The Personal Information Protection Act (the “Act”) of British Columbia, regulates the way private sector organizations within British Columbia collect, use, keep, secure and disclose personal information. “Personal Information” means all information about an identifiable individual. FS Financial Strategies Inc. and its related parties: FS Financial Services Inc.; Mission of Care Benefits Plus Inc., Verico FS Capital Inc. (dba FS Capital), FS Financial Strategies Services Inc., FS Stellar Insurance Services Inc.; 3i Capital Clearpath Limited Partnership and Mission of Care Association (collectively called “FS”) recognize the importance of privacy and the sensitivity of personal information received by us in the course of our business.
FS recognizes its professional obligation to maintain the confidentiality of its clients’ information, and recognizes its obligations concerning the Personal Information of all individuals that its collects, uses or discloses in its practice. This policy has been developed with those obligations in mind.
FS Need for Personal Information
In order to be able to provide services to its clients, FS needs access to all relevant facts and information that relate to the representation of our clients. This information will necessarily include personal information about our clients and about individuals other than our clients.
Collection, Use and Disclosure of Personal Information
When practical and possible, FS collects personal information directly from the person to whom the information pertains. When necessary, FS will collect personal information from other sources.
By retaining FS for professional services, an individual consents to FS’ necessary collection, use or disclosure of the individual’s personal information in order to properly advise and represent the individual.
It is FS’s policy to collect personal information about individuals other than our clients in accordance with the provisions of the Act.
The Act deems that an individual has consented to our collection, use or disclosure of personal information about that individual if, at the time the consent is deemed to be given, the purpose would be considered obvious to a reasonable person. In such circumstances, FS will collect, use or disclose personal information without obtaining a written or verbal consent to do so.
The Act also allows FS to collect, use or disclose personal information about an individual in some circumstances without the individual’s consent. Those include circumstances in which:
2.1. the collection, use or disclosure is clearly in the interests of the individual and consent cannot be obtained in a timely way;
2.2. it is reasonable to expect that the collection or use of personal information with the consent of the individual would compromise the availability or accuracy of the information, and the collection or use of the information is necessary for an investigation or proceeding;
2.3. it is reasonable to expect that the disclosure of personal information with the consent of the individual would compromise an investigation or proceeding, and the disclosure of the information is necessary for an investigation or proceeding;
2.4. the personal information is available to the public from a prescribed source; and
2.5. the collection, use or disclosure of personal information is required or authorized by law.
When FS collects, uses or discloses personal information, we will make reasonable efforts to ensure that it is accurate and complete.
Security of Personal Information
FS recognizes its professional and legal obligations to protect the confidential information of its clients. FS recognizes as well its legal obligations to protect the personal information it has gathered about its clients and about other individuals during the course of its business.
FS has therefore made arrangements to secure against the unauthorized access, collection, use, disclosure, copying, modification, disposal or destruction of Personal Information.
Links to Third-Party Websites
FS’ Website may include links to Other Websites, whose privacy practices may differ from those of FS. If you submit Personal Information to any of those Other Websites, your information is governed by their privacy policies and FS does not accept any responsibility or liability in respect of third party sites or Other Websites. Please check the privacy policies published on any third party sites which you may access through that website before submitting Personal Information to them.
Requests for Access to Personal Information
The Act permits individuals to submit written requests to us to provide them with:
- their personal information under our custody or control;
- information about how their personal information under our control has been and is being used by us;
- the names of the individuals and organizations to whom their personal information under our control has been disclosed by us.
FS will respond to requests in the time allowed by the Act and will make a reasonable effort to assist applicants and to respond as accurately and completely as reasonably possible. All requests may be subject to any fees and disbursements the law allows to charge.
An individual’s ability to access his or her personal information under our control is not absolute.
The Act provides that we must not disclose personal information when:
- the disclosure could reasonably be expected to threaten the safety or physical or mental health of an individual other than the individual who made the request;
- the disclosure can reasonably be expected to cause immediate or grave harm to the safety or to the physical or mental health of the individual who made the request;
- the disclosure would reveal personal information about another individual;
- the disclosure would reveal the identity of an individual who has provided personal information about another individual and the individual providing the personal information does not consent to disclosure of his or her identity.
The Act further provides for circumstances in which an organization is not required to disclose personal information.
Requests for Correction of Personal Information
The law allows individuals to submit written requests to us to correct errors or omissions in their personal information that is in our custody or control. Upon receipt of such a request, FS will:
- correct the personal information and, if reasonable to do so, send correction notifications to any other organizations to whom we disclosed the incorrect information; or
- decide not to correct the personal information, but annotate the personal information that a correction was requested but not made.
Contacting or Communicating with Us
If you have any questions or concerns with respect to our policies related to the handling of your personal information, or if you wish to request access to, or correction of, your personal information under our care and control, please contact us to the following address:
FS Financial Strategies Inc.
602-1401 W. Broadway
Vancouver, BC V6H 1H6
Attention: Scott Low
If you are dissatisfied with our handling of your personal information, we invite you to contact us in writing, setting out the reasons for your concern. If, after our review and response to your concern, you remain dissatisfied, you may wish to use the alternatives provided to you by the Act.