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MCAP Privacy Code - Our Commitment to You
The MCAP Group is committed to fairly and lawfully collecting and maintaining accurate personal information and to protecting the confidentiality of all personal information that we collect, retain, use, or disclose to others during our business activities.
Our Continuing Commitment to You
Protecting the privacy and confidentiality of personal information has always been fundamental to the way we do business at MCAP. We strive to meet or exceed all the privacy standards established by federal, provincial and industry authorities in all our dealings with past, current, and prospective customers.
We Live by It – Everyday
Every MCAP employee annually signs a declaration acknowledging their agreement to be bound by the MCAP Code of Business Conduct, which includes references to this MCAP Privacy Code (the “Code“) and a confidentiality section obligating them to maintain the confidentiality of information both during and after their employment with MCAP.
MCAP has a Chief Privacy Officer (“CPO”) and has established a complaints procedure to ensure compliance with this Code.
Do You Have Questions or Concerns?
If you have privacy questions, concerns, or complaints, we want them to be answered as quickly as possible and ask that you follow, in order, the following three steps.
Talk to a Customer Service Agent. They can usually handle most questions or concerns immediately over the phone. All pertinent numbers and email addresses can be found on our “Contact Us” page on our website or by following this link.
If the Customer Service Agent is unable to resolve the matter to your satisfaction, advise them that you wish the matter to be reviewed by the department manager who will contact you to resolve the issue. You may be asked to put your concern or complaint in writing.
If you are still not satisfied, contact MCAP’s CPO at:
Mark Adams – Chief Privacy Officer
Mail: Suite # 400 200 King Street West
Toronto, ON M5H 3T4
If the above steps fail to resolve your concern to your satisfaction, you may submit your issue to the Privacy Commissioner of Canada, who you may contact at any time in this process, by writing to:
The Privacy Commissioner of Canada
30 Victoria Street Gatineau, Quebec K1A 1H3
Or by telephone, toll free, at 1 800 282 1376 or by TTY at 1 819 994 6591
MCAP Roles and Responsibilities
Any MCAP employee who believes personal information is not being handled in accordance with this Code is required to immediately advise their manager and the CPO.
Department managers are required to resolve privacy issues (as per the second step in our privacy question and complaint handling process) and shall maintain appropriate records of the same and shall report them to the CPO.
Department managers are responsible for oversight of this Code within their department, including establishing, implementing, and regularly reviewing the necessary procedures and standards to give effect to this Code and to train their staff accordingly. MCAP’s CPO is responsible for providing advice to the department managers on appropriate compliance programs and for reviewing the effectiveness of such programs.
The CPO or their delegate shall act as a resource to department managers in the handling of complaints and shall maintain a list of all privacy incident reports as required by applicable law, the nature and number of privacy issues reviewed and any recommendations with respect to privacy strategies, oversight and policies.
The CPO or their delegate will assist department managers with developing procedures, standards, guidelines, and interpretations, promoting awareness of privacy issues and developing staff training programs.
Keeping This Privacy Code Current
Changes to privacy legislation and the personal information handling practices of MCAP will result in amendments to this document from time to time. The Code will be reviewed by MCAP’s CPO, at a minimum, annually. MCAP may add, delete, or modify sections at its discretion. Any changes MCAP makes to this Code will be effective when the revised Code is posted on the MCAP website. We recommend that you check this page from time to time to inform yourself of any changes to this Code.
MCAP Privacy Code Last Updated: August 2023