Introduction

On January 1, 2004, the use of personal information in Canadian commercial activities was protected by new federal legislation under the Personal Information Protection and Electronic Documents Act (PIPEDA).

PIPEDA is a new law that protects personal information in the hands of private sector organizations and provides guidelines for the collection, use and disclosure of that information in the course of commercial activity.

The Act is based on the ten privacy principles developed by the Canadian Standards Association (CSA). It is overseen by the Privacy Commissioner of Ontario and the federal court. These ten principles form the ground rules for the collection, use and disclosure of personal information. The Act also addresses the right of individuals to have access to their personal information and to have it corrected if necessary.

Educators Financial Group (Educators Financial Group) is committed to maintaining the accuracy, confidentiality and security of your personal information. As part of our commitment, we follow the Ten Privacy Principles established by the Canadian Standards Association's Model Code as outlined below.

Principle 1 - Accountability

Educators Financial Group is accountable for all personal information in its possession including any personal information transferred to third parties for processing. We have a designated individual who is responsible for Educators Financial Group's compliance with the Ten Privacy Principles.

Principle 2 - Identifying Purposes

Educators Financial Group will inform individuals of the purposes for which personal information is collected at or before the time the information is collected.

Principle 3 - Consent

An individual's knowledge and consent are required for the collection, use or disclosure of personal information except where inappropriate.

Principle 4 - Limiting Collection

The collection of personal information shall be limited to that which is necessary for the purposes identified by Educators Financial Group. The information shall be collected by fair and lawful means.

Principle 5 - Limiting Use, Disclosure and Retention

Educators Financial Group will only use or disclose personal information for the purposes for which it was collected, unless an individual gives consent to use or disclose it for other reasons. Educators Financial Group may have a legal duty or right to disclose personal information without consent. Personal information may only be retained for the period of time required to fulfill the purpose for which it was collected.

Principle 6 - Accuracy

Educators Financial Group will ensure that the personal information we have on file is as accurate, complete and up-to-date as is necessary for the purposes for which it is to be used.

Principle 7 - Safeguards

Educators Financial Group has security safeguards in place that are appropriate to the sensitivity level of the information.

Principle 8 - Openness

Educators Financial Group will make information available to individuals specific information about its policies and practices relating to the management of their personal information.

Principle 9 - Individual Access

Upon request, Educators Financial Group will inform an individual of the existence, use and disclosure of his or her personal information, and will give the individual access to the information. An individual will be able to verify the accuracy and completeness of their information and have it amended as appropriate.

Principle 10 - Challenging Compliance

Clients may direct any questions or enquiries with respect to the privacy principles outlined above by contacting the Privacy Officer at 1-800-263-9541.

To ensure that Educators Financial Group is abiding to Principle 1 - Accountability, the appointed individual responsible for privacy compliance will implement policies and practices to ensure that:

• procedures are established to protect the privacy of personal information;
• procedures are established to receive and respond to complaints and inquires;
• Educators Financial Group staff are trained and understand the policies and practices

What is Personal Information?

Personal information includes any factual or subjective information, recorded or not, about an identifiable individual. In layman's terms, personal information is information that we collect with your consent that specifically identifies you as an individual.

Obtaining Consent

Educators Financial Group will inform and obtain permission from an individual before or when it collects, uses or discloses personal information.

Educators Financial Group may collect, use or disclose personal information without the knowledge or consent of an individual only in limited circumstances as permitted by law if:

• it is clearly in the best interests of the individual and consent cannot be obtained in a timely manner( i.e. in an emergency situation where the individual's life, health or security is threatened);
• the information is publicly available

What personal information do we collect?

Educators Financial Group will collect only the amount and type of information needed for the purposes documented by Educators Financial Group and identified to the individual. The information we ask for depends on the nature of your request and is limited to that which is required to process your request. The information collected is gathered primarily through our Client Account Application forms. Examples of information collected and maintained in your client file is as follows: Name

• Age
• Address
• Social Insurance Number
• Date of Birth
• Spouse's Name, Address, Social Insurance Number and Date of Birth if applicable
• Telephone Number(s)
• School Board / Affiliation
• E-mail Address
• Investment Knowledge
• Investment Income
• Risk Tolerance
• Gross Annual Income
• Net Worth
• Bank Information (void cheque)

Although we need this information to properly meet your needs, you may at any time, refuse to provide or withhold certain personal information. However, in that case, we will not always be able to deliver a complete range of services, advise you properly or meet some of your needs.

Under certain circumstances, Educators Financial Group may disclose personal information without consent when required or permitted by law. Some examples are: subpoenas, search warrants

• bankruptcy - collection of debts
• disclosure to a lawyer who represents Educators Financial Group
• CCRA(Canada Customs and Revenue Agency) - for registration of new accounts and for income tax reporting

Why do we ask for your personal information?

