Investment expertise

Investment expertise

Our investment team is made up of experienced professionals with specific expertise, skills and knowledge. The members of the team have managed money through all markets. They follow a team-based approach to draw on the strengths and expertise of every member of the investment team.

By webcentre , 5 June 2025
President and Chief Investment Officer
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As President and Chief Investment Officer at Empire Life Investments Inc. Paul leads both the equity and fixed income investment teams who collectively manage certain Empire Life segregated funds1 and the insurance company’s general funds.

As Senior Vice-President and Chief Investment Officer at Empire Life, Paul Holba is responsible for the management and oversight of Empire Life’s assets. In addition to being a member of Empire Life’s Executive Leadership Team he also sits on the Asset Management Committee and Product Review Management Committee of Empire Life. He continues to work closely with distribution partners to communicate strategies and results.

He joined Empire Life’s retail distribution division in 2009, moving into the Vice-President, Investments role with Empire Life Investments Inc. in 2010. Prior to that, Paul was the Vice-President, Retail Distribution.

Before joining Empire Life, he spent more than 20 years working in the Canadian investment industry through progressively senior roles with global investment management firms and the asset management division of a major Canadian bank.

Paul has a Bachelor of Mathematics with a specialty in business from the University of Waterloo. He is a Chartered Financial Analyst (CFA) charterholder and a member of the CFA Institute and the Toronto CFA Society.

1 Policies are issued by The Empire Life Insurance Company.

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Company Policies

These policies outline the Company’s requirements under the Accessibility for Ontarians with Disabilities Act, 2005 (“AODA”).

Customer Service Standards - Further Information
Training staff
  • Designated employees will be trained on policies, practices and procedures affecting the way services are provided to people living with disabilities. Employees will also be trained on an ongoing basis when changes are made to these policies, practices and procedures
  • Training is developed and delivered during Corporate Orientation and as required when an employee transfers to a position where they are required to deal with the public.
  • Training will focus on:
    • The purpose of the Accessibility for Ontarians with Disabilities Act, 2005 and the requirements of the Customer Service Standard.
    • How to interact and communicate with people with various types of disabilities.
    • How to interact with people with disabilities who use an assistive device or require the assistance of a service animal or a support person.
    • How to use and maintain assistive devices available on Empire Life Investments’ property
    • What to do if a person with a disability is having difficulty accessing Empire Life Investments’ services.
    • Our accessibility policy, procedures and practices relating to the Customer Service Standard
Feedback Process
  • The ultimate goal of Empire Life Investments is to meet and surpass customer expectations while serving customers living with disabilities. Comments on our services regarding how well those expectations are being met are welcome and appreciated. 
  • A Customer Feedback Form can be obtained:
    • By emailing: [email protected]
    • By faxing: 1 877 390 6557
    • By calling Bell Relay Service to speak with our Customer Service line: 1 855 823-6883.
  • You may also provide feedback in person by arranging an appointment with the Ombudsman at 1 877 548-1881 Extension 3236
  • All feedback regardless of format will be directed to the Ombudsman. Customers can expect to hear back within 10 (ten)  business days.
Workplace Emergency Preparedness
  • We are committed to implementing workplace emergency preparedness procedures which take into account all persons who might be within an Empire Life premises during the time of an emergency including those living with disabilities.
  • We are committed to providing individualized workplace emergency response information to employees who self-identify as having a disability and that individualized information is necessary.
  • For any employee who receives individualized workplace emergency response information and who requests and consents to receiving assistance during an emergency, a designated person will provide this assistance.
  • We will review individualized workplace emergency response information when:
    • an employee moves to a different location within the Company;
    • the employee’s overall accommodation needs or plans are reviewed; and
    • the Company reviews its general emergency response policies.
Modifications to the Customer Service Standards Policy or other policies
  • No changes will be made to this policy before considering the impact on persons living with disabilities.
  • Any Empire Life Investments operational policy affecting customer service that does not respect and promote the dignity and independence of persons living with disabilities will be modified or revoked.
Questions about our Company Accessibility Policy and procedures
  • If anyone wishes to receive a copy of the Policy and/or Procedures in an alternate format or has a question about their content or purpose, please contact:
     
