DC Pulse 2016
Our latest insights into retirement readiness with plan sponsors and participants
In our monthly fixed income market outlook, Rick Rieder, BlackRock’s Chief Investment Officer...
I am registered or I represent an entity that is registered under the securities legislation of a jurisdiction of Canada either as (i) an investment dealer (in which case, I am also registered with the Investment Industry Regulatory Organization of Canada or Mutual Fund Dealers Association of Canada); or (ii) a portfolio manager. Alternatively, I am registered or I represent an entity organized in a foreign jurisdiction that is registered in a category that is analogous to (i) or (ii) above. I am a fiduciary.
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BlackRock is an equal opportunity employer committed to diversity in the workplace.
Dated: August 2014
© 2016 BlackRock, Inc. All rights reserved. BLACKROCK and iSHARES are registered and unregistered trademarks of BlackRock, Inc. or its subsidiaries in the United States and elsewhere. All other trademarks are those of their respective owners.
BlackRock Asset Management Canada Limited (“BlackRock Canada”) and its affiliates (collectively, “BlackRock”) are concerned about the protection of personal information of its “clients” (as hereinafter defined). This policy sets out a set of principles respecting the manner in which BlackRock protects the privacy of clients resident in Canada.
This policy addresses two broad issues: the way BlackRock Canada collects, uses, discloses and protects personal information; and the right of clients to have access to personal information about themselves and, if necessary, to have the information corrected. Ten interrelated principles form the basis of the policy. Each principle is accompanied by a commentary that elaborates on the principle.
1. Provides principles for the management of personal information; and
2. Specifies the minimum requirements for the adequate protection of personal information held by BlackRock Canada.
SUMMARY OF BLACKROCK’S PRIVACY PRINCIPLES
Ten interrelated principles form the basis of this policy. Each principle must be read in conjunction with the accompanying commentary.
1. Accountability. BlackRock Canada is responsible for personal information under its control and shall designate an individual or individuals who are accountable for BlackRock Canada’s compliance with the following principles.
2. Identifying Purposes. The purpose(s) for which personal information is collected shall be identified by BlackRock to the client at or before the time the information is collected.
3. Consent. The knowledge and consent of the client are required for the collection, use, or disclosure of personal information, except for legal or security reasons.
4. Limiting Collection. The collection of personal information shall be limited to that which is necessary for the purposes identified by BlackRock. Information shall be collected by fair and lawful means.
5. Limiting Use, Disclosure and Retention. Personal information shall not be used or disclosed for purposes other than those for which it was collected, except with the consent of the client or as required by law. Personal information shall be retained only as long as necessary for the fulfillment of those purposes.
6. Accuracy. Personal information shall be as accurate, complete, and up-to-date as is necessary for the purposes for which it is to be used.
7. Safeguards. Personal information shall be protected by security safeguards appropriate to the sensitivity of the information.
8. Openness. BlackRock Canada shall make readily available to clients specific information about its policies and practices relating to the management of personal information.
9. Client Access. Upon request, a client shall be informed of the existence, use, and disclosure of his or her personal information and shall be given access to that information. A client shall be able to challenge the accuracy and completeness of the information and have it amended as appropriate.
10. Challenging Compliance. A client shall be able to address a challenge concerning compliance with the above principles to the designated individual or individuals accountable for BlackRock Canada’s compliance.
1.1. This policy describes the minimum requirements for the protection of personal information. Any applicable legislation must be considered in implementing these requirements.
1.2. This policy applies to personal information relating to “clients” as defined in Section 2.
1.3. The objective of this policy is to assist BlackRock Canada and all of its employees in developing and implementing policies and practices to be used when managing personal information.
The following definitions apply in this policy:
“client” – persons resident in Canada about whom BlackRock collects personal information in carrying out its business; and includes persons who have dealt with or intend to deal with BlackRock, and any other person resident in Canada who has contacted BlackRock and provided his or her own personal information to BlackRock.
“collection” -- the act of gathering, acquiring or obtaining personal information from any source, including from third parties, by any means.
