Policy development · Fintech & financial services
Privacy & Security Policy Development for Wealth Management & Robo-Advisors
Written policy is what turns NI 31-103's system-of-controls requirement from an assumption into evidence a CIRO examiner or CSA reviewer can actually read. We draft the privacy, security and data-governance documents a registrant needs, covering everything from KYC retention to off-channel messaging, so the firm has answers ready before a sweep letter asks the question. Most engagements start when a compliance review finds the firm operating on memory rather than documented policy.
Reviewed by the Privacy Horizon team · Last reviewed
What you're protecting
What registrant policy has to define, not just imply
A generic privacy-policy template collapses fast against a wealth firm's actual data flows. The policies we draft are built around the records and channels specific to this business.
Who may access KYC and suitability files
The policy sets role-based access to identity, income and risk-profile data, including how access changes when an advisor leaves or moves books, so the rule matches the platform's actual permission model.
How EFT and withdrawal instructions are changed
A written procedure requiring verification before any banking-detail change on a client account, closing the gap that BEC and impersonation fraud routinely target.
What advisors may say off the firm's recorded channels
Electronic-communications policy defines which platforms are approved for client business and what happens to messages sent outside them, a topic supervisory reviews increasingly probe.
How long each record type is kept
A retention schedule that reconciles securities record-keeping expectations for trade and account records against privacy law's limit on keeping personal information longer than its purpose requires.
Regulatory map
Why NI 31-103 and CSA guidance expect this in writing
Regulators do not accept an unwritten system of controls. Policy is the artifact that lets a registrant demonstrate supervision exists and is followed, not merely intended.
NI 31-103 s. 11.1's system of controls
Registrants must maintain a system of controls and supervision appropriate to their business, and CSA staff read that requirement as extending into cybersecurity and data governance, not stopping at trading supervision.
CSA Staff Notice 33-321's policy expectations
Built from a survey of more than 1,000 firms, the notice sets out expectations for written cybersecurity policies, incident response readiness, vendor due diligence and staff training.
CSA Staff Notice 31-342's online-adviser model
Online advisers operate under the same NI 31-103 controls as any registered portfolio manager, so a robo-advisor's onboarding and suitability documentation needs the same policy rigour as a traditional PM's.
PIPEDA's limiting-use and retention principles
Personal information collected for one purpose cannot be repurposed indefinitely, and it should not be kept beyond what that purpose requires, a constraint the retention schedule has to sit inside alongside securities record rules.
What goes wrong
What missing policy exposes a registrant to
Firms rarely fail because they lacked good instincts. They fail because nothing was written down for a new hire, an examiner or an incident responder to follow.
A sweep letter with no policy to produce
A CSA compliance sweep referencing Staff Notice 33-321 asks for documents, and a firm that can only describe its practices verbally starts the review at a disadvantage before a single control is even assessed.
Retention decisions made ad hoc, account by account
Without a written schedule, one advisor deletes files aggressively and another keeps everything, producing inconsistent answers to a client's access request and an uneven privacy risk across the book.
Off-channel messaging with no consequence
If policy never states which platforms are approved, advisors default to whatever is convenient, and client instructions or KYC details end up in unmonitored, unrecorded channels.
Vendor commitments nobody wrote down
Without a documented vendor-management policy, due diligence on the portfolio platform, custodian and statement vendors happens inconsistently or not at all, which a sweep or DDQ will surface immediately.
Our policy development for wealth management & robo-advisors
What the policy engagement delivers for a registrant
Documents are drafted to reflect how your firm actually operates, then aligned with the regulations that govern you, rather than adapted from a generic corporate template.
A cybersecurity and privacy policy suite
Core documents covering access control, data handling, retention, incident response linkage and acceptable use, drafted with NI 31-103 and CSA guidance in view.
An electronic-communications and off-channel policy
Clear rules on approved platforms for client business, recordkeeping expectations, and the consequences for conducting business outside them.
A retention schedule reconciling two regimes
A single reference table setting retention periods for KYC, trade records, tax slips and communications, built to satisfy securities record-keeping and privacy limitation principles at once.
Vendor and third-party policy
Written expectations for custodians, portfolio-platform providers and statement or mail-house vendors, covering due-diligence steps, contract terms and ongoing oversight.
Ongoing updates as rules evolve
Revisions as CIRO and CSA guidance shifts or as new systems are adopted, so the policy suite stays current instead of drifting from what the firm actually does.
How the engagement runs
How the policies get built with your compliance team
Step 1
Review current practice
We map what the firm actually does today across KYC handling, retention, communications and vendor management, identifying where practice and paper already diverge.
Step 2
Draft against the applicable rules
Each policy is written to reflect NI 31-103, CSA guidance and PIPEDA or Law 25 as they apply to your registration category and client base, in language your staff can follow.
Step 3
Review with the CCO and UDP
Drafts go through a working review with compliance leadership to confirm the policies match operational reality before adoption, avoiding rules nobody can actually follow.
Step 4
Roll out and revisit
Policies are communicated to staff, tied into training, and revisited on a schedule or after a material change to systems or regulation.
What it costs
What drives policy development pricing for a registrant
Cost depends on how many policy documents are in scope, whether you are a CIRO dealer with additional 3703-linked requirements or a CSA-only PM, how many systems and provinces the retention schedule has to reconcile, and how much of the current documentation can be revised rather than written from scratch.
The Minimum Viable Privacy program includes policy development as one of its core components. Tell us your registration categories and current documentation state and we will scope the work.
Wealth Management & Robo-Advisors: Policy development questions, answered
Section 11.1 does not list specific documents, but CSA staff have made clear through Staff Notice 33-321 that a working system of controls implies written policy covering access management, incident response, vendor due diligence and staff training at minimum. Examiners assess whether the policy exists, matches practice and is actually followed, so the documents need to be specific to your systems rather than generic statements of intent.
Yes, and it is one of the more frequently missing documents at small registrants. The policy names which platforms are approved for client business, states that client instructions and KYC discussion belong on recorded channels, and sets consequences for conducting business elsewhere. Without it, advisors default to personal texting or messaging apps, which creates both a supervision gap and a recordkeeping problem.
The two obligations pull in different directions: securities recordkeeping expects trade and account records kept for defined minimum periods, while privacy principles say personal information should not be kept longer than its purpose requires. We resolve this by setting retention periods per record type that satisfy the longer of the two applicable requirements, then documenting the reasoning so the schedule can be defended to either a securities examiner or a privacy regulator.
The regulatory foundation is the same, since CSA Staff Notice 31-342 treats online advisers as registered portfolio managers, but the operational detail differs. A robo-advisor's policies need explicit language on the onboarding questionnaire's automated collection, the advising representative's review checkpoint, and how consent and disclosure are presented in a digital flow, where a traditional PM's policies focus more on advisor-managed paper and in-person KYC updates.
At minimum annually, and immediately after a material change: a new portfolio platform, a new custodian relationship, an online-adviser registration filing, or updated CIRO or CSA guidance. Policies that sit untouched for several years tend to fall out of step with what the firm actually does, which is precisely what a sweep or exam is designed to catch.
Yes, and pairing them closes the gap between what a policy says and what staff actually do. Once a policy is drafted, it becomes the basis for role-specific training sessions for advisors and operations staff, so the written document and the behaviour it expects are introduced to the team together rather than as separate, disconnected exercises.
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