    Company Ombudsman
    The Empire Life Insurance Company
    275 King St. E 
    Kingston ON K7L 3A8 
    E-mail: [email protected]
    Phone: 1 877 548 1881 Extension 3236
     
Copyright

The contents of this site are protected by copyright. Visitors to this site may copy information for their own non-commercial personal use but may not republish or reproduce any part without the prior written permission of Empire Life Investments Inc. Republishing and reproducing includes any uploading, downloading or providing access to the information on this site on the Internet or any other local or international computer system or means of distribution. An acknowledgement of the source must be included whenever our materials are copied or published.

If you require further information about how you may use the information on this site, please contact us by phone, by letter,  or by e-mail.

Empire Life Investments Inc. will take appropriate legal action in response to any infringement of its rights. Empire Life Investments Inc. disclaims any and all liability which may result from any unauthorized reproduction or use of the information on this site.

Trademarks

The Empire Life Insurance Company owns all the trademarks used on or in connection with the goods and services provided by Empire Life Investments Inc. Empire Life Investments Inc. uses such trademarks under license. The trademarks are protected by Canadian laws. All rights reserved.

Terms of use

The purpose of this Web site is to provide general information about Empire Life Investments and its products and services.

Before using this site, please read the following terms of use carefully. As the terms of use may change at any time, you should regularly review them to ensure that your understanding of the terms is up-to-date. Any references to “you” or “your” means the person or entity using or accessing this site. References to “Empire Life Investments” shall be deemed to include Empire Life Investments Inc. and its subsidiaries.

The information and features contained in this Web site, as well as the Web site itself (collectively, the “Internet Service”), may be modified or upgraded without notice. Empire Life Investments does not guarantee the accuracy or completeness of any of the Web site content, its functionality or transmission capability.

Empire Life Investments provides its Internet Service on this Web site to you, subject to these terms of use which may be updated by us from time to time without notice to you. By accessing or using the Internet Service, you acknowledge and agree to these terms of use. In addition, you shall be subject to any other guidelines or rules applicable to the Internet Service which may be published from time to time. All such guidelines or rules are hereby incorporated by reference into these terms of use. If you do not agree with these terms of use, please exit this Web site.

Empire Life Investments makes commercially reasonable efforts to maintain the availability of this Web site. However, Empire Life Investments reserves the right to shut down this Web site in order to perform maintenance, updates and other reasonable adjustments. Some or all of the Internet Service may be unavailable during such times.

Empire Life Investments reserves the right at any time to modify or discontinue, temporarily or permanently, the Internet Service (or any part thereof) with or without notice. You agree that Empire Life Investments shall not be liable to you or to any third party for any modification, suspension or discontinuance of the Internet Service. You agree to indemnify and hold Empire Life Investments (and its officers, agents and employees) harmless from any claim or demand, including reasonable legal fees and expenses, made by any third party due to or arising out of your use of the Internet Service, your connection to the Internet Service, or your violation of the terms of use.

You agree that Empire Life Investments, in its sole discretion, may terminate use of the Internet Service for any reason, including, without limitation, if Empire Life Investments believes that you have violated or acted inconsistently with the letter or spirit of the terms of use. You agree that any termination of your access to the Internet Service under any provision of the terms of use may be effected without prior notice. Further, you agree that Empire Life Investments shall not be liable to you or any third party for any termination of your access to the Internet Service.

You agree that you will not (i) interfere with the functioning of the Internet Service; (ii) bypass any measures used to secure or restrict access to the Internet Service; (iii) impose an unreasonable or disproportionately large burden on the Internet Service's infrastructure; or (iv) employ any automatic devices or means to use or access the Internet Service.

If you have access to password protected sections of the Web site, you may provide or be provided with confidential or personal information which must be collected, used and disclosed in accordance with the laws and industry guidelines relating to privacy in the jurisdictions in which we operate. (Please see our On-line Privacy Policy for more information relating to privacy.) You agree to keep any password strictly confidential and to be responsible for any Internet Service use connected to your password. You also agree to notify Empire Life Investments immediately if you know or have reason to believe that the security of your password has been compromised.