“corporate client” – clients other than individuals. Without limiting the foregoing this includes clients resident in Canada and structured as corporations, partnerships, joint ventures, trusts, associations, unincorporated organizations, governmental authorities or any other entity recognized by law.
“consent” -- voluntary agreement with what is being done or proposed. Consent can be either express or implied. Express consent is given explicitly, either orally or in writing. Express consent is unequivocal and does not require any inference on the part of BlackRock. Implied consent arises where consent may reasonably be inferred from the action or inaction of the client.
“control” -- BlackRock controls personal information if the personal information is in the possession of BlackRock or a person to whom BlackRock has disclosed the personal information, excluding a person to whom such disclosure was required by law.
“disclosure” -- making personal information available to others outside BlackRock.
“person” -- shall be broadly interpreted and includes an individual, corporation, partnership, joint venture, trust, association, unincorporated organization, any governmental authority or any other entity recognized by law.
“personal information” -- information about an identifiable client (if that client is an individual) or information about an identifiable individual acting on behalf of a corporate client but does not include the name, title or business address or telephone number of an employee, officer, trustee or other representative of a corporate client.
Commentary. This definition of “personal information” includes information about an individual client or about any other individual if the client or other individual is identifiable as the subject of the information, but does not include aggregate information that cannot be associated with a specific client or individual. "Personal information" may include, but is not limited to, an individual's name, social insurance number, address, telephone number, e-mail address, date of birth, family status, marital status, occupation, assets, investments, liabilities, income and, credit rating.
“use” -- treatment and handling of personal information within BlackRock.
3. GENERAL REQUIREMENTS
3.1. The ten principles that make up this policy are interrelated.
3.2. Each principle is followed by a commentary. The commentaries are intended to help employees of BlackRock Canada understand the significance and the implications of the principles.
3.3. Prescriptive language used herein (that is, words like “shall” or “must”) are requirements. The use of the word “should” indicates a recommendation.
3.4. Use of the singular does not exclude the plural (and vice versa) when the sense allows.
BlackRock Canada is responsible for personal information under its control and for establishing and implementing policies and practices for the appropriate collection, retention and use of the personal information.
4.1.1. BlackRock Canada’s senior management committee or BlackRock Canada’s Chief Compliance Officer shall designate one or more individuals who shall be accountable for BlackRock’s compliance with the principles set out in the policy (the “Responsible Individuals”). The identity of the Responsible Individuals shall be available to BlackRock Canada employees and clients upon request.
4.1.2. BlackRock Canada is responsible for personal information in its possession, custody or control, including information that has been transferred to a third party for processing. Prior to disclosing any personal information to any third party, BlackRock Canada shall use contractual or other means to provide a comparable level of protection while the personal information is in the possession, custody or control of a third party. Prior to the release of any personal information to a third party, a Responsible Individuals shall be consulted to ensure appropriate levels of protection are in place, to the extent necessary.
4.1.3. The Responsible Individual shall coordinate the implementation of policies and practices to give effect to the principles, including:
126.96.36.199. implementing procedures to protect personal information; and
188.8.131.52. establishing procedures to receive and respond to complaints and enquiries;
4.2. Identifying Purposes
The purposes for which personal information is collected shall be identified to the client by BlackRock Canada before or at the time the information is collected.
4.2.1. The purposes for which personal information is collected shall be documented by the person collecting such information in order to comply with this policy.
4.2.2. Identifying the purposes for which personal information is collected at or before the time of collection allows BlackRock Canada to determine the information it needs to collect to fulfill these purposes. Clause 4.4 requires BlackRock Canada to collect only that information necessary for the purposes that have been identified.
4.2.3. The identified purposes should be specified at or before the time of collection to the client from whom the personal information is collected. Depending upon the way in which the information is collected, this can be done orally or in writing. An application form, pamphlet, website notice or other suitable media, for example, may give notice of the purposes for which personal information is being collected.
4.2.4. When personal information that has been collected is to be used for a purpose not previously identified, the new purpose shall be identified before use. Unless the new purpose is required by law, the consent of the client is required before personal information can be used for that purpose.
