Medicus Pension Plan Privacy Statement

The personal information that we collect varies depending on your relationship with us (i.e., prospective member, member, spouse or beneficiary), but may include:

• name and contact information, including your mailing address, email address, and phone number;
• government-issued identification information, such as your social insurance number;
• biographic information, such as your date of birth, sex and marital status;
• employment and income information, including the name of employer, employment dates, and pensionable earnings;
• financial information, such as banking information;
• beneficiary information, including name and date of birth of a member’s spouse, children and/or beneficiary;
• marriage breakdown information, such as separation or divorce agreements, or orders or judgement from a court, tribunal or similar body relating to pension entitlements in marriage breakdown;
• other plan administration information, such as power of attorney and information related to death.

We may collect other information with your consent or as otherwise permitted or required by law.

We collect, use and disclose your personal information with your consent, except where otherwise permitted or required by law. For example, we may be required or permitted under statute or regulation to collect, use or disclose personal information without your consent to comply with law or regulations, an inquiry by a government agency, or a court order, or to collect funds owed to the Plan.

Your consent to our collection, use and sharing of your personal information may be given in various ways.

When you become a member of the Plan you are asked to sign the Privacy Notice and Consent. By signing this form, you are expressly consenting to our collection, use and disclosure of your personal information as outlined in the Privacy Notice and Consent. 

In providing us with personal information in other circumstances, such as sending or responding to communications or otherwise interacting with us and submitting information to us in connection with your membership in the Plan, we will assume that you consent to our collection, use and sharing of such information for the purposes described in this Privacy Statement, if applicable, or otherwise at the time of collection. If you provide us with personal information relating to someone else, such as your beneficiary, you represent and warrant that you have all necessary consents to do so. 

You can withdraw your consent to our collection, use or disclosure of your personal information at any time, subject to contractual and legal restrictions. If you withdraw your consent to certain necessary collections, uses or disclosures of your personal information, you may no longer be able to participate in the Plan. You can withdraw your consent to our collection and use of personal information for tailored marketing without impacting our ability to provide products or services to you. To withdraw your consent, please contact our Privacy Officer using the contact information provided below.

As a member of the Plan, or a prospective member of the Plan, we generally collect personal information from you directly, but may also collect personal information from others such as the Sponsor, or its affiliates or subsidiaries, or your employer.   

The collection of your personal information directly from you may be done over the telephone, by email, by mail, through our online enrolment tool, or in any other direct manner, for example, when you activate your access to the member portal, use other online tools made available to you, send or respond to emails, make an inquiry concerning your pension entitlement, or update your personal information on the member portal, and through other documents and communication channels.

Your employer may also provide us with information about your annual pensionable earnings, contributions and other applicable events like a leave of absence, termination of employment or retirement. By becoming a member, you give permission for your employer to share your personal information with us to allow us to administer your pension entitlement. 

When you interact with our online enrolment tool, member portal or other online tools made available to you, certain types of information may be collected automatically through cookies and similar tracking technologies. For more information about these tools, please review the privacy policy posted on the site or portal that hosts these tools.

The Medicus Pension Plan website is hosted by the Sponsor. Personal information collected through that website is governed by the Sponsor’s privacy policies, which you can access here, and is not governed by this Privacy Statement. 

We use your personal information in a variety of ways, to verify your identity, determine your initial and ongoing eligibility for the Plan, manage and administer the Plan, communicate with you in respect of the Plan and related benefits, and meet the Plan’s legal, income tax and regulatory obligations. The Administrative Board may also use your personal information for tailored marketing, analytics and market research purposes, and to create aggregate or anonymous data; to manage and assess risks; to prevent or detect criminal activity; and to identify and correct any errors. 

Below are some examples of how we use your personal information:

• determining your eligibility for membership;
• calculating your employer’s contributions to the Plan;
• verifying your identity when communicating with you;
• verifying your membership status;
• producing and issuing pension statements, notices and retirement or termination documents;
• calculating your pension benefits and directly depositing them into your bank account when you begin collecting your pension;
• verifying eligibility claims for pension benefit entitlement;
• responding to your inquiries, providing information about your pension entitlement or otherwise communicating with you;
• providing you with administrative messages, updates, legal notices, technical notices or security alerts;
• fulfilling reporting requirements and complying with the Pension Benefits Act (Ontario), the Income Tax Act (Canada) and any other pension or other legislation applicable in your jurisdiction, to the extent they apply;
• meeting legal, regulatory, insurance, security or processing requirements;
• maintaining business and other records for reasonable periods;
• managing and assessing risks and preventing or detecting criminal activity;
• identifying and correcting errors;
• performing aggregate analyses of Plan liabilities;
• evaluating, improving and managing the Plan, our operations and our services to you;
• creating tailored marketing and performing data analytics and market research to improve our understanding of your needs;
• measuring the effectiveness of our communications with members;
• creating aggregate or anonymous data; and
• otherwise with your consent or as permitted or required by law.

