Privacy Code for the Ontario Teachers’ Pension Plan
	Members I Employees and Prospective Employees
	At the Ontario Teachers’ Pension Plan, we are dedicated to protecting your privacy and safeguarding your personal information. As part of our commitment, we have established this Privacy Code to govern our actions as they relate to the collection, use and disclosure of your information. In developing our Privacy Code, we conducted a thorough review of our practices and re-examined why we collect, use and retain certain personal information. We invite you to review the principles of our Privacy Code. Any concerns that you have regarding your personal information with us may be addressed to our Corporate Privacy Officer, who is responsible for monitoring and promoting the plan’s compliance with our Privacy Code. Protecting the confidentiality of your personal information has always been fundamental to the Ontario Teachers’ Pension Plan. With the Privacy Code, we renew our commitment to protect your privacy and safeguard your personal information at the plan. Privacy Code for Members The Principles Principle 1 - Accountability Principle 2 - Identifying Purposes Principle 3 - Consent Principle 4 - Limiting Collection Principle 5 - Limiting Use, Disclosure and Retention Principle 6 - Accuracy Principle 7 - Safeguarding Your Information Principle 8 - Openness Principle 9 - Individual Access to Information Principle 10 - Inquiries or Complaints Principle 1 - Accountability The Ontario Teachers’ Pension Plan is responsible for personal information under its control. 1.1 The Corporate Privacy Officer of the Ontario Teachers’ Pension Plan is accountable for monitoring and promoting compliance with our Privacy Code. 1.2 We have established policies and procedures to implement the Privacy Code, including: • policies and procedures to protect personal information we collect, use and disclose for plan administration • requirements for other organizations that assist in plan administration • procedures to respond to inquiries and complaints • communications and training programs to inform our staff about privacy policies and practices • information for plan members to explain our Privacy Code. Principle 2 - Identifying Purposes We collect personal information from you, your employer and others that we need to administer the plan, including to: • accurately record and validate service as reported by employers • invoice employers for required contributions • determine benefit entitlements and process benefit applications • communicate information about the plan • understand and analyze your pension needs and develop services to inform you about how to preserve or improve your benefits • assess the quality of the service we provide • comply with applicable laws.

Principle 3 - Consent

We will obtain your express consent before collecting, using or disclosing your personal information for a purpose other than the administration of the plan, unless otherwise authorized by law.
3.1	Participation in the Ontario Teachers’ Pension Plan is mandatory for all qualified teachers employed in education in Ontario. The information that you, your employer and others provide in relation to the plan is collected, used or disclosed under the authority of legislation such as the Teachers’ Pension Act, the Pension Benefits Act and the Income Tax Act (Canada). Your consent to the collection, use and disclosure of personal information for the administration of the plan is implied and cannot be withdrawn.
3.2	We will ask for your express consent to the collection, use or disclosure of personal information for special promotions of products and services available from others. Consent to these promotions can be withdrawn at any time.

Principle 4 - Limiting Collection
We will collect only the personal information we need for the purposes described, and will do so only by fair and legal means.

Examples of the personal information we usually collect and maintain for use in administering the plan are available upon request.

Principle 5 - Limiting Use, Disclosure and Retention
We will use or disclose your personal information only for the purposes described, and retain it only for as long as is necessary for administration of the plan.

We will use or disclose your personal information only for the purposes described, and retain it only for as long as is necessary for administration of the plan.

Principle 6 - Accuracy
We will make every reasonable effort to keep your submitted personal information up-to-date and accurate.

Principle 7 - Safeguarding Your Information
We will protect your personal information with appropriate safeguards and security measures according to its sensitivity.

We will make every reasonable effort to protect your personal information against loss or theft as well as unauthorized access, disclosure, copying, use or modification.

Principle 8 - Openness
Information about our privacy policies and practices concerning your personal information is available upon request.

Principle 9 - Individual Access to Information

Upon written request, we will advise you of the collection, use and disclosure of your personal information and provide you with access to that information. You may challenge the accuracy and completeness of the information and have it amended as appropriate. We will record your concern if it is not resolved to your satisfaction.
9.1	We will respond to your access request within 30 days. There will be no charge for reasonable requests for such access.
9.2	Upon written request, we will disclose to you our record of your personal information along with an account of the source of the information, its use by us and its disclosure to third parties.
9.3	We may be unable to provide access to some or all of your information in certain circumstances including those where the information: • is unreasonably costly to provide • contains references to other individuals • cannot be disclosed for legal or security reasons • is subject to solicitor-client and litigation privilege.

Principle 10 - Inquiries or Complaints
Any inquiry regarding our Privacy Code may be addressed to:

Ontario Teachers’ Pension Plan
5650 Yonge Street,
Toronto, ON M2M 4H5
Attention: Client Services Department

Phone:  (416) 226-2700 or 1-800-668-0105 (toll free)
Fax:      (416) 730-7807 or 1-800-949-8208 (toll free)
E-mail:   inquiry@otpp.com

Any complaint regarding compliance with our Privacy Code may be addressed to our Corporate Privacy Officer (Attention Plan Policy Department):

Phone:    (416) 730-3592 or 1-877-812-7989 ext. 3592 (toll free)
Fax:        (416) 730-3771 or 1-800-949-8208 (toll free)

We will respond to all inquiries or complaints related to the handling of personal information. If a complaint is found to be justified, we will take appropriate measures. Complaint procedures are available from the Corporate Privacy Officer.