4.2.5. Employees collecting personal information should be able to explain to clients or other identifiable individuals, the purposes for which the information is being collected.
The knowledge and consent of the client are required for the collection, use, or disclosure of personal information, except as provided in this Principle.
Commentary: In certain circumstances, express consent need not be obtained from a client before such client’s personal information is collected, used, or disclosed. For example, legal or security reasons may make it impossible or impractical to seek consent. In addition, BlackRock Canada may not be able to seek consent because it does not have a direct relationship with the client. However, when most information is being collected (including financial information) BlackRock Canada must obtain express consent from the client.
4.3.1. Consent is not required for the collection, use and disclosure of personal information for legal or security reasons such as the collection of personal information for the detection and prevention of fraud or compliance with subpoenas, search warrants, and other court, regulatory or government orders, where obtaining consent might defeat the purpose of collecting the information.
4.3.2. Consent is required for the collection of personal information and the subsequent use or disclosure of this information. Consent must be obtained for the use or disclosure of the information at the time of collection. In certain circumstances, consent with respect to use or disclosure may be sought after the information has been collected but before use (for example, when a new purpose for previously gathered information is identified).
4.3.3. The principle requires “knowledge and consent”. Reasonable effort shall be made to ensure that the client is advised of the purposes for which the personal information will be used. To make the consent meaningful, the purposes must be stated in such a manner that the individual can reasonably understand how the personal information will be used or disclosed. In obtaining consent, the reasonable expectations of the client or other identifiable individual are also relevant.
4.3.4. Clients shall not be required, as a condition of the supply of a product or service, to consent to the collection, use, or disclosure of personal information beyond that required to fulfill the explicitly specified purposes. The client must be informed of all information requirements that are related to the product or service. Doing so ensures that a specified, explicit and legitimate purpose has been identified for the client. As a result, BlackRock can then refuse to deal with a client who will not consent to the collection, use and disclosure of the personal information for the specified, explicit and legitimate purpose. For example, laws may require BlackRock Canada to obtain certain personal information so as to carry out its responsibilities to its clients. If this personal information is not obtained, BlackRock Canada cannot determine the suitability of investments and, therefore, cannot provide the investment advice sought by the client. Consent shall not be obtained through deception.
4.3.5. The form of the consent sought by BlackRock Canada may vary, depending upon the circumstances and the type of personal information. In determining the form of consent to use, BlackRock Canada shall take into account the sensitivity of the personal information. Although most personal information obtained by BlackRock Canada is considered to be sensitive, any personal information can be sensitive, depending on the context. A client at the time of providing any personal information and upon completion of an investment management agreement/transition agreement must be advised as to the specific uses and by whom the personal information given in such form may be used. At such time, the client must expressly consent to such uses. The degree of specificity of such description may vary depending upon the personal information shared. For example, if only the name and address is given out to affiliates of the BlackRock entity receiving the information for the purposes of mailing generic marketing materials, then less specificity is required. On the other hand, if it is intended that personal information is used to create targeted, personally tailored marketing materials then greater specificity would be required. BlackRock should generally seek express consent of the client or identifiable individual to the collection, use and disclosure of personal information about that individual.
4.3.6. Consent can also be given by an authorized representative (such as a corporate officer, trustee legal guardian or a person having power of attorney). 4.3.7. Clients can give consent in many ways. For example:
184.108.40.206. an application form may be used to seek consent, collect personal information, and inform the client of the use that will be made of the personal information. By completing and signing the form, the client is giving consent to the collection and the specified uses;
220.127.116.11. a check-off box may be used to allow clients to request that certain or all personal information not be given to third parties. Clients who do not check the box are assumed to consent to the transfer of this personal information to third parties for specified purposes;
18.104.22.168. consent may be given orally when personal information is collected over the telephone, provided that BlackRock reasonably verifies the identity of the person giving consent over the telephone;
22.214.171.124. consent may be given at the time that clients request or use a product or service; or
126.96.36.199. consent may be given electronically over the Internet or by other electronic means, if the client can be reliably identified as the source of such consent.
