Significant Business Disruption Business Continuity and Disaster Recovery Plan Disclosure
Policy
The Company’s primary focus is to attempt to provide continuous and uninterrupted services to our
clients. However, as a result of any significant business disruption, the Company will act immediately
to quickly recover and resume operations, protecting all of the Company’s books and records, and
allowing our clients to transact business. In the event that we determine we are unable to continue
our business, we will make every effort to assure clients prompt access to their funds and securities.
Responsibility
The CCO is responsible for creating and maintaining the Company’s immediate and long -term
contingency planning and recovery procedures that are appropriate to the scale and scope of the
Company’s business.
Notification of Proper Authorities
After an emergency has been declared, the CCO, or designee, will notify the proper regulatory
authorities of the nature of the emergency, and the temporary location of the Company. Additionally,
the same party will notify the local public utilities, the telephone company, the post office and any
other vendor as deemed necessary.
Telephone Service/Fax
In the event the Company’s primary telephone line is disrupted, phone and fax lines will be
forwarded to 905.337.2227.
Temporary Operation Location/Recovery Site
If the primary office is inaccessible, the Company will temporarily relocate to the following address:
1295 Cornwall Road, Unit A3, Oakville, Ontario L6J 7T5.
Client data is easily accessible at any remote location with Internet access as client data, including
e mail correspondence and pertinent books and records are backed up daily to the Company’s cloud
drive, maintained by our offsite storage vendor.
The electronic backup, where used by the Company, is maintained away from the Company’s primary
business location (via the Cloud) to allow for retrieval of client records where the primary office
location is not accessible
Equipment/Hardware
The Company will maintain a list of all equipment, hardware and software used by the Company. The
list shall contain the item, the serial number, the manufacturers and serial/registration number, where
such information is available and retrievable by the Company. The CCO will notify the Company’s
insurance company of any damage.
If the Company’s computer system is deemed unusable for any reason, the Company will procure
another computer at that time. Time constraints for the purchase, delivery, and installation of a
computer will depend on a number of outside factors such as the retailer, delivery services, and the
consultant hired to install the computer, but it is expected that the Company will only be without a
computer for a maximum of two business days. Once the new computer is installed, the last tape
backup will be restored to the new system
Mail Service
Mail will be forwarded to the temporary office location as described above under “Temporary Operation Location/Recovery Site”.
Client Information and Client Trading Records
Original client agreements, contracts, profiles, and other documentation related to each client as well
as trading records, brokerage statements and confirmations are maintained at the principal place of
business for the appropriate time that is required by law.
Copies of pertinent client information shall be kept at a secure off-site location. If it is not practical to
keep paper copies, electronic facsimiles may be kept in a format that is easily retrievable, i.e. pdf, tif,
gif, etc., and in a timely manner. Periodically, the CCO will review these disaster recovery plans
pertaining to client’s records to assure that these records will be adequately maintained in the event
of a disaster or emergency.
Copies of pertinent client information shall be kept at a secure off-site location. If it is not practical to keep paper copies, electronic facsimiles may be kept in a format that is easily retrievable, i.e. pdf, tif, gif, etc., and in a timely manner. Periodically, the CCO will review these disaster recovery plans pertaining to client’s records to assure that these records will be adequately maintained in the event of a disaster or emergency.
Custodian
Copies of all client records are also maintained by the custodian(s) holding the client’s assets. The
Company can access all client files from the custodian’s facilities should the need arise. If a client
needed immediate access to their account, and for any reason could not contact Company, the client
could contact his or her custodian(s) directly.
Client Contact
If a disaster occurs, every effort will be made by the Company to contact all clients. This will either be
done by phone calls, emails, general mailing, and/or posting a message on the Company website. A
list of all clients is maintained in the Company’s account management system and can also be
received by contacting the relevant account custodian.
Financial Data/Resources
The Company’s financial information is stored in a financial software data file that is included in the
backup procedures discussed above.
The Company has adequate liquid reserves to maintain business continuity and shall acquire
business insurance if deemed necessary.
Updates and Annual Review
The Company will update this plan whenever there is a material change to the Company’s operations,
structure, business or location or to those of our custodian (or any other critical service providers). In
addition, the Company will test and update the plan, at least annually, to ensure the plan remains
consistent with the Company’s policy and overall business operations.
Should you have any questions regarding this disclosure, please contact Joshua J. Prince, President and
CCO of Promus Advisors.