We only collect, use and disclose personal information for the following purposes:

• to offer and provide access to mutual funds, mortgages and other related products and services;
• to establish an investment account;
• to verify your identity and protect you against fraud;
• to fully understand your investment needs, objectives and tolerance for risk so that we may determine appropriate investment strategies for you;
• to establish and maintain services that you have requested such as PAC's (Pre-Authorized Chequing) and Group Payroll Deduction Plans;
• to establish and maintain communications with you through newsletters, quarterly statements and special mailings;
• to provide you with information about our products and services;
• to meet legal and regulatory requirements

Maintaining accuracy

On request, Educators Financial Group will inform individuals of the existence, use and disclosure of their personal information and provide access to that information to ensure its accuracy and completeness.

Educators Financial Group will update personal information only if it is necessary for the purpose for which it was collected.

Educators Financial Group also relies on individuals to inform us if there are any changes to their personal information. To amend or make a change to your information please contact our office at 1-800-263-9541. While some changes (i.e. address, telephone number, etc.) may be changed verbally over the phone or via our website, other changes require written authorization.

Once notified, we will revise the personal information indicated and if necessary, notify any third parties to whom the incorrect or outdated information was disclosed.

Individuals may access and verify their information (transactional or personal) by reviewing your quarterly account statements, by viewing your account information online or by speaking or meeting with one of our Client Advisory team members.

How do we safeguard your personal information?

At Educators Financial Group we maintain current security standards to ensure that personal and financial information is protected against unauthorized access, disclosure, inappropriate alteration or misuse. All safety and security measures are appropriate to the sensitivity of the information.

Educators Financial Group may transfer personal information to third parties to administer the delivery of products and services to individuals. Examples are as follows:

• statement producers;
• mailing houses;
• software developers and data storage providers

Educators Financial Group will require these third parties to have safeguard measures in place that are consistent with those of Educators Financial Group and/or as regulated by law.

Educators Financial Group may disclose personal information to credit bureaus and mortgage insurers with the individual's consent.

All client files are maintained in locked filing cabinets in an area that is monitored by motion detectors.

Access to your confidential information is restricted to and may only be accessed by employees whose professional duties require them to do so.

All Educators Financial Group employees must respect and adhere to our internal privacy policy. As well, employees are required to adhere to IFIC's Privacy Code and sign a confidentiality agreement prohibiting the disclosure of client information to outside parties.

Educators Financial Group will use professional shredding services when disposing of or destroying personal information in order to prevent unauthorized access to the information.

Online Security

Educators Financial Group uses the Investortrax system, designed and maintained by Unisen Inc., which enables investors to access their fund data via the internet, 24 hours a day, 7 days a week. Investortrax is equipped with the latest and most sophisticated security mechanisms to ensure unauthorized users cannot access your account information. Data transmitted over this site is secure and private.

Our server environment is managed appropriately and our firewall infrastructure is strictly adhered to. All security practices are reviewed on a regular basis.

Communicating openly

Educators Financial Group will openly communicate to individuals our policies and procedures for the management of personal information. Educators Financial Group will provide the information to individuals in a format that is easy to understand.

Providing access

On request, Educators Financial Group will advise individuals as to the type of personal information Educators Financial Group has in its possession or control, provide individuals with access to that information and inform them as to which third parties the information has been disclosed.

Educators Financial Group will require individuals to be specific about the personal information they are requesting to permit Educators Financial Group, to provide an accurate account of the existence, use and disclosure of the individuals personal information.

Educators Financial Group will respond to an individual's request not later than 30 days after receiving the request. Educators Financial Group will provide the requested information in a format that is easy to understand.

In certain situations, Educators Financial Group may not be able to provide access to personal information in its possession or control. Some examples are: the information may contain references to other individuals that that could result in a threat to the security of those individuals

• the information is protected by solicitor-client privilege;
• the information has been collected for the purposes of a legal investigation
• by providing access to the information, it may reveal personal information about a third party

If Educators Financial Group refuses the individual's request to access personal information, Educators Financial Group will inform the individual in writing of the refusal and the reasons why.

Questions, Concerns and Complaints

As a client of Educators Financial Group you have the right to inquire about any aspect of our company's compliance policy as it relates to the protection of your personal information. The privacy and confidentiality of your personal information is our highest priority. If you have any questions or concerns please do not hesitate to contact our Privacy Officer at 1 (800) 263-9541. If you are not completely satisfied with our response, you may file a formal complaint with the Federal Privacy Commissioner.