4.3.8. A client may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice. BlackRock Canada shall inform the client of the implications of such withdrawal. Absent any such withdrawal, consent is valid for the length of time needed to achieve the identified purposes.
4.4. Limiting Collection
The collection of personal information shall be limited to that which is necessary for the purposes identified by BlackRock. Information shall be collected by fair and lawful means.
4.4.1 BlackRock Canada shall not collect personal information indiscriminately. Both the amount and the type of information collected shall be limited to that which is necessary to fulfil the purposes identified. BlackRock Canada may obtain personal information from clients through hard copy, electronic or other means, but also from other sources, including but not limited to investment dealers, custodians or other third parties who represent that they have the right to disclose the information. BlackRock Canada shall collect personal information from third parties only with the consent of the client or identifiable individual concerned, unless the collection is clearly in the interests of the individual and consent cannot be obtained in a timely way, it is reasonable to expect that the collection with the knowledge of the client or identifiable individual would compromise the availability or accuracy of the information and the collection is reasonable for purposes relating to investigating a breach of an agreement or a contravention of law, or the information is publicly available and is specified by the regulations to the Personal Information Protection and Electronic Documents Act. BlackRock Canada shall specify the type of information collected as part of its information-handling policies and practices in accordance with the Openness principle (Clause 4.8).
Commentary. Personal information should only be collected if necessary. For example, BlackRock Canada may collect personal information in order to satisfy its obligation to know its clients. To satisfy that obligation, they will collect information about a client’s financial situation and, if applicable, relevant personal data, such as family size and SIN number, in order to comply with the requirements of Canada Revenue Agency. However, there is no need to obtain a health card number or information about the client’s political affiliations.
Commentary. These requirements apply not only to documents such as a client’s account application form or investment management agreement, but also to notes or memoranda maintained by BlackRock Canada made as a result of discussions and correspondence with the client.
Commentary. The requirement to specify information requires that disclosure be made to clients of BlackRock Canada’s policy on the collection and retention of personal information. This disclosure could be by way of a statement in the client’s account application form. Alternatively, it could be by way of a separate disclosure document given to the client with provision made for the client to consent to the proposed use or such disclosure could be posted on BlackRock’s websites if the client could be reasonably expected to review it there. If changes are proposed to be made in the use or retention of personal information to which the client has consented (for example, in order to market new products or as a result of a proposal to share data because of new strategic alliances), then a new, revised disclosure document should be provided and a new consent obtained.
4.4.2 The requirement that personal information be collected by fair and lawful means is intended to prevent BlackRock Canada from collecting information by misleading or deceiving clients about the purpose for which information is being collected. This requirement implies that consent with respect to collection must not be obtained through deception.
Commentary. Note that the use of personal information for financial profiling, without having previously disclosed to the client that the information would be used for that purpose, would not preclude such use, provided any personal identifying data was not included in the undisclosed use. For example, use of financial information to generate statistics about a typical investor profile.
4.5. Limiting Use, Disclosure & Retention Personal information shall not be used or disclosed for purposes other than those for which the information was collected, except with the consent of the client or as required by law. Personal information shall be retained only as long as necessary for the fulfillment of those purposes.
4.5.1 There are situations specific to the investment management business where investment funds, investment fund management companies, dealers and service providers will disclose personal information that is necessary in the course of providing their services to or on behalf of clients. For example, personal information may be disclosed to:
(a) Information Services Providers: members of the investment funds industry for the purposes of providing tax statements, client statements and fulfilling orders;
(b) Fund Services Providers: businesses that provide other goods and services to funds, fund management companies and dealers and/or their clients, such as data processors and record keepers; and
(c) Fund Intermediaries: intermediaries such as trustees and custodians. Only the personal information necessary for these services will be provided by BlackRock to these service providers. Every such disclosure shall be made subject to the protection measures specified below in clause 4.7.3 of this policy.
Commentary. Databases provided to third parties by BlackRock Canada should be limited to personal information required in order for the third party service provider to provide the specified services; otherwise, the consent to such sharing of information will have to be more explicit. For example, “any information we collect may be shared with our service providers” versus “information required for tax reporting may be shared with third parties engaged to provide tax reporting”.
