The CAAT Pension Plan and its staff are committed to protecting your privacy and the confidentiality of your personal information
We are pleased to provide you with the following Privacy Statement which 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
This Privacy Statement explains how we collect, use and disclose your personal information. 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.
The Plan has appointed a Privacy Officer to ensure compliance with this Privacy Statement and our personal information handling practices. This person will oversee 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 use 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 personalized annual member pension statements and retirement or termination options documents;
- to verify eligibility of claims for benefit entitlement;
- to fulfil reporting requirements and compliance with the Ontario Pension Benefits Act, the Income Tax Act and the Family Law Act;
- 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, Beneficiary or Spouse) and includes:
- your name, address, telephone number, and other contact information;
- information such as your gender, date of birth and marital status;
- employment information including the name of your employer, employment category, employment earnings and employment dates;
- the name and date of birth of your spouse, children and/or beneficiary;
- benefit amounts;
- death certificate;
- divorce or separation agreement;
- power of attorney;
- social insurance number and banking information; and
- other information with your consent 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 for the purpose of 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 annual statements and to our legal counsels. These service providers are subject to contractual or other measures to protect your personal information while processed or handled by these service providers.
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 express (e.g. orally or in writing, including by signing an enrolment form outlining the intended uses and disclosures of personal information) or implied (e.g. 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 will also have to sign a form to authorize us to use 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 mail plan-related correspondence directly to retired members. If we receive returned mail, we attempt to locate these individuals directly to confirm their current address. 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 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 office or in 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 the Privacy Officer at the address set out below. You should contact your employer to request that your personal information be updated or corrected. 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.
If you are dissatisfied with the Plan's handling of personal information, you may make a written complaint to the 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.
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.
However, 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 the Privacy Officer:
By mail at:
CAAT Pension Plan
250 Yonge Street, Suite 2900
P.O. Box 40
Toronto ON M5B 2L7
1.866.350.2228 / 416.673.9000