You acknowledge and agree that the information presented to you through the Internet Service is protected by copyrights, trademarks, service marks, patents and/or other proprietary rights and laws. Except as expressly authorized by Empire Life Investments, you agree not to modify, rent, lease, loan, sell, distribute or create derivative works based on the Internet Service, in whole or in part.

Your use of the Internet Service is at your sole risk. Any material downloaded or otherwise obtained through the use of the Internet Service is at your own discretion and risk. You will be solely responsible for any damage to your computer system or loss of data that results from the download of any such material. The Internet Service is provided on an "as is" and "as available" basis. Empire Life Investments expressly disclaims all warranties of any kind, whether express or implied.

Without limiting the generality of the foregoing, Empire Life Investments makes no warranty that

(i) the Internet Service will meet your requirements,  
(ii) the Internet Service will be uninterrupted, timely, secure or error-free, or  
(iii) any errors will be corrected.

No advice or information, whether oral or written, obtained by you from Empire Life Investments or through or from the Internet Service shall create any warranty not expressly stated in the terms of use.

The Internet Service is not intended to provide financial, legal, medical, accounting or tax advice, and should not be used or relied upon as a substitute for professional advice or your independent research.

This Web site may provide links to other Web sites or resources or it may be accessed via a link from other Web sites or resources. Empire Life Investments has no control over these Web sites or resources, does not endorse any content found on them, and is not responsible for any consequences resulting from your use of them.

Empire Life Investments shall not be liable for any direct, indirect, incidental, special, consequential or exemplary damages, including but not limited to damages for loss of profits, goodwill, use, data or other intangible losses (even if Empire Life Investments has been advised of the possibility of such damages), resulting from:

(i) the use of, or the inability to use, the Internet Service,  
(ii) unauthorized access to or alteration of your transmissions or data, or  
(iii) any other matters relating to the Internet Service.

The laws of the Province of Ontario and the applicable laws of Canada shall govern the terms of use and the relationship between you and Empire Life Investments with respect to the use of the Internet Service. You hereby consent and submit to the jurisdiction of the courts of the Province of Ontario in connection with any proceedings arising from the Internet Service or your use of this Web site.

The failure of Empire Life Investments to exercise or enforce any right or provision of the terms of use shall not constitute a waiver of such right or provision. If any provision of the terms of use is found by a court of competent jurisdiction to be invalid, the parties nevertheless agree that the court should endeavour to give effect to the parties' intentions as reflected in the provision, and the other provisions of the terms of use shall remain in full force and effect. You agree that regardless of any statute or law to the contrary, any claim or cause of action arising out of or related to use of the Internet Service or the terms of use must be filed within one (1) year after such claim or cause of action arose or be forever barred.

Important Information
Use of information on this site

The information herein is not intended to provide legal, accounting, tax or investment advice. If such advice is required, you should seek the services of a qualified professional. Views expressed regarding any particular company, security, industry or market sector are the views of only that individual at that time, are subject to change and do not necessarily represent the views of Empire Life Investments.

Your Personal Information and Your Privacy

The Empire Life Insurance Company and Empire Life Investments Inc. (“Empire Life”), are committed to respecting your privacy and protecting your personal information. Here's an overview of our personal information practices. Please read our Privacy Notice for full details or click on any link below for more information on a specific topic.

Collection of personal information

We collect your personal information when you:

  • submit a product application or a form,
  • apply for a job or
  • apply to distribute our products.

We may also collect your personal information over the phone or through an on-line chat with our customer service representatives.

Generally, we obtain your express consent before we collect your personal information. Whenever possible we will collect personal information directly from you but may also collect it from third parties. We only collect the personal information we need.

Sharing your personal information

Generally, we obtain your express consent before we disclose your personal information and we may do so:

  • to individuals or other entities you have permitted us to disclose your personal information to
  • to individuals or other entities you have permitted us to disclose your personal information to
  • where required by law (e.g., CRA, law enforcement)

Your privacy rights

You have the right:

  • to request information about our privacy practices, and
  • to request access to your personal information and have it updated or corrected if needed.

