the lower left-hand corner of this web page.
Contact us
If you have any concerns, queries or complaints in respect of this privacy policy, or our management of your personal information, you can contact our Client Services team by email at privacy@russellinvestments.com, by telephone at 416-362-8411 or toll-free at 888-509-1792, or by mail to the following address:
Russell Investments Canada Limited
100 King Street West
Suite 5715
Toronto, ON M5X 1E4
Attn: Client Services
You may also contact our Chief Privacy Officer at privacy@russellinvestments.com, by telephone at 416-640-2511 or by mail at the address noted above.
Security
This site has security measures in place to protect the loss, misuse and alteration of the information under our control.
Choice/opt-out
Our site provides users the opportunity to opt-out of receiving communications from us at the point where we request information about the visitor.
This site gives users the following options for removing their information from our database to stop future communications or to no longer receive our service.
You can send e-mail to canada@russellinvestments.com.
Correct/update
This site gives users the following options for changing and modifying information previously provided.
You can send e-mail to canada@russellinvestments.com.