Client Identification and Verification Policy

Purpose

This policy explains how NEO Legal Services Professional Corporation identifies its clients and verifies their identity, as the Law Society of Ontario's By-Law 7.1 requires. These steps help protect clients and the public from fraud, identity theft and money laundering.

Who it applies to

Every licensee, employee and contractor of the firm, for every new client and every new matter.

Identifying every client

Before we act, we record:

• For an individual: full name, home address, telephone number and occupation.
• For an organization: its name, address and telephone number, its incorporation or business number, the nature of its business, and the name and position of each person who gives us instructions for it.

Verifying identity

By-Law 7.1 requires a licensee to verify a client's identity using reliable, independent documents in specified situations, including when the licensee receives, pays or transfers funds for the client. NEO verifies the identity of every client when they set up their account, whether or not the By-Law requires it in their matter. We do this by:

1. Checking a valid, original, government-issued photo identification document, in person or by video or through our secure online identity check; or
2. Another method the By-Law permits, where photo identification isn't suitable.

Where a client is outside Ontario, we may use an agent under a written agreement, as the By-Law allows.

Records

We keep a record of the information we obtained, the documents we checked and when. Identity images are kept in private, encrypted storage that only the people who need them can open, for at least as long as By-Law 7.1 requires: the longer of the client relationship and six years after the work is completed.

If something doesn't add up

If we become aware that we may be assisting in fraud or other illegal conduct, we will not act, or we will stop acting, as the Law Society's rules require.

Review

This policy is reviewed at least once a year, and whenever the Law Society's By-Laws or rules change. The principal approves every change.

Questions

Email info@neolegalservices.com, call 647-200-3526 or toll-free 888-519-2435, or write to us at Unit 236, 1099 Kingston Road, Pickering, Ontario L1V 1B5.