Commentary. The process by which BlackRock Canada receives client consent must include a mechanism which permits a client to indicate that the client does not consent to the sharing of information for collateral purposes, i.e. to market other products, as opposed to satisfying BlackRock’s “know your client” obligations.
Commentary. Where a client objects to the sharing or use of personal information, the systems upon which BlackRock Canada relies must permit the tracking of any restrictions or such sharing or use, i.e. the personal information must be “bonded” to the specific use so that it will not be included in databases used for collateral purposes. Note that information shared with third party service providers must similarly provide for such “bonding”.
4.5.2 Prior to using personal information for a new purpose, BlackRock Canada shall document this purpose.
Commentary. Entering into a new line of business may require that BlackRock Canada obtain new client consent to the sharing of personal information. For example, BlackRock Canada may obtain personal information about investors for the purposes of the administration of its clients’ accounts. If BlackRock Canada determined to enter into a strategic alliance with a financial service conglomerate which offers a broad range of products and services, BlackRock Canada would be required to obtain a new consent before personal information is shared with the financial conglomerate for marketing the latter’s products and services.
4.5.3 It is an objective of BlackRock Canada to develop guidelines and implement procedures with respect to the retention of personal information. These guidelines should include minimum and maximum retention periods. Personal information that has been used to make a decision about a client shall be retained long enough to allow the client access to the information after the decision has been made. There may be legislative requirements with respect to retention periods and counsel should be consulted as to these retention periods.
4.5.4 Personal information that is no longer required to fulfil the identified purposes should be destroyed, erased or made anonymous. BlackRock Canada should develop guidelines and implement procedures to govern the destruction of personal information, subject to legal and practical considerations relating to the destruction of archived information.
4.6. Accuracy Personal information shall be as accurate, complete, and up-to-date as is necessary for the purposes for which it is to be used.
Commentary: The purpose of Principle 6 is to strike a balance between repeated and frequent inquiries relating to BlackRock Canada’s clients’ personal information and the clients’ expectation that BlackRock Canada is acting upon personal information that is accurate, complete and up-to-date.
4.6.1 The extent to which personal information shall be accurate, complete and up-to-date will depend upon the use of information, taking into account the interests of the client. Information shall be sufficiently accurate, complete and up-to-date to minimize the possibility that inappropriate information may be used to make a decision about the client.
Commentary: At some point, personal information of a client collected by BlackRock Canada will become stale. BlackRock Canada should establish procedures to ensure that personal information of its clients is reviewed and updated on a regular basis, depending on the nature of the actual use of such information. For example, it would be appropriate to verify mailing addresses for the purpose of delivering materials mandated by law. However, it would not be appropriate to update such information solely for the purpose of delivering marketing materials. Similarly, it would be inappropriate to update financial information of a client for the sole purpose of marketing BlackRock Canada’s products, but it would be appropriate to update such information for the purpose of determining the appropriateness of a client’s particular investment.
Commentary: In order to ensure that clients are not contacted more frequently than is necessary, BlackRock Canada’s update procedures relating to personal information should restrict to a minimum the gathering of personal information directly from clients.
Commentary: The procedures instituted by BlackRock Canada to keep personal information of its clients up-to-date shall also apply to information collected and properly disclosed to third parties. BlackRock should promptly notify such third parties of any change in the personal information previously delivered if such notification is appropriate.
4.6.3 Personal information that is used on an on-going basis, including information that is disclosed to third parties, should generally be accurate and up-to-date, unless limits to the requirement for accuracy are clearly set out.4.6.2 BlackRock Canada shall not routinely update personal information, unless such a process is necessary to fulfill the purposes for which it was collected.
Personal information shall be protected by security safeguards appropriate to the sensitivity of the information.
4.7.1 The security safeguards shall protect personal information against loss or theft, as well as unauthorized access, disclosure, copying, use, or modification. BlackRock Canada shall protect personal information regardless of the format in which it is held.
