Maintain a foundation of trust
Table of Contents
Obsessed with your success
Manage our impact responsibly
Supplemental reporting
Appendices and Glossary
Overview
DATA PRIVACY Our approach Our comprehensive Privacy Compliance framework establishes the principles of our organization-wide privacy management program to protect the personal information of our clients and comply with applicable legal and regulatory requirements. Our Chief Privacy Officer oversees our privacy management program and is responsible to set and monitor the effectiveness of related policies and procedures. The Governance and Conduct Review (GCR) Committee of the Board oversees privacy risk management and receives regular reporting as part of its oversight responsibilities. Incidents involving suspected or actual breaches of privacy are documented and investigated by our Privacy Office. If a privacy breach has occurred, our teams follow established procedures to limit its impact, understand the root cause of the incident, ensure that the issue is remediated and take preventative steps to avoid recurrence. Where appropriate, we notify applicable regulators and impacted individuals.
Our privacy management program extends to third-party service providers, and we assess their privacy management practices and controls prior to providing them with any personal information of our clients. Once satisfied with the service provider’s procedures and safeguards, we will only provide them with the personal information required to deliver contracted services. Training and awareness We make privacy a key focus for our team members and take steps to ensure they are aware of privacy-related regulatory obligations relevant to their role, know how to comply with those obligations, and are accountable to achieve effective compliance. All team members are required to undergo privacy training as part of their onboarding experience, and on an annual basis thereafter. Privacy principles, such as only accessing information for legitimate business purposes, are also embedded in our Code of Conduct, which applies to all our directors, officers and team members.
Refer to our Privacy Statement and Online Privacy and Interest-Based Advertising Statement to learn more about our privacy management practices, including an overview of how we collect, use and disclose personal information, and the choices clients may exercise in this regard.
19 2023 SUSTAINABILITY REPORT AND PUBLIC ACCOUNTABILITY STATEMENT
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