As described in more detail below, your personal information may be shared: (i) with service providers who help us administer the Plan and manage our operations; (ii) with third parties (including the Sponsor and its affiliates or subsidiaries) when required to ensure proper administration of the Plan, to meet our compliance, regulatory and risk management obligations or in the event of a business transaction; (iii) between the Administrative Board and the Sponsor as necessary to carry out their duties and responsibilities with respect to the administration of the Plan; and (iv)  in other circumstances with your consent or where required or permitted by law. We do not sell or trade any personal information we collect.  

The types of service providers with whom we may share your personal information include:

• third-party administrator to assist us in the administration of the Plan;
• actuarial advisors to perform actuarial valuations of the Plan;
• custodian to hold, and maintain appropriate records relating to, Plan assets;
• legal advisors where legal advice is required;
• auditors to audit the Plan;
• payment processing service providers to assist us with processing pension payments;
• marketing, market research and analytics providers; and
• data hosting and IT service providers.

Third-party service providers are restricted from using or disclosing your information for reasons other than performing services on our behalf or to comply with legal requirements. When personal information is provided to the Plan’s service providers, the service providers are required to protect the information in a manner that is consistent with this Privacy Statement. 

Below are some examples of third parties with whom we share your personal information:

• your employer as necessary to administer the Plan;
• applicable pension regulators and the Canada Revenue Agency as necessary for tax and income reporting and other regulatory reporting and compliance purposes;
• other government, regulator and law enforcement agencies to meet our compliance, regulatory and risk management obligations or to comply with the law;
• the Sponsor as necessary for the purposes of executing Sponsor responsibilities, and to Sponsor affiliates or subsidiaries for the purposes of calculating advisor compensation or to facilitate enrolment, as applicable;
• your legal representative, including a legal guardian, appointed substitute decision-maker, power of attorney or someone else authorized by law, where such disclosure is necessary to administer the Plan;
• third parties in the event of a potential merger or acquisition, transfer of assets, reorganization or bankruptcy, in which case the parties are required to keep your information confidential and secure and are restricted in their use of information to this purpose; and
• other third parties as directed by you, such as a financial institution that you direct us to transfer your pension amount to upon retirement, or a new plan administrator in the event that you choose to leave the Plan. 

Your personal information is stored on secure servers and will be accessible by authorized employees, representatives, agents and service providers for the purposes described in this Privacy Statement. Some of our service providers and agents are located outside of Canada, including in the United States. Our service providers or agents may also be located outside of your province of residence. When your personal information is used or stored in a jurisdiction other than where you are residing, it is subject to applicable local laws, and there may be circumstances when local government or national security agencies are entitled to access the personal information collected and held by the Plan or our service providers.

We keep your personal information for as long as it is necessary for the purposes described above, or to otherwise meet our legal or regulatory obligations, including to comply with guidance and policies issued by pension regulatory authorities. When it is no longer needed, it is either securely destroyed or anonymized (so that the personal information can no longer identify you).

We are committed to protecting the privacy of your personal information. We have instituted appropriate organizational, physical, and technological security measures that are designed to protect personal information in our control from theft, loss, and unauthorized access, use and disclosure. However, no security measures can guarantee absolute security and there remains a risk that your personal information may be accessed, used or disclosed without authorization. 

We will make reasonable efforts to keep your information as accurate, complete and up-to-date as necessary for the purposes for which we intend to use it. We also rely on you to provide us with information that is true and complete.  If any of your personal information changes or otherwise becomes inaccurate or out of date, please update your information on the member portal or advise us using the contact information set out below, so that we can update our records. 

You have the right to request access to and correction of the personal information we hold about you, subject to limited exceptions under applicable laws. Much of your personal information is available to you through annual statements, through the member portal. You can also make corrections in the member portal or by contacting us using the contact information set out below. However, you can also request access to your personal information, or request rectification of inaccurate or incomplete information, by sending a request in writing to the Privacy Officer using the contact information set out below. To process your request, we may ask you for certain information to validate your identity and confirm the scope of your request. If you require accessible documents, you may request that your personal information be made available in an alternative format.  

You have options for managing your privacy with respect to your communication preferences.

Legal requirements mandate that some of our communications about the Plan must be provided to all members. For example, we may be legally required to send notices of Plan amendments, the annual statement of benefits, retirement statements, and termination statements, amongst other things, to all members. You may choose to receive this information in hard copy by mail (as opposed to receiving it electronically) by calling or writing us but you are not able to opt out of receiving the communications entirely due to our legal obligations to provide them. 

With respect to non-mandatory communications that provide you with information about the Plan -- for example, our annual report -- you can change your communication preferences in the member portal.

We may modify this Privacy Statement from time to time to reflect changes in our personal information practices. When this happens, we will post the revised Privacy Statement. We may also notify you of changes to this Privacy Statement in any of the following ways:

• a notice in your annual pension statement;
• a notice in the member portal; or
• any other reasonable method. 

You can review our current Privacy Statement at any time by requesting a copy from our Privacy Officer. This Privacy Statement is effective as of the Effective Date written above.