Jacinta is a Dealing Representative with WealthSource Partners Inc.

The correct answer is D. If Jacinta shares the list with Saabir without obtaining the clients’ prior consent, she will be in breach of the Personal Information Protection and Electronic Documents Act (PIPEDA).

PIPEDA is the federal privacy law for private-sector organizations in Canada. It sets out the ground rules for how businesses must handle personal information in the course of their commercial activity. One of the key principles of PIPEDA is consent. This means that organizations must obtain meaningful consent from individuals before collecting, using, or disclosing their personal information, unless an exception applies. Consent must be obtained for the original purpose of collecting the information, and for any new purpose that arises later. Consent can be express or implied, depending on the sensitivity of the information and the reasonable expectations of the individual.

In this scenario, Jacinta’s clients’ personal information is sensitive, as it relates to their financial situation and investment goals. Jacinta’s clients would not reasonably expect that their information would be shared with Saabir, who is not affiliated with WealthSource Partners Inc., for the purpose of marketing insurance products. Therefore, Jacinta must obtain express consent from her clients before disclosing their information to Saabir. If she does not, she will violate PIPEDA and risk legal action from her clients or from the Office of the Privacy Commissioner (OPC).