Commentary. The protection of personal information by security safeguards required under Principle 7 begins with an assessment of all information received by, flowing through, or released by BlackRock Canada. In assessing all such information, BlackRock Canada must identify that information which is “personal information”.
4.7.2 The nature of the safeguards will vary depending on the sensitivity of the information that has been collected, the amount, distribution, and format of the information, and the method of storage. More sensitive information should be safeguarded by a higher level of protection.
4.7.3 The methods of protection should include:
(a) physical measures, for example, locked filing cabinets and restricted access to offices;
(b) organizational measures, for example, security clearances and limiting access on a “need-to- know” basis;
(c) technological measures, for example, the use of passwords and encryption; and
(d) contractual measures, for example, the use of non-disclosure agreements with third parties to which BlackRock Canada discloses personal information.
4.7.4 BlackRock Canada shall be responsible for making the importance ofmaintaining the confidentiality of personal information known to its agents, employees and any relevant third parties.
4.7.5 Care shall be used in the disposal or destruction of personal information, to prevent unauthorized parties from gaining access to the information.
BlackRock Canada shall make readily available to clients specific information about its policies and practices relating to the management of personal information.
4.8.1 BlackRock Canada shall be open about its policies and practices with respect to the management of personal information. Clients shall be able to acquire information about BlackRock Canada’s policies and practices without unreasonable effort. This information shall be made available in a form that is generally understandable.
4.8.2 The information made available shall include:
(a) the name or title and address of the person who is accountable for BlackRock Canada’s policies and practices (or how to obtain that information) and to whom complaints or inquiries can be forwarded;
(b) the means of gaining access to personal information held by BlackRock Canada;
(c) a description of the type of personal information held by BlackRock Canada, including a general account of its use; and
(d) a copy of any brochures or other information that explain BlackRock Canada’s policies, standards, or codes; and
4.8.3 BlackRock Canada may make information on its policies and practices available in a variety of ways. The method chosen depends on the nature of the relevant business and other considerations. For example, BlackRock Canada may choose to make brochures available in its place of business, mail information to its customers, provide online access, or establish a toll-free telephone number.
4.9. Client Access
Upon request, a client shall be informed of the existence, use, and disclosure of his or her personal information and shall be given access to that information. A client shall be able to challenge the accuracy and completeness of the information and have it amended as appropriate.
Commentary: In certain situations, BlackRock Canada may not be able to provide access to all the personal information it holds about a client. Exceptions to the access requirement should be limited and specific. The reasons for denying access should be provided to the client upon request. Exceptions may include prohibitive cost, personal information that contains references to other clients, information that cannot be disclosed for legal, security or commercial proprietary reasons, and information that is subject to solicitor-client or litigation privilege.
4.9.1 BlackRock Canada shall respond to a written request for client access with due diligence and in any case not later than 30 days after receipt of the request or any permitted extension by informing the client whether or not BlackRock holds personal information about the client. The client shall be allowed access to this information unless to do so would (1) reveal personal information about a third party, (2) breach a solicitor-client privilege, (3) potentially threaten the life or security of another individual, (4) disclose personal information collected to investigate a breach of an agreement or contravention of law, or (5) reveal information generated in the course of a dispute resolution process. In addition, BlackRock Canada shall provide an account of the use that has been made or is being made of this information and an account of the third parties to which it has been disclosed. If such a request is denied, the client shall have the right to be given reasons for the denial.
4.9.2 Before BlackRock Canada provides an account of the existence, use, and disclosure of personal information of a particular client, the client may be required to provide sufficient information to permit BlackRock Canada to provide an account of the existence, use and disclosure of personal information. The information provided shall only be used for this purpose.
4.9.3 Any account of third parties to which BlackRock Canada has disclosed personal information about a client should be as specific as possible. When it is not possible to provide a list of the organizations to which information about a client has actually been disclosed, a list of organizations to which such information may have been disclosed shall be provided to the client.
4.9.4 The requested information shall be provided or made available in a form that is generally understandable. For example, if abbreviations or codes are used to record information or other industry, or company-specific terminology, an explanation shall be provided. Access to personal information shall be given in an alternative format, such as to an individual with a sensory disability, if conversion into that format is reasonable and necessary in order for the individual to exercise rights of access.
