Privacy Policy

The Letko, Brosseau & Associates Inc. (“LBA”) Commitment

This Privacy Policy applies to the collection, use and disclosure of personal information in our possession. These standards apply in addition to our employees professional obligations to maintain confidentiality of all client information we receive in accordance with LBA’s Code of Ethics and Standards.

Personal Information Protection

LBA collects, uses and discloses personal information in accordance with applicable laws and the following ten principles on which the Personal Information Protection and Electronic Documents Act of Canada and the Act Respecting the Protection of Personal Information in the Private Sector of Quebec are based.

Personal information is any information which relates to a natural person and allows that person to be identified.

1. Accountability

LBA is responsible for all personal information under its control and has designated an officer to ensure adherence of this policy. The Privacy Officer may also, on occasion, appoint one or more other persons in the firm to act on his behalf.

The Privacy Officer contact details are:
Mr. Daniel Brosseau
Letko, Brosseau & Associates Inc.
1800 McGill College Ave, Suite 2510
Montreal, QC H3A 3J6
[email protected]

LBA has implemented internal policies and practices to respond to the following principles:

  • Procedures regarding protecting of personal information;
  • Procedures for receiving and processing complaints and requests; and
  • Training of employees and communication to employees’ of LBA’s privacy policies and practices.

2. Identifying purposes

LBA identifies, discloses and documents the purposes for which personal information is collected prior to or at the time of the collection of the personal information.

3. Consent

LBA obtains the informed consent of the individual for whom the collection, use or disclosure of personal information will be used, unless exempted by law. When requesting consent, LBA discloses the purposes for which personal information is being collected to allow the individual to reasonably understand how it will be used or disclosed.

The form and method of obtaining consent may vary from written consent to implied consent, depending on the circumstances and nature of the information collected. In determining the form and manner of consent, LBA will consider the sensitivity of the information collected and the reasonable expectations of the person.

Subject to any legal or contractual restrictions, individuals may withdraw their consent to LBA’s collection, use and disclosure of personal information at any time, by providing LBA with reasonable notice. LBA will inform the individual of the implications of such withdrawal.

4. Limiting collection

LBA limits the collection of personal information to what is necessary to conduct its business and for the purposes disclosed at the time of the collection thereof.

5. Limiting use, disclosure and retention

LBA does 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 applicable law.

LBA may, from time to time, disclose your personal information to third parties, such as agents and service providers that perform specialized services on our behalf. When LBA uses such external parties, it uses contractual or other measures to ensure that these parties agree to protect personal information in the same manner as LBA.

LBA retains personal information in accordance with its retention policy and, in any event, for no longer than is necessary given the purpose for which it was collected.

 6. Accuracy

LBA ensures that personal information is as accurate, complete and up-to-date as necessary for the purposes for which it is to be used.

To help us keep our records accurate and complete, we ask clients to consent to our use of their personal information in our account information form and each annual update of the account information form. Clients are also asked to notify us of any personal information changes, deletions or corrections.

7. Safeguards

LBA takes reasonable steps to properly protect all personal information against loss or theft, as well as unauthorized access, disclosure, copying, use or modification, by applying security measures that address the sensitivity of the information.

The methods of protection include:

  • Physical measures (locked drawers, access restricted to our offices and secured archives room);
  • Organizational measures (code of conduct signed by all employees); and
  • Technological measures (use of passwords and encryption).

8. Reporting Privacy Breaches

A privacy breach is the loss of, unauthorized access to, or disclosure of, personal information resulting from a breach of an organization’s security safeguards. Upon the occurrence of a privacy breach, LBA will investigate and evaluate the implications of the breach of security safeguards. LBA will report the breach to the appropriate regulatory body and/or notify affected individuals if we have determined that the breach creates a real risk of significant harm to an individual, unless giving notice is otherwise prohibited by law. LBA will take immediate steps to mitigate the risks associated with a breach of security safeguards and all necessary steps to prevent future breaches.

9. Openness

LBA will make readily available to individuals specific information about its policies and practices relating to the management of personal information upon request. All inquiries regarding this policy privacy should be directed to the Privacy Officer.

10. Individual Access

Upon request, LBA will inform individuals of the existence, use and disclosure of their personal information. Subject to certain exceptions prescribed by law, individuals will be given reasonable access to their personal information and are entitled to request that we delete their personal information, or challenge the accuracy and completeness of their information and, if shown to be inaccurate, to have it amended as appropriate.

11. Challenging Compliance

Any person may file a complaint concerning our protection of personal information by contacting LBA’s Privacy Officer. LBA will investigate all complaints. If a complaint is substantiated, it will take appropriate action, including if necessary, amending its policies and practices.

For more information regarding privacy laws and regulations, please contact the Commission d’accès à l’information or the Office of the Privacy Commissioner of Canada at:

Commission d’Accès à l’Information

Québec
Bureau 2.36
525, René-Lévesque Blvd. East
Québec, QC G1R 5S9
Phone: 418-528-7741
Fax: 418-529-3102

Montréal
Bureau 18.200
500, René-Lévesque Blvd. West
Montréal, QC H2Z 1W7
Phone : 514-873-4196
Fax: 514-844-6170

Toll free number: 1-888-528-7741

Email: [email protected]

Office of the Privacy the Privacy Commissioner of Canada

30 Victoria Street
Gatineau, QC K1A 1H3
Phone: 819-994-5444
Fax: 819-994-5424

Toll free number: 1-800-282-1376