Concentra Financial is committed to ensuring the accuracy, confidentiality and security of the information we hold about you. This is more than simply a legal requirement; it is an ethical obligation we readily accept. Please see our "Code for the Protection of Personal Information" for details on the 10 principles that make up our promise to you.

Information Collection

When Concentra and the customer establish a new or enhanced relationship, we will ensure that the purposes for which personal information is collected, used and disclosed are identified and documented. Thereafter, we will collect only personal information that is required for the purposes identified.

Concentra Financial collects personal information for one or more of the following purposes:

• to provide financial intermediary and trust services;
• to meet legal and regulatory requirements;
• to assist in crime prevention and detection and the apprehension and prosecution of offenders;
• to verify the individual's identity in order to determine whether the individual poses a risk to the Company;
• to comply with legislative requirements, such as those provided under the Income Tax Act, the Proceeds of Crime (Money Laundering) and Terrorist Financing Act, the Regulations Implementing the United Nations Resolutions on the Suppression of Terrorism, the United Nations Al-Qaida and Taliban Regulations, the Criminal Code, guidelines issued by the Financial Transactions and Reports Analysis Centre of Canada ("FINTRAC"), guidelines issued by the Office of the Superintendent of Financial Institutions ("OSFI") and provincial consumer reporting legislation.

The personal information we obtain assists us in providing services in a timely and efficient manner.

Information Held

Many of our business relationships require that we receive and hold personal information about our clients. In addition to information relative to the amounts of financial transactions, accumulations and obligations, certain personal information is, by necessity, held.

Examples include:

For every account we open directly with a client, legislation dictates that we must retain a record of an individual's name, address, date of birth, principal business or occupation and intended use of the funds in the account.

• Depending on the type of account opened or transaction conducted, we may require your telephone number. Clients will also be required to produce original government identification documentation when opening an account, such as: birth certificate, driver's license, passport, record of landing, permanent resident card, old age security card, certificate of Indian status, etc.
• When we open accounts for clients who are not physically present, we may use several different methods, such as: confirming information about a financial entity account, requiring a cheque to be cleared, using an approved agent, etc. to verify client identity.
• In the case of a business account or trust account the individuals authorized to act for the business or trust will be subject to the same identification requirements as listed above; however, the name, address and occupation of directors and shareholders must also be obtained.
• At the time of account opening, we are also required to determine if an individual is a politically exposed foreign person. That is, we must ask each individual if he/she or a close family member 1 has ever held an office or position in or on behalf of a foreign country 2.
• In the case of income generating accounts, such as GIC, RRSP, RRIF, RESP or TFSA, we must also receive and record an individual's Social Insurance Number for government reporting purposes.
• For mortgage clients we receive full disclosure of information relative to assets and liabilities. Additionally, we maintain a record of how you have met your obligations in respect of the mortgage.
• Estate planning clients, in addition to providing full asset and liability summaries, often must share intimate personal information about family relationships and long-range goals intentions about who will benefit from those assets in the future.
• In most instances, this information we hold is obtained from you. In some instances, for example when considering a mortgage loan application, we obtain credit information from the appropriate credit bureau as authorized by you. Also, we may contact personal references as supplied by you.
• There are certain exceptions to this requirement, including the amount of information that must be collected from clients who hold registered plans.

Release of Information

By allowing us to share your information, we are able to provide you with important material on the full range of financial services offered by Concentra Financial and our partnering co-operative financial services organizations*.

When you apply for a loan or mortgage, with your consent, we do collect additional information and check with external sources, such as credit bureaus, employers, etc.

It is also necessary, particularly given the Company's legislated obligations, to collect, use and disclose limited personal information from deposit account applicants for the purposes of verifying the individual's identity and determining whether the individual has a history of illegal or fraudulent use of a personal deposit account.

Concentra Financial may use service providers to perform specialized services on our behalf. Our service providers may at times be responsible for processing or handling personal information. They are provided only the information necessary to perform the services. In addition, we require them to protect the information in a manner that is consistent with our privacy policies and security practices. In the event our service provider is located outside of Canada, the service provider is bound by, and personal information may only be disclosed, in accordance with the laws of the jurisdiction in which the service provider is located.

