Cookie and Consent Policy

This policy is governed by Quebec's Law 25 and by the federal Personal Information Protection and Electronic Documents Act. It is not written against the European framework, and it does not borrow a European banner, because the Canadian requirements differ in ways that matter and a copied foreign notice tends to describe obligations the site does not have while omitting ones it does.

The short version

Before you make a choice, this site loads nothing from any third party. Not analytics, not a tag manager, not a font, not a map, not a video embed, not a chat widget.

That is a stronger statement than most cookie notices make, and it is meant literally. The technology is not loaded and then asked to stay quiet. It is never written into the page at all until you have chosen.

Why that distinction matters

A great many consent banners in Canada do something different. The page loads, the analytics library downloads, a measurement request is sent, and the banner appears alongside all of it. The visitor is then asked to agree to something that has already happened.

Law 25 requires consent before the technology is activated, not after. A banner that appears while measurement is already running is not obtaining consent; it is announcing a decision that was made for the visitor.

There is a second problem with that arrangement, and it is the one a regulator would find hardest to excuse. A cookie policy in that situation describes controls the site does not actually have. The gap between the stated policy and the observed behaviour is the finding, more than the tracking itself.

This site is built so that gap cannot open. Anything requiring consent is written into the page in an inert form that a browser will not execute, and it is promoted to a live script only when a choice permits it. If you refuse, nothing is promoted, and nothing runs.

What is stored before you choose

Nothing.

Not a consent record, not an identifier, not a preference. While there is nothing on this site that needs your permission, there is no decision to record, so nothing is written to your device at all.

When there is something to decide, your decision is what gets stored. It is kept on your own device so you are not asked again on every page, and written only at the moment you choose. Closing the notice writes nothing. Pressing Escape writes nothing. Reading on writes nothing.

The record is built to be checked a year later. A bare yes or no proves nothing when the question turns out to be what exactly somebody agreed to and when, so the record carries the date and time, the version of the text you were shown, the language you were addressed in, the page that text lives on, every purpose the panel offered, and which of them you allowed. You can read it yourself, in your browser's local storage, under the name ibcf_consent.

It is not sent anywhere, it identifies nobody, and clearing your browser storage removes it, after which you will be asked again.

The purposes

A purpose appears on the panel when, and only when, something on the site belongs to it. A switch that controls nothing is a misleading representation rather than a courtesy, and on a site about money it is the kind a regulator notices. The list below is the vocabulary the site is built to speak; the panel shows the part of it that is currently true.

Essential. The record of the choice you make, and nothing else. It cannot be switched off, because switching off that record would mean asking you again on every page.

Measurement. Counting which pages are read, so the practice can tell what is worth writing next. Not needed in order for you to read anything.

Advertising. Technology that measures advertising or builds an audience for it.

Features you ask for. A map, a video or a chat window that loads when you choose to open it rather than when the page loads.

You may allow one purpose and refuse another. Consent here is per purpose, not all or nothing, and a notice offering only Accept or a route back to reading is not offering a choice.

What is actually in each purpose today

Essential: the consent record, when there is a consent to record. Nothing else.

Measurement: nothing. Advertising: nothing. Features you ask for: nothing.

Which is why the panel, today, shows one row and says in as many words that there is nothing here to accept or refuse. That is a stronger statement than an empty category with switches attached, and you can verify it in a minute by the method set out at the end of this page.

When something is placed in a purpose, this section names it: the technology, what it is for, who provides it, and how long anything it stores persists, before it goes live rather than afterwards.

How consent is obtained

A notice appears when there is something to ask about, and before that thing has made its first request. While nothing on the site needs your permission, no notice appears, because a notice asking a question with no subject is theatre. The preferences panel is still one click away in the footer, and it says plainly that there is nothing to decide.

Refuse and Accept are presented identically. Same size, same weight, same colour, side by side, with only the word different. A refusal rendered as a faint link beneath a prominent button is not a genuine choice, and the asymmetry is itself the mechanism by which agreement is extracted. This is measured rather than asserted: the two are compared as the browser draws them, at four screen widths and in both languages, and any difference stops publication.

