At Common Wealth Pension Services Inc. (Common Wealth), safeguarding the privacy of your personal information is a fundamental priority. This Privacy Statement elaborates on our commitment and governs our actions as they relate to the collection, use and disclosure of personal information for the purpose of administering the retirement savings plan. Common Wealth is subject to applicable federal and provincial privacy legislation.
What is personal information?
The personal information collected for plan administration is any information relating to an identified or identifiable person and includes name, contact information, banking information, retirement planning information, date of birth, marital status, sex, occupation, and beneficiary information. Other personal information is collected for tax reporting purposes such as social insurance number (S.I.N.) and residency status.
How is my privacy protected?
- adopting policies and procedures to protect personal information it collects, uses and discloses;
- providing information to retirement savings plan members about its collection, use or disclosure of personal information;
- establishing procedures to respond to inquiries regarding the collection, use or disclosure of personal information;
- establishing processes to identify potential privacy breaches and providing appropriate notification of any breaches to affected individuals;
- appointing a Privacy Officer to promote compliance with privacy laws in jurisdictions where we operate, and with internal policies and procedures;
- securing its premises and electronic systems;
- limiting access to personal information to employees on a “need to know” basis as required for their business functions;
- training staff about the importance of protecting the personal information under their control;
- requiring third parties who provide services to support the retirement savings plan to comply with all relevant privacy legislation, appropriately safeguarding your information, and limiting their activities for the purposes for which your information was provided.
Why is personal information collected and what is it used for?
As a member or beneficiary of the plan, Common Wealth collects your personal information and takes every reasonable precaution to ensure your information is collected, used and disclosed only for the purpose of administering the retirement savings plan. Personal information is collected primarily to administer your retirement benefits, invest your contributions, pay your entitlement after retirement and to allow us to serve you better. Reasons we collect and use your personal information include the following purposes:
- generally administering the retirement savings plan;
- making entitlement payments and other benefits to members, spouses and beneficiaries;
- accurately receiving, recording and validating contributions received either from your bank account or your employer as applicable;
- maintaining appropriate records;
- allowing you to select or purchase certain products or services;
- communicating information about the retirement savings plan;
- establishing and maintaining member relationships;
- researching, developing, managing and improving our services, including conducting surveys that provide us with feedback on our service standards and operations;
- analyzing the member experience using data analytic tools to resolve issues;
- tracking website usage, transaction history and membership patterns in an aggregate form for the purposes of market research and/or tailored messages;
- meeting legal or regulatory requirements, including tax requirements and tax reporting; and,
- implementing procedures to investigate specific transactions or patterns of transactions to detect unauthorized or illegal activities.
Will my personal information be shared?
Permitted transfer of personal information by Common Wealth may include making certain information available to third parties for purposes of their work in supporting the administration of the retirement savings plan. Examples of some third parties that we share your personal information with are, but are not limited to:
- Custodian – used for the purpose of collecting contributions and holding and safeguarding your assets;
- CRA – required by tax laws to report certain personal information to the CRA, such as your SIN and tax reporting information;
- Annuity provider – used for the purpose of purchasing annuity products;
- Financial institutions to facilitate transfer of assets and to determine eligibility for transfer;
- Plan sponsor – when necessary for administering the plan for you (e.g., payroll contribution instructions, membership status);
- Broker advisors associated with your plan – used to support retirement and/or financial planning discussions with you;
- Compliance service provider – used to perform anti-money laundering and anti-terrorist financing screening activities in accordance with legal or regulatory obligations;
- Survey services – information may be disclosed to deliver or administer surveys relating to plan administration activities; and,
- Members’ legal representative – information may be disclosed to a legal guardian, appointed substitute decision maker, power of attorney, or someone authorized by you or by law, if necessary to administer the plan.
Some third parties that provide services to the plan may be located or may store personal information necessary to provide such services, outside Canada. Whenever personal information is transferred to a third-party service provider, we require them to comply with all relevant privacy legislation, appropriately safeguard your information and to limit its use only to purposes required for the service.
How long will you keep my personal information?
Is consent needed for collection, use and disclosure of my personal information?
Enrolling in a Common Wealth involves consenting to the collection, use and disclosure of your personal information. Your consent can be withdrawn for the collection, use and disclosure of your personal information, subject to legal and contractual restrictions and reasonable notice. Without your consent you may no longer be able to receive certain plan services and products and you may trigger a withdrawal from the plan. Notify our Privacy Officer in writing if you want to withdraw your consent.
How can I access or correct my personal information?
Common Wealth will make every reasonable effort to keep your personal information accurate, complete and up-to-date. However, we rely on you to provide accurate information and to update your personal information when there is a change. You can make corrections to personal information in your plan’s online account.
Upon request you shall be made aware of the collection, use and disclosure of your personal information. You may also request access to your personal information at any time and may challenge its accuracy. However, in certain situations, we may not be able to provide access to all the personal information we hold about you. For example, the information may contain details about other individuals, or there may be legal reasons why the information is limited or withheld. If that is the case, we will advise you of those reasons when responding to your request.
Inquiries or Complaints
Attention: Privacy Officer
Common Wealth Pension Services Inc.
77 King Street West, Suite 2130
Toronto, ON, M5K 1E7