In rare instances, your information may be processed and stored in foreign jurisdictions such as the United States by our third party service providers. Foreign governments, courts or law enforcement or regulatory agencies may be able to obtain disclosure of your information through the laws of that jurisdiction. The Company is required by law to respond to valid requests for information from domestic or international authorities.

Safeguarding Information

You have our commitment that we will treat your personal information with the same standard of care as we treat our own confidential information of a similar nature. Security safeguards are employed to protect personal information against loss or theft, as well as unauthorized access, disclosure, copying, use, or modification. Concentra Financial will protect personal information regardless of the format in which it is held.

Concentra Financial employees understand the policies and procedures for protecting customers' personal information. As a condition of employment, our employees are required to sign an Oath of Ethical Conduct including a commitment to keep an individual's personal information in strict confidence.

When Concentra Financial discloses personal information to third parties for data processing services, debt collection or for other goods and services, we require these third parties to ensure the information is used only for authorized purposes.

Concentra Financial may disclose personal information to businesses such as credit insurers and lenders with the customer's consent. In accordance with provincial consumer reporting legislation, we may also disclose personal information to credit bureaus. Concentra Financial relies on the protection of credit reporting legislation to ensure that credit bureaus protect our clients' personal information.

Some partners of Concentra Financial are governed by provincial legislation that contains protection for personal information. In these instances, Concentra Financial will direct the individual to the appropriate channels for inquiry or complaint.

Concentra Financial may disclose personal information without the knowledge or consent of the individual if the disclosure is made to a government institution that has made a request for the information, identified its lawful authority to obtain the information and indicated that the disclosure is requested for the purpose of enforcing legislation.

Under no circumstances do we ever sell any personal customer information or provide it to anyone other than co-operative financial services organizations* and partners. Also, we do not release information to others, including spouses, relatives or friends, without your written authorization.

Communicating Your Privacy Choices to Concentra Financial

We recognize that protecting your privacy is important. We wish to assure you that it is also an integral part of our business. We are pleased to be able to provide you with important information to assist you in building and maintaining your wealth. We will continue to provide this type of communication unless you notify us that you wish to limit the way in which we use your personal information.

You may, at any time, withhold, withdraw or change your consent. To do this, either contact our Care Centre at 1-800-788-6311 or simply visit our web site at www.concentrafinancial.ca and download a form indicating your privacy choices and forward the "Restriction of Consent" to our Privacy Officer at:

In most cases, this will have no effect on our relationship with you. However, in some circumstances it may limit our ability to provide you with certain products or services that require the sharing of your information.

Accuracy of Information

We attempt to maintain your personal information in an up-to-date fashion. This is essential to providing a high level of service. It is therefore important that you keep us informed as to any change of address or change in your personal circumstances.

We may contact you in order to update your personal information when we become aware of a change in your account preferences, or when required by legislation/regulation.

Upon receipt of a written request from you and payment of a small fee to cover administration costs, we will provide you with access to the personal information that we hold about you. If the personal information we have is inaccurate or incomplete, you can contact Concentra Financial and request the information be corrected.

¹ a head of state or government; a member of the executive council of government or member of a legislature; a deputy minister (or equivalent); an ambassador or an ambassador's attaché or counsellor; a military general (or higher rank); a president of a state owned company or bank; a head of a government agency; a judge; or a leader or president of a political party in a legislature.

² spouse or common law partner; mother or father; child; brother, sister, half-brother or half-sister; or spouse's or common-law partner's mother or father.

* Co-operative financial services organizations includes Credit Unions, Caisse Populaires, CUMIS, The Co-operators, Credential Group, and other partners.

Concentra Financial Services Association ("Concentra Financial"), and its wholly owned subsidiary Concentra Trust, are governed by the provisions and practices stated in this document and the use of the term Concentra Financial herein refers to both of these companies.