Privacy

The CAAT Pension Plan and its agents are committed to protecting your privacy and the confidentiality of your personal information.

Privacy Statement

This Privacy Statement describes how we collect, use, disclose and protect your personal information.

Our Privacy Statement is modelled after the principles of the federal Personal Information Protection and Electronic Documents Act (PIPEDA).

We are responsible for protecting the personal information under our control

Personal information refers to information that can identify you, such as your name, date of birth or pension information. This Privacy Statement does not apply to information that is not personal information.

Accountability

The Plan has appointed a Privacy Officer to ensure compliance with this Privacy Statement and our personal information handling practices. This Privacy Officer oversees all activities related to the development, implementation, maintenance, and adherence to this Privacy Statement.

Why we collect, use and retain your personal information

Your personal information is necessary in order for us to be able to administer the Pension Plan and fulfil our legal and regulatory reporting obligations. Accordingly, generally the Plan will limit the use of your personal information:

  • to calculate and pay benefits under the Plan;
  • to create and maintain a database of individuals entitled to benefits under the Plan;
  • to produce and issue various personalized pension statements, notices and retirement or termination options documents;
  • to verify eligibility of claims for benefit entitlement;
  • to fulfil reporting requirements and compliance with the Pension Benefits Act (Ontario), the Income Tax Act (Canada) and any other pension or family law legislation applicable in your jurisdiction, to the extent that they apply;
  • in some instances, to verify your identity when communicating with you;
  • to manage and administer the Plan including to collect funds owing to the Plan;
  • to maintain business and other records for reasonable periods;
  • to meet legal, regulatory, insurance, security and processing requirements; and
  • otherwise with your consent or as permitted or required by law.

What type of information does the Plan collect

The personal information the Plan collects varies depending on your relationship with us (e.g. Member, Retired Member, Prospective Member, Beneficiary or Spouse) and includes:

  • your name, address, telephone number, and other contact information;
  • biographical information such as your sex, date of birth and spousal marital status;
  • employment information including the name of your employer(s), and employment dates, and where applicable, employment category and, employment earnings;
  • the name and date of birth of your spouse, children and/or beneficiary;
  • benefit amounts;
  • information included on a death certificate;
  • divorce or separation agreement information;
  • orders or judgments from a court, tribunal or similar body relating to pension entitlement; declarations in connection with marriage breakdown;
  • power of attorney;
  • social insurance number and banking information; and
  • other information with your consent that is required to fulfill a legitimate identified purpose or as permitted or required by law.

Please ensure that before providing the Plan with personal information about third parties such as your spouse or beneficiaries, you have that person's consent to provide their personal information to us.

We limit the disclosure of your personal information

The Plan does not sell or trade any personal information it collects. Personal information will be shared with third parties as described in this Privacy Statement, or otherwise with your consent or where permitted or required by law. The Plan will share personal information with government and regulatory authorities in order to comply with our legal obligations. In addition, the Plan provides limited information to participating employers or certain organizations representing groups of employers regarding their members for purposes such as determining and managing eligibility of insurance benefits that are conditional on Plan participation.

The Plan may transfer personal information to certain service providers outside of the Plan who assist us in carrying out our obligations such as CIBC Mellon to pay pension benefits, to the actuary for the creation of the actuarial valuation, to our information technology service provider to maintain the pension administration system, to a third party service provider for the mailing of the required statements and to legal counsel. The Plan also utilizes third party pension administrators to administer the pensions of members from a number of participating employers. These service providers are subject to contractual or other measures to protect your personal information while processed or handled by these service providers. Personal information may be sent to another jurisdiction, as required, for pension administration related purposes, as described within this Privacy Statement.

Your consent is needed for the collection of personal information

Your consent to the Plan's collection, use and disclosure of personal information may be given in various ways. Consent can be expressed (e.g. orally or in writing) or implied (for example, when you provide information necessary for an explanation of your benefits). Consent may be given by your authorized representative (such as a legal guardian or a person having a power of attorney). Beneficiaries and spouses will need to consent to the use of their information to pay a survivor benefit. Generally, by providing us with personal information, we will assume that you consent to our collection, use and disclosure of such information for the purpose identified or described in this Privacy Statement, if applicable, or otherwise at the time of collection. If you provide the Plan with personal information about a third party such as a spouse or beneficiary, we will assume that you have the consent of that third party to provide their Personal Information to the Plan.