If you have a question, concern or would like access to your personal information, please contact us.

Use of your personal information

We will tell you why we need your personal information. Some of the uses of your personal information include:

  • to identify and verify you
  • to approve and manage your products or services
  • for quality assurance/process improvement
  • to meet our legal obligations
  • to present you with product or service offers
  • to process a claim
  • to review a job application

Our websites and web portals use cookies to enable them to properly function. We may also use cookies (or other technology) to understand how visitors use our website. These cookies don't collect personal information.

Protection and retention of your personal information
We're committed to protecting your personal information with administrative, technological and physical safeguards.
We'll retain your personal information:

  • for as long as required for the purposes we collect it, and
  • in compliance with our legal obligations

Privacy Policy

Privacy Notice

An important part of any relationship is trust. At Empire Life we work hard to earn and maintain your trust through our commitment to fairness, integrity, and respect in all our dealings with you. This includes our handling of your personal information and respecting your privacy rights. This privacy notice represents our commitment to transparency regarding our practices related to the management of personal information.

Who this privacy notice applies to

This privacy notice applies to:

  • our customers, former customers and individuals who apply for our products or use our services
  • life insureds, policy beneficiaries and group plan members
  • advisors who sell our products or provide service to our customers
  • individuals who contact us, for example, by phone, email, website, web portal or postal mail
  • individuals who apply for a job posting
  • individuals who visit our website

Note: If you apply for a job at Empire Life through our website, your information will be collected by ADP, Inc., our human resources management system provider, on our behalf. For more information on ADP's privacy practices, please visit ADP's Privacy Statement.

What is personal information?

Personal information means any factual or subjective information concerning an identifiable individual. We obtain consent before or at the time we collect personal information (with limited legal exceptions).

Collection of personal information

Depending on your relationship with us, we may collect personal information such as the examples listed below:

Financial information—which may include banking information, tax information, income, current employer or net worth.

Contact and demographic information—which may include your name, address, telephone number, email address, date of birth, marital status or language preference.

Medical information—which may include a list of medical professionals who provide services, medical history of you or your family (excluding genetic testing) or the results of laboratory tests.

Lifestyle information—which may include smoking status, alcohol consumption, driving history or travel plans.

Whenever possible we'll collect personal information directly from you or from someone you've authorized. We may also collect information about you from others such as your advisor or group plan administrator, and depending on the product,

If you apply for a life insurance policy, we may also collect information from (i) MIB Group, Inc. (MIB), a cooperative data exchange between its members that the life and health insurance companies, (ii) Health-care providers such as doctors, hospitals, clinics or other health-care professionals that provide services to you, or (iii) policy beneficiaries, claimants or estate executor in the event of death. 

If you are purchasing an investment product, we may collect information from your beneficiary or the executor of your estate in the event of your death.

If you are a group plan member, we may collect information from paramedical benefits providers and organizations that assist us in providing you with services such as travel health benefits and prescription coverage.

We will also collect personal Information we are required to collect by law.

As this is not an exhaustive list of who we may collect information about you from, please speak with your advisor or contact us to discuss any questions you may have about who may share information about you with Empire Life.

Use of personal information

We obtain consent (with limited legal exceptions) to use personal information before or at the time we collect it and before we use personal information for a new purpose. Depending on our relationship with you and the products you apply for or purchase, we may use your personal information to:

  • verify your identity and assess your application for a product or service
  • inform you about the features of your current products and present you with new offerings that may be of interest to you
  • administer your policy and provide you with customer service, including paying claims and processing transactions
  • help us improve our services and develop programs for our customers
  • We may also use, or provide to third parties, personal information that has been de-identified or aggregated :
  • to build and improve our products, services, websites or web portals
  • for statistical analysis
  • for study and research purposes
  • We will not: use your social insurance number for any purpose other than tax reporting without your consent
Sharing of personal information

Depending on your relationship with us, we may share your personal information, for the purposes for which it was collected with:

  • your advisor (and their agency, firm or market intermediary)
  • your group benefits administrator
  • third parties that may assist us in providing you with products and managing our business please click for a list of categories of third parties
  • other insurance or reinsurance companies, MIB, administrators of government benefits or other benefits programs
  • organizations that demonstrate their legal authority to have it (e.g., government institutions)
  • individuals you have granted us permission to (e.g. your power of attorney, beneficiary or executor of your estate, in the event of your death)
  • paramedical services providers
  • your doctor if we deem it is in your best interest
  • if required by law
Retention and protection of personal information

We'll keep your personal information for as long as required for the purposes we collected if for and as required to meet legal requirements.

