Privacy Policy

To participate in the Advantages Retirement Plan™, you are required to provide personal information to Common Wealth Pension Services Inc (Common Wealth). Common Wealth will use that information to manage and administer the Advantages Retirement Plan™ and provide you with retirement planning information and tools.

The personal information that Common Wealth will collect includes your name, your social insurance number, contact information, bank account information, your sex and your age. To manage and administer the Advantages Retirement Plan™, Common Wealth may disclose your personal information to OMA Insurance Inc. and third parties including Canadian Western Trust, Brookfield Annuity Company, Canada Revenue Agency, legal counsel and other professional advisors and regulators.

Common Wealth may also collect, use, retain, and disclose your personal information (including collection from and disclosure to third parties), as needed, for other purposes permitted by law, including to comply with legal and regulatory requirements, investigate potential breaches of contract or the law, and to detect or prevent fraud.

Personal information that Common Wealth collects is safeguarded in a number of ways, including the following:

  • organizational safeguards have been implemented to protect your privacy, including restricting access to your personal information to those of its employees, agents and authorized service providers who require it in order to perform their work;
  • physical and technological controls are in place to protect the security of personal information collected, including restricted access to the Insurer’s premises, user authentication, encryption, firewall technology and the use of intrusion detection software; and
  • third parties are subject to confidentiality and privacy protection obligations in their contracts with Common Wealth

Please note that Common Wealth’s IT infrastructure for secure management and storage of some data may involve the back-up of data on servers that are located in the United States. Data hosted in the United States is subject to United States law.

Your consent to the collection, use and disclosure of your personal information as described above and in the Common Wealth™ Privacy Policy is required in order to participate in the Advantages Retirement Plan™.

At Common Wealth Pension Services Inc. (Common Wealth), safeguarding the privacy of your personal data 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 for the purpose of administering the retirement savings plan. Common Wealth is subject to applicable federal and provincial privacy legislation (e.g., Personal Information Protection and Electronic Documents Act (PIPEDA)).

Accountability
Common Wealth is responsible for personal information under its control for the purposes of administering the retirement savings plan and has established procedures 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;
  • appointing a Privacy Officer to oversee privacy and information procedures;
  • requiring third parties who provide services to support the retirement savings plan to comply with all relevant privacy legislation, appropriately safeguard your data, and limit their activities for the purposes for which your data was provided; and,
  • training staff about the importance of protecting the personal information under their control.

Purpose
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. This refers primarily to administering your retirement benefits, collecting and investing of contributions, paying your entitlement after retirement and allowing us to serve you better. Reasons we collect and use your personal data include the following purposes:

  • generally administering the retirement savings plan;
  • making entitlement payments and other benefits to members, spouses and beneficiaries;
  • accurately recording and validating contributions received;
  • maintaining appropriate records;
  • allow you to select or purchase certain products or services
  • communicating information about the retirement savings plan;
  • establishing and maintaining member relationships;
  • researching, developing, managing, improving and protecting our services, including conducting surveys that provide us with feedback on our service standards;
  • tracking website usage, transaction history and patterns, for the purposes of market research and/or tailored messages;
  • meeting legal or regulatory requirements, including tax requirements and tax reporting requirements; and,
  • implementing procedures to investigate specific transactions or patterns of transactions to detect unauthorized or illegal activities.

Limitations
Common Wealth uses or discloses your personal information only for the purposes described above; and given the long-term nature of retirement accumulation and payout, retains this information for an extended period of time.

Information Collected
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 information is collected for tax reporting purposes such as social insurance number (S.I.N.) and residency status.

Consent
Before you can enroll in the retirement savings plan, Common Wealth will obtain your express consent for the collection, use and disclosure of your person information. Your consent can be withdrawn for the collection, use and disclosure of your personal data, subject to legal and contractual restrictions and reasonable notice. Without your consent you will no longer be able to receive plan services and products and you will 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 the Privacy Policy.

Safeguarding Your Information
Common Wealth will protect your personal information with appropriate technical and
organizational safeguards and security measures and will make every reasonable effort to
protect your personal information against loss or theft as well as unauthorized access,
disclosure, copying, use or modification. Common Wealth adopts industry standard
technology and efforts to safeguard your personal data including secure servers and firewalls.

Appropriate controls are in place over computer systems and data processing procedures and these controls are reviewed on an ongoing basis to ensure compliance with our security and privacy requirements. Common Wealth secures its premises and electronic systems and all employees are responsible for maintaining the confidentiality of any personal information they handle in the course of performing their duties.

Disclosure of Personal Information
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:

  • 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
  • Plan sponsor: When necessary for administering the plan for you (e.g., call centre support)
  • Survey services: May be disclosed to deliver or administer surveys relating to plan administration activities
  • Members’ legal representative: May be disclosed to a legal guardian, appointed substitute decision maker, power of attorney, or someone authorized by law, if necessary to administer the plan.

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.

Accuracy
Common Wealth will make every reasonable effort to keep your personal information up-to-date and accurate. However, we rely on you to provide accurate information and to update your personal data when there is a change.

Individual Access to Information
You may request access to your personal information at any time. 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

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

Attention: Privacy Officer
Common Wealth Pension Services Inc.
77 King Street West, Suite 2110
Toronto, ON, M5K 2A1
e-mail: info@commonwealthretirement.com