Privacy Policy: Data, AI, and Your Information

At Common Wealth Pension Services Inc. (“Common Wealth”), safeguarding the privacy of your personal information is a fundamental priority. This Privacy Policy elaborates on our commitment and governs our actions as they relate to the collection, use and disclosure of personal information, including through the use of artificial intelligence and other data automation technologies, for the purpose of administering retirement savings plans and serving our advisor partners, clients, and plan members. Common Wealth is subject to Canadian privacy legislation including the Personal Information Protection and Electronic Documents Act (PIPEDA) federally; the Act respecting the protection of personal information in the private sector (Quebec Law 25); the Personal Information Protection Act (Alberta); and the Personal Information Protection Act (British Columbia). Where provincial legislation applies to your personal information, that legislation governs.

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?

Common Wealth is responsible for personal information under its control for the purposes of administering the retirement savings plan and has established safeguards to implement the Privacy Policy, including:

- 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;
- providing financial planning services and financial education to members;
- 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.

Use of Artificial Intelligence (AI)

How we use AI

Common Wealth may use artificial intelligence (“AI”) technologies in the course of providing and improving our services. Among other things, AI may be used to:

- assist with member service inquiries and support;
- enhance the administration of retirement savings plans;
- support internal operations, including automating routine administrative tasks;
- analyze aggregated or anonymized data to improve service quality and plan outcomes; and
- develop educational content and communications related to retirement planning.

How your information is protected

When AI technologies are used to process personal information, the same safeguards described in this Privacy Policy apply. We take reasonable steps to limit the personal information made available to AI systems to what is necessary for the intended purpose. Where third-party AI service providers are used, we require them to comply with all relevant privacy legislation, appropriately safeguard your information, and use it only for authorized purposes on our behalf.

What we do not do

Common Wealth does not sell your personal information to any third party.

No decision that affects your plan entitlements, benefits, contributions, or account status is made solely by automated means. Where AI or automated processing is used to support a decision, a Common Wealth employee with authority and competence to override the system reviews and approves the decision before it takes effect.

If a decision affecting you is informed by automated processing, you have the right to:

- be informed of the personal information used in the decision;
- be informed of the principal factors and parameters that led to the decision;
- have the decision reviewed by a Common Wealth employee; and
- submit observations for consideration in that review.

To exercise these rights, contact our Privacy Officer using the details in the Inquiries or Complaints section.

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;

Transfers outside your province or Canada

Some service providers that support Common Wealth, including AI service providers and cloud infrastructure providers, may store or process your personal information outside Quebec or outside Canada, including in the United States. Personal information held outside Canada is subject to the laws of that jurisdiction, which may permit access by foreign courts, government agencies, or law enforcement.

Before transferring personal information outside Quebec, Common Wealth conducts a privacy impact assessment as required by Quebec law and puts contractual safeguards in place to ensure equivalent protection.

How long will you keep my personal information?

Common Wealth retains your personal information only as long as necessary to fulfill the purposes for which it was collected and to meet our legal, regulatory, tax, and contractual obligations. Retention periods are determined by:

- the duration of your participation in the plan, including any post-retirement payout period;
- tax record retention requirements under the Income Tax Act (Canada), which generally require retention of tax records for at least six years after the end of the relevant tax year;
- pension and financial services regulatory requirements applicable to plan administration;
- applicable limitation periods for legal claims; and
- legitimate business needs such as fraud prevention and dispute resolution.

Is consent needed for collection, use and disclosure of my personal information?

Creating an account with Common Wealth involves consenting to the collection, use and disclosure of your personal information, including as described in the Use of Artificial Intelligence section of this Privacy Policy. 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.

Common Wealth will ask for your express consent before your personal information will be used or disclosed for a purpose other than the purposes described in this Privacy Policy.

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.

Person Responsible for Personal Information

Head of Engineering serves as Common Wealth’s Privacy Officer and as the person responsible for the protection of personal information for the purposes of Quebec Law 25. Contact details are provided in the Inquiries or Complaints section.

Inquiries or Complaints

Any inquiry regarding Common Wealth’s Privacy Policy may be addressed to:

Attention: Privacy Officer
Common Wealth Pension Services Inc.
214 King Street West, Suite 314
Toronto, ON, M5H 3S6
e-mail: privacy@commonwealthretirement.cP