Closing the notice stores nothing. There is a close control, the Escape key does the same thing, and neither records agreement. Neither counts as a refusal either: your decision is left whole, and the notice returns on the next page to ask again. Silence is not agreement, and neither is carrying on reading. A notice that banked your indifference as permission would be the worst pattern of the lot, precisely because it looks polite.

A third option lets you choose purpose by purpose rather than accepting or refusing everything.

Nothing is preselected. Optional purposes are off when the panel opens. A preticked box is not consent, it is an announcement.

The whole notice works from the keyboard. Focus lands on Refuse, never on Accept, and every control is large enough to hit without precision. Nothing on the notice falls below the standard set out on the accessibility page.

How to withdraw

Withdrawal is as easy as granting, which the law requires and which many sites do not deliver.

A Cookie preferences link appears in the footer of every page on this site. It reopens the same panel, with your current choices shown, and it is available whether you accepted, refused, or chose purpose by purpose. Accepting takes one click. Withdrawing takes two: the link, then Refuse all.

Withdrawal acts at once, without waiting for a reload. Switching a purpose off removes the element added to the page for it, returns any embed that had been allowed to connect to its inert state, stops any feature that can be stopped, and deletes the cookies that purpose was allowed to leave.

The one thing no website can undo is code that has already run in the page in front of you. That is how browsers work rather than a limitation of this site, and it stops when you reload or move on. The panel says so on its own face rather than implying otherwise.

Clearing your browser storage has the same effect and returns you to being asked afresh.

There is no form, no email, and no request to reconsider.

What is currently in use, and what is not

This section is a register rather than a promise. It states what is running as at the review date shown on this page, and it is updated when that changes. A policy that declared permanent absences would become inaccurate the moment anything was added, which is the failure this page criticises elsewhere.

Currently in use. Nothing. Not even the consent record, because there is currently no consent to record.

Currently not in use. Analytics of any kind. Advertising or measurement pixels. Embedded video. Embedded maps. A chat widget. An automated assistant. Social media widgets or share buttons that connect on page load. Externally hosted typefaces or stylesheets.

Served from this domain rather than from a third party. Typefaces and stylesheets. A font requested from an external service transmits the visitor's address to that service at page load, before any notice appears, which is a disclosure no banner can cure. Serving them here removes the disclosure instead of consenting to it.

Linked rather than embedded. Video, maps and social profiles. A link causes no request until it is followed, so a page containing links to a social profile sends nothing to that platform unless you click.

When something is added

The practice expects to add capabilities to this website over time: video, social media integration, a chat facility, an automated assistant able to answer questions, and measurement to understand which material is useful. Saying so now is more honest than a policy implying nothing will ever change.

Four rules govern any addition. What makes them worth stating is that none of them depends on anybody remembering: each is checked when the site is built, and a change that breaks one of them cannot be published.

One. It is placed in a purpose before it is placed on the site. Every third-party technology belongs to Measurement, to Advertising, or to the Features you ask for purpose described below. A technology naming a purpose that has not been defined, in both languages, with a sentence saying what it is for, fails the build. Nothing is added outside the structure, because nothing outside the structure can be published.

Two. It is gated by default. Anything requiring consent is written into the page in an inert form the browser will not execute, and promoted only when a choice permits it. A page carrying a live address belonging to anyone but this site fails the build, whatever it is and whoever added it. That check is what makes the first paragraph of this policy a property of the site rather than a promise about it.

Three. The register above is updated in the same change. The technology, its purpose, its provider and its retention period are named here before it goes live, not afterwards.

Four. The consent version changes, and you are asked again. Your stored choice carries the version of the text you agreed to, and half of that version comes from the set of purposes the site gates. Adding a technology therefore changes the version by itself, every stored consent retires, and everyone is asked again. A second check works from the other direction: if a purpose appears that was not on the panel when you chose, your stored answer cannot cover it and you are asked again on the evidence of your own record.