We protect personal information using a wide variety of security measures designed to secure your personal information and strictly control who can access it. We use various administrative, technological, and physical safeguards to protect your personal information, such as passwords and limiting access to only authorized individuals who need access to perform their job. Security safeguards also include steps to ensure that all third parties with whom we contract and who may be required to handle personal information have implemented comparable security measures. We also regularly provide our employees with privacy training.

Data analytics

To develop new and innovative products, to improve our existing offerings and to be an organization that is simple, fast and easy to deal with, we may use your personal information to conduct analytic studies or develop artificial intelligence (AI) or machine learning models. Generally, we use de-identified personal information to conduct our studies or develop new models, but if we require identifiable personal information, we'll first obtain your consent.

Automated decision-making

Automated decision-making is the process of rendering a decision by automated means without any human involvement which may include the use of artificial intelligence or machine learning.

If Empire Life uses your personal information for automated decision-making, we will:

  • ensure it is lawful, fair and transparent, and
  • inform you before or at the time the decision is rendered.
  • You'll have the right to request the:
  • personal information used to render the decision;
  • the principal factors that led to the decision (with some exceptions); and
  • personal information used to render the decision be corrected, if it was inaccurate.

You'll also have the right to ask questions regarding any automated decision made by Empire Life impacting you.

Cookies

Our website uses:
Session cookies to enable our website to remember your journey through our website. If we didn't use a session cookie, the website would think you were a new visitor every time you moved to another page (i.e., you couldn't go back to the page you were just on). This type of cookie is temporary and is deleted when you close your browser. Session cookies contain session information only.

Persistent cookies to function as your identification card - recording your preferences. This type of cookie persists after you close your browser and has an expiration date.

Performance cookies to improve our website's performance by, for example, counting page visits, examining how much time a user has spent on a website and/or analyzing loading speeds. They also enable our website to collect analytics data and perform other functions that provide a good user experience.

Our cookies do not collect personal information

Your privacy rights

You have certain rights you may exercise after we collect your personal information to:

Withdraw your consent
At any time, with reasonable notice, you may withdraw your consent to allow Empire Life to collect, use and disclose your personal information for any purpose, subject to legal and/or contractual restrictions.

When you request to withdraw your consent, we'll notify you at that time of any implications of such a withdrawal, which may include termination of a policy, termination of benefits or inability to process a claim.

Your withdrawal of consent is not retroactive.

Request information about data processing
Upon request, we'll provide you with:

  • personal information we collected from you;
  • categories of employees who have access to your information;
  • period of time your information will be kept;
  • contact information of the Empire Life Chief Privacy Officer; and
  • source of your personal information when we collect it from a third party (unless prevented from doing so by law).

Request access to your personal information and have it corrected if necessary
You can request access to personal information we hold about you. There may be a small charge for doing so.
To make a request, please send your written request to:
Chief Privacy Officer
The Empire Life Insurance Company
259 King Street East
Kingston, ON K7L 3A8
Fax: 1 800 920-5868
Email:[email protected]

We'll make every effort to respond to your request within 30 days. If we are unable to respond within 30 days, we'll let you know and explain why additional time is required.

If you're registered for our customer portal, you have the right to access and correct your personal information and privacy preferences at any time which may be done by you (self service option) or by contacting customer service.

File a complaint
If you have a question or concern with how we handle your personal information, we want to know. Please contact us.