4.9.5 When a client successfully demonstrates the inaccuracy or incompleteness of personal information, the information will be amended as required. Depending upon the nature of the information challenged, amendment could involve the correction, deletion or addition of information. Where appropriate, the amended information shall be transmitted to third parties having access to the information in question.
4.9.6 When a challenge is not resolved to the satisfaction of the client, the substance of the unresolved challenge shall be recorded. When appropriate, the existence of the unresolved challenge shall be transmitted to third parties having access to the information in question.
Commentary. The following steps should be considered to ensure compliance with Principle 9:
1. Conduct a review of all personal information held, its use and the third parties that receive this information.
2. Create policies and procedures that cover:
(i) What information is to be disclosed to clients upon request;
(ii) All exceptions and circumstances in which information should be withheld;
(iii) Process for clients to request access to their personal information;
(iv) How the information is to be communicated (verbal, letter, fax, e-mail) to the client and what if any explanatory information should accompany the correspondence;
(v) Which senior officer of the firm is responsible for resolving disputes with clients over the accuracy or completeness of their personal information;
(vi) Response time that is expected for inquiries of this nature; and
(vii) Escalation procedures in the case of disputes.
3. Identification of a specific individual or department to maintain a database or file of all disputes and the final outcome whether resolved or unresolved. Particular attention should be paid to those disputes that remain unresolved.
4. Creation of specific literature to inform clients of the right to access their personal information and the process to do so. If appropriate, this disclosure can be incorporated in existing client literature (e.g. prospectus)
5. Annual review of the unresolved disputes to determine if common issues exist such that changes to the policies and procedures should be considered.
6. Annual review and update of the policies and procedures.
4.10. Challenging Compliance
A client shall be able to address a challenge concerning compliance with the above principles to the designated individual or individuals accountable for BlackRock Canada’s compliance.
4.10.1 The individual accountable for BlackRock Canada’s compliance is discussed in Clause 4.1.1.
4.10.2 Procedures should be put in place to receive and respond to complaints or inquiries about BlackRock Canada’s policies and practices relating to the handling of personal information. The complaint procedures should be easily accessible and simple to use. Initial complaints from investors in BlackRock Canada’s retail investment funds should be directed to the iShares Call Centre, 1-866-iShares (1-866-474-2737). Initial complaints from “institutional” clients or their employees, officers, etc. should be directed to the Client’s client representative and, if not resolved, elevated to the accountable individual. 4.10.3 BlackRock Canada shall inform clients who make inquiries or lodge complaints of the existence of relevant complaint procedures. A range of these proceduresmay exist. For example, the Investment Industry Regulatory Organization of Canada (“IIROC”) or securities regulators may accept complaints about the personal information handling practices of any BlackRock companies they regulate.
Commentary. Client relationship staff should be knowledgeable as to how a complaint should be initiated so that the information can be relayed to the client. Once initiated, confirmation of receipt of the complaint should be sent to the client. The individual(s) handling the complaint should inform the client of the procedure that will take place. This information could be delivered via a leaflet or in a letter or similar document. The document should also include the role, if any, of regulatory bodies or other overseeing organizations.
4.10.4 All complaints shall be investigated. If a complaint is found to be justified through either the internal or external complaint review process, appropriate measures shall be taken, including the amendment of policies and practices, if necessary. 4.10.5 In addition to the remedies provided in the Personal Information Protection and Electronic Documents Act, clients who are dissatisfied with the manner in which their complaints have been handled may contact the securities regulator in the jurisdiction in which they reside.
Commentary. In such a case, the head of the Institutional Client Businessgroup, in consultation with counsel, should inform the client of the option to bring the complaint to the attention of the appropriate provincial or territorial securities regulator (although this should have already been outlined at the beginning of the complaint process). In that case, all pertinent information shall be forwarded to the appropriate securities regulator and assistance shall be provided to staff of the relevant securities regulatory authority in their investigation.