The Functional category

A purpose exists for technology that a visitor actively invokes rather than one that measures them. It is described now so that the structure is in place before anything occupies it. It does not appear on the panel until something does, for the reason given above.

A chat facility or automated assistant. Where such a feature is added, it loads only when you choose to open it, not on page load. What you type into a chat is information you have submitted, so it is governed by the privacy policy rather than by this one. If an automated assistant is used, the provider processing those messages will be named there, along with whether messages are retained and for how long. An assistant answering questions about insurance also does not give advice, for the same reasons set out on the disclaimer page.

Embedded video. Where a video is embedded rather than linked, the embed connects to the hosting platform. Such an embed would sit behind consent and would be named in the register above.

Social media integration. Sharing buttons and embedded feeds connect to the platform on page load, which is why the site currently links to profiles instead. Any move from linking to embedding is a change to what runs and would be treated as one.

Maps. Same mechanism, same treatment. An address shown as text with a link achieves the same thing for a reader and sends nothing to a mapping provider.

The distinction that matters is not whether a feature is useful. It is whether it makes a request before you have chosen, and the answer for anything in this category is that it will not.

There is a second distinction worth drawing, because the two are often confused. A feature that stores something on your device is governed by this policy. A feature that receives something you typed is governed by the privacy policy. A chat facility does both, which is why it appears in both documents rather than being described once and cross-referenced. Where an automated assistant is involved, a third question arises that neither document has answered before: whether what you type is used to train a system belonging to someone else. When such a facility is added, that question will be answered here explicitly rather than left to a provider's own terms, because a visitor should not have to read a third party's documentation to find out what happens to a sentence they typed on this website.

Consent for email is a separate thing

Agreeing to measurement on a website is not agreeing to receive email, and the two are kept apart.

Canada's anti-spam legislation requires express consent for commercial electronic messages, obtained separately, with the sender identified and an unsubscribe mechanism in every message. On the discovery meeting page the request to be contacted about a meeting and the optional agreement to receive educational material are two distinct checkboxes, and the second is not required to submit the first.

Bundling them would be simpler and would not be valid.

Server logs

Like any web server, the server hosting this site records requests: the address they came from, the page requested, the time, and the browser identifier sent by your software. This happens at the network level, before any page is rendered, and it is not something a consent notice can prevent on any website.

These records exist for security and for diagnosing faults. They are not used to build a profile, they are not combined with anything else, and they are retained only as long as needed for those purposes.

This is disclosed because a policy that describes only what a banner controls, and stays silent about what the server records regardless, is describing half the picture.

If this policy changes

The consent record carries a version, and the version has two halves: a date that is raised by hand when the wording of the notice changes in a way that affects what was agreed to, and a list of the purposes the site actually gates, which the build works out for itself. If this policy changes in a way that affects what you agreed to, the version changes with it and you are asked again rather than treated as having consented to something that did not exist when you chose.

Changes that do not affect what runs, corrections of wording, added explanation, do not reset your choice. That is why the two halves are separate.

Every page on this site carries the date it was last reviewed, and this one is no exception.

Questions, and the person responsible

The person responsible for the protection of personal information at the practice is named in the privacy notice at the foot of every page, together with a postal address, an email address and a telephone number that reach a person rather than a queue.

If you want to know what is held about you, ask. If you want it corrected or deleted, ask. Neither request requires a reason and neither is treated as a complaint.

The standard this policy is trying to meet

Not the minimum that avoids a finding.

A cookie policy is one of the few documents on a website where a reader can check the claims themselves. Open the developer tools in your browser, look at the network panel, reload this page without touching the notice, and see what is requested. Every statement above is verifiable that way in under a minute.

The practice does the same to itself before publishing. Every page is loaded in a browser with no consent decision stored and the network recorded, and the number of requests to any address other than this one has to be zero. At the last check that was all 158 pages of this site, and the count was zero.

That is the standard worth holding: a policy that describes behaviour you can observe. A policy that cannot survive that test is not a policy, it is a statement of intent, and the difference matters most to the people least able to check.