If you would like to know more about our privacy policies or ask questions about accessing your personal information, please contact us either by phone or in writing at:

Empire Life 
259 King Street East 
Kingston, Ontario 
Canada K7L 3A8 
Telephone: 1-877-548-1881 (North America) 
Telephone: 1-613-548-1881 (All others) 
Email: [email protected] 
Please include your name, address, and/or email address when you contact us.

Privacy Policy

Introduction

The protection of personal information is an integral part of doing business at Empire Life Investments Inc. (“ELII”). Protecting personal information is important to us and this policy sets out how we collect and manage personal information in a manner that protects the personal privacy of our clients, contractors and employees.

What is Personal Information?

In this document, "personal information" means any factual or subjective information concerning an identifiable individual.

Personal information may be collected concerning a variety of individuals with whom our company does business, including from clients, beneficiaries, employees, contractors and dealers.

Personal information can be collected in a variety of forms, including written (such as correspondence and memoranda) as well as electronic communications and records, video or audio recordings and photographs.

Examples of personal information include information concerning an individual's name, age, sex, health, personal characteristics or personal and financial circumstances. Personal information can also include such things as identification numbers (such as SIN or employee numbers), banking and income information and employment records. 

Personal information does not include the name, title or business address, telephone number or e-mail address of employees of an organization. 

At ELII, we follow 10 privacy principles:

Principle 1: Accountability

ELII is responsible for personal information under its control and has designated an individual or individuals who are accountable for compliance with this policy. 

ELII, its employees and contractors are responsible for all personal information in their possession or control, including information that has been obtained from or transferred to a third party for processing.

A Privacy Officer has been designated as accountable for adherence by ELII to this policy and applicable privacy statutes, regulations and guidelines. Where appropriate, the responsibilities of the Privacy Officer may be delegated to an individual or individuals within a particular business area familiar with the nature of the personal information collected within the area and any special needs the area may have concerning the protection of personal information.

Principle 2: Identifying Purposes

ELII will identify the purposes for which personal information is being collected before or at the time that the information is collected. 

ELII collects personal information in a number of ways. For example, information may be collected on an application, during a personal interview or through other means. Prior to or at the time of collection, ELII will identify the purpose of collection. This may be communicated in writing or orally, depending upon the manner in which the information is collected. 

Persons collecting personal information are expected to be able to explain to individuals the purposes for which the information is being collected.

ELII will not collect, use, or disclose information beyond that required to fulfil the purposes specified at the time of collection.

Unless the new purpose is required by law, before using personal information for a purpose not previously identified, the company will identify the new purpose and obtain the consent of the individual to its use.

Principle 3: Consent

ELII must obtain the knowledge and consent of the individual to the collection, use and disclosure of personal information, except where inappropriate. 

Usually, ELII will obtain consent for the use or disclosure of personal information at the time of collection. Sometimes, consent will be obtained after the information has been collected but prior to use (for example, when the company wishes to use information for a purpose not previously identified). 

ELII may seek consent in a variety of ways, depending on the circumstances and the type of information collected. The company will generally seek express consent when the personal information is likely to be considered sensitive. 

Sometimes consent may be obtained from an authorized representative, such as a legal guardian or person holding a power of attorney.

Implied consent may be inferred in circumstances where the information is less sensitive and consent to collection, use or disclosure can be reasonably inferred.

In certain limited circumstances, personal information can be collected, used, or disclosed without the knowledge and consent of the individual. For example, legal or security reasons may make it impossible or impractical to seek consent. When information is being collected for the investigation of a potential breach of contract, the prevention or detection of fraud or for law enforcement purposes, seeking the consent of the individual might defeat the purpose of collecting the information. Similarly, seeking consent may be impossible or inappropriate when the individual is a minor, seriously ill, or otherwise incapacitated.

An individual may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice. ELII will inform the individual of the implications of such withdrawal, which may include the inability to administer an account and/or maintain record of the units.

Principle 4: Limiting Collection

The collection of personal information will be limited to that which is reasonably necessary for the purposes identified by ELII. Information shall be collected only by fair and lawful means.

The company will not collect personal information indiscriminately. Both the amount and the type of information collected shall be limited to that which is reasonably necessary to fulfil the purposes identified. 