When you enrol in the Plan, your consent will be valid for so long as necessary to fulfil the purposes described in this Privacy Statement or otherwise at the time of collection, and you may not be permitted to withdraw consent to certain necessary uses and disclosures (for example, but not limited to, maintaining reasonable administration and transaction records, disclosures to Canadian and foreign government entities as required to comply with laws).

The Plan collects, uses and discloses your personal information with your consent, except as permitted or required by law. We may be required or permitted under statute or regulation to collect, use or disclose personal information without your consent, for example to comply with a court order, to comply with local or federal regulations or a legally permitted inquiry by a government agency, or to collect funds owed to the Plan.

We limit the length of time we retain your personal information

The Plan has developed guidelines and implemented procedures with respect to the retention of personal information. The length of time we retain your personal information may vary depending on the circumstances and the nature of the information.

We will keep your personal information in our records so long as it is needed for its identified purposes, or as required to satisfy business or legal requirements.

We are committed to accuracy

We make every effort to ensure the information we collect remains accurate and up to date as is necessary for the purposes for which it is to be used. Throughout the year, we may mail correspondence directly to Plan members. If we receive returned mail, we attempt to locate these individuals directly to confirm their current address. Plan members, of course, can review their personal information on the Annual Pension Statement they receive each year. This is an excellent opportunity to confirm the accuracy of their data and contact their employer or the CAAT Pension Plan directly to request that it be updated or corrected, if necessary.

We will use our best efforts to protect your personal information

While we can’t guarantee that a breach will never occur, we will use our best efforts to protect your personal information by means of various physical, technological and organizational security measures designed to protect your personal information from unwarranted intrusions, theft, accidental release, loss, or unauthorized disclosure, use, copying, or modification. In addition, when we destroy your personal information, we use appropriate safeguards.

Location of personal information

Personal information is kept at the Plan's and its agents’ offices and/or secure offsite storage.

Your right to access and make corrections

If you wish to request access to your personal information in our custody or control, you may write to our Privacy Officer at the address set out below. With satisfactory verification of your identity, we will provide you with access to your personal information subject to applicable legal restrictions. If your request is made through a third party, we will need satisfactory proof of your consent and authorization to release information to that third party or to make the requested changes. The Plan will respond to your request as quickly as possible, and no later than 30 days after receiving it. There is no fee for such requests.

You should contact your employer or the CAAT Pension Plan to request that your personal information be updated or corrected.

Challenging compliance

If you are dissatisfied with the Plan's handling of personal information, you may make a written complaint to our Privacy Officer. The Privacy Officer will ensure that the matter is investigated, and corrective action taken where necessary. We will advise you of any steps taken to address concerns.

Privacy Statement changes

This Privacy Statement may be revised from time to time. If we intend to use or disclose personal information for purposes materially different than those described in this statement, we will make reasonable efforts to notify affected individuals, if necessary, including by revising this Privacy Statement. We urge you to request and review this Privacy Statement frequently to obtain the current version. Your continued provision of personal information following any changes to this Privacy Statement constitutes your acceptance of any such changes. This Privacy Statement is effective as of August 14, 2008, and was last revised as of December 31, 2020.

Canada’s Anti-Spam Legislation (CASL)

From time to time, the CAAT Pension Plan communicates with members via email. These email newsletters are part of the Plan’s fiduciary obligation to communicate to all members with information about the Pension Plan. These non-commercial messages are permitted under CASL, as they are in respect of a benefit plan in which you are enrolled or under which you have entitlements. The Plan does offer the option to unsubscribe from email Newsletters that are sent direct-to-member. It is important to note, however, that if you do unsubscribe, you may not receive timely and important information that can impact your membership in the Plan.

Questions or concerns

If you have any questions or concerns about this Privacy Statement or the use or security of your personal information, please contact our Privacy Officer:

By mail at:
CAAT Pension Plan
250 Yonge Street, Suite 2900
P.O. Box 40
Toronto ON M5B 2L7

By phone:
1.866.350.2228 / 416.673.9000

Through email at:
contact@caatpension.ca

December 2020