Information will be collected in a manner that complies with the company's obligations to identify the purpose of collection and to obtain the consent of the individual to collection, use and disclosure of personal information.

Principle 5: Limiting Use, Disclosure, and Retention

ELII will not use or disclose personal information for purposes other than those for which it was collected, except with the consent of the individual or in accordance with the exceptions set out above. Personal information will be retained only as long as necessary for the fulfilment of those purposes. 

Personal information that has been used to make a decision about an individual will be retained long enough to allow the individual access to the information after the decision has been made.

Personal information that is no longer required to fulfil its purpose shall be destroyed in accordance with the Empire Life Record Retention policy.

Principle 6: Accuracy

Personal information will be as accurate, complete and up-to-date as is necessary for the purposes for which it is to be used.

The extent to which personal information shall be updated will depend upon the use of the information, taking into account the interests of the individual. Information will be sufficiently accurate, complete and up-to-date to minimize the possibility that inappropriate information may be used to make a decision about the individual. 

ELII will not routinely update personal information, unless such a process is necessary to fulfil the purposes for which the information was collected.

Principle 7: Safeguards

Personal information will be protected by security safeguards appropriate to the sensitivity of the information.

ELII has implemented security safeguards and appropriate training to protect personal information against loss or theft, as well as unauthorized access, disclosure, copying, use or modification. 

Security safeguards vary depending on the nature and format of the information collected. The methods of protection include physical, organizational and technological measures designed to limit access to authorized persons, ensure the integrity of the information and protect it from unauthorized use or disclosure. 

Security safeguards also include steps to ensure that all third parties with whom we contract and who may be required to handle personal information have implemented comparable security measures.

Principle 8: Openness

ELII will make readily available to individuals specific information about its policies and practices relating to the management of personal information. 

The information made available shall include: 

  • the name or title, and the address, of those accountable for the company's policies and practices and to whom complaints or inquiries can be forwarded;
  • the means of gaining access to personal information held by the company;
  • a description of the type of personal information held the company and a general account of its use;
  • a copy of this policy and any other brochures or information that explain or elaborate upon this policy; and
  • what personal information is made available to related organizations or subsidiaries.
Principle 9: Individual Access

Upon request, an individual will be informed of the existence, use, and disclosure of his or her personal information and shall be given access to that information. An individual will be able to challenge the accuracy and completeness of the information and have it amended as appropriate. 

Upon request, ELII will inform an individual whether or not is holds personal information about the individual, will permit the individual to access the information and provide an account of the use made of the information, including any disclosure to third parties (if any).

In certain situations, ELII may not be able to provide access to all of the personal information it holds about an individual. Exceptions to the access requirement will be limited and specific, and the reasons for denying access will be provided to the individual upon requests. Exceptions may include information that is prohibitively costly to provide, information that contains references to other individuals, information that cannot be disclosed for legal security, or commercial proprietary reasons, information that has been obtained in the course of an investigation of a potential breach of contract or fraud, and information that is subject to solicitor-client or litigation privilege.

ELII will respond to an individual’s request within a reasonable time and at minimal or no cost to the individual. The requested information will be provided or made available in a form that is generally understandable. For example, when abbreviations or codes are used an explanation will be provided upon request. If the individual requests copies of any of the documents in the files of ELII, a reasonable fee may be charged for duplication. 

When an individual successfully demonstrates the inaccuracy or incompleteness of personal information, ELII will amend the information as required. Depending on the nature of the information challenged, amendment may mean the correction, deletion or addition of information. 

When a challenge is not resolved to the satisfaction of the individual, the substance of the challenge will be recorded. The individual will also be entitled to place in the file a statement as to their position and the documents they rely on in support of that position.

Principle 10: Challenging Compliance

An individual may address a challenge concerning compliance with this policy to the Compliance Officer at ELII. 

ELII will inform individuals who make inquiries or lodge complaints of the applicable complaint handling protocol. 

ELII will investigate and respond to all complaints in accordance with the applicable departmental complaint handling protocol. If a complaint is found to be justified, ELII will take appropriate measures, including if necessary, amending its policies and procedures.

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