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Privacy Code for Employees and Prospective Employees

The Principles
Principle 1 - Accountability
Principle 2 - Identifying Purposes
Principle 3 - Consent
Principle 4 - Limiting Collection
Principle 5 - Limiting Use, Disclosure and Retention
Principle 6 - Accuracy
Principle 7 - Safeguarding Your Information
Principle 8 - Openness
Principle 9 - Individual Access to Information
Principle 10 - Inquiries or Complaints

Principle 1 - Accountability

The Ontario Teachers’ Pension Plan is responsible for personal information under its control.
•	The Corporate Privacy Officer of Teachers' is accountable for monitoring and promoting compliance with our Privacy Policy.
•	We have established policies and procedures to implement the Privacy Policy, including: • policies and procedures protecting the personal information we collect, use and disclose for Human Resources administration and Expense management ("employee administration"), and requirements for other organizations that may assist with such activities • procedures responding to inquiries and complaints.

Principle 2 - Identifying Purposes

We collect personal information about employment candidates and employees for purposes of employee administration. We require information for:
•	assess the applications of job candidates
•	negotiate and make offers of employment
•	provide for the supervision, management and remuneration of employees including budgets
•	record employees' skills and training/development requirements
•	develop succession plans
•	record significant events during the employment relationship such as job or salary changes
•	reimburse employees for expenses
•	maintain Teachers' facilities as a safe workplace, and monitor use of equipment including e-mail and Internet access
•	record illness and injury of employees that affects their work including workers compensation claims
•	administer and make payments to pension and benefit plans
•	conduct investigations including employee complaints
•	provide post-employment references
•	comply with applicable laws.

Principle 3 - Consent

When you respond to an advertisement or notice of a job opportunity, you consent to the collection, use and disclosure of the personal information that you or your references have provided.

As an employee, your consent to the collection, use and disclosure of personal information for purposes of employee administration is implied and cannot be withdrawn.

We may collect, use and disclose your personal information without your prior knowledge or consent, for purposes other than employee administration, if legal, medical or security reasons make it impossible or not feasible to obtain consent.

Principle 4 - Limiting Collection
We will collect only the personal information we need for the purposes described, and will do so only by fair and legal means. Personal information that we routinely collect includes:

•	name, home address, e-mail address and telephone number
•	age, sex, education, training, work experience, employment history, references, Social Insurance Number
•	emergency contact, next of kin, dependants
•	severe allergies or medical conditions that require awareness
•	photograph
•	employment record, attendance information, salary and benefits and performance evaluations, all while at Teachers'
•	information required for the administration of payroll, benefit plans including group insurance plans, and pension plans
•	information required for purposes of securing Teachers' facilities
•	information required for compliance with Teachers' Code of Business Conduct and related policies including personal trading
•	information required by law such as court orders or garnishments
•	information required for expense reimbursement.

Personal information of job applicants and employees may be collected from various sources in the course of employee administration including:

•	resumes
•	interviews
•	reference, security and other background checks
•	performance appraisals
•	medical certificates from attending physicians
•	applications for employment benefits
•	requests for maternity, parental, and other leaves-of-absence, as well as vacation requests
•	investigations, including complaints.

Principle 5 - Limiting Use, Disclosure and Retention

To the extent required for a purpose we have identified, or as required by law, we may use your personal information or disclose it to third parties including:
•	external payroll administrators
•	reference check agencies
•	potential employers conducting reference checks
•	benefits administrators
•	trustees in bankruptcy
•	law enforcement agencies
•	outplacement agencies.

We use written contractual arrangements with third parties as necessary to ensure a comparable level of protection where they process personal information for Teachers'.

We will retain certain personal information to satisfy the purposes for which it was collected and to carry out our legal obligations. The Human Resources Department will maintain the Employee and Applicant Data Retention Guidelines ensuring information that is no longer required will be disposed of in a secure manner. The Corporate Finance Department will maintain necessary employee banking information.

Principle 6 - Accuracy
We will make every reasonable effort to keep submitted personal information up-to-date and accurate.

If there is inaccurate or incomplete personal information in your file, please advise us of the correction(s) or additions(s) and we will amend the record as appropriate. If we conclude that an amendment is not warranted, you will be permitted to attach a notation to the record in your file.

Principle 7 - Safeguarding Your Information
We will protect your personal information by using appropriate security safeguards.

The Human Resources and Corporate Finance departments at Teachers' maintain security systems and other safeguards respecting personal information that is collected, used, retained and disclosed, including physical measures such as locking cabinets, electronic security, encryption and organizational systems. Your personal information will be treated as confidential and only used by Teachers' or disclosed to third parties for the purposes for which it was collected or as required by law.

Principle 8 - Openness
Information about our privacy policies and practices concerning your personal information is available upon request.

Principle 9 - Individual Access to Information
The Human Resources Department at Teachers' maintains a file for each employee generally containing information about offer of employment, promotions, transfers, performance reviews and other documentation related to employment. The information contained in these files is collected, used and disclosed for the purposes of employee administration. These files are treated as confidential and are secured in locked cabinets within an area of limited access in the Human Resources Department.

The Corporate Finance Department collects, uses and discloses personal information for the purpose of budgeting and expense reimbursements to employees. This information is also treated as confidential and is secured in that department.

You can request access to your personal file at any time. Access is permitted within 48 hours (where possible) of your request to the Human Resources Department. A member of the department will be present when you view your file. It may be necessary to limit your access to parts of your file where information cannot be disclosed for legal or security reasons, or is subject to solicitor-client privilege or litigation privilege.

Principle 10 - Inquiries or Complaints
You have the right to make a complaint about the improper collection, use or disclosure of your personal information by Teachers'. Any complaint should be directed to the Corporate Privacy Officer. Your complaint will be investigated and, if justified, appropriate measures will be taken. We will respond to your complaint within 30 days.

For more information, or to discuss a complaint, please contact:

Scott Perkin
Corporate Privacy Officer
Ontario Teachers’ Pension Plan
5650 Yonge Street,
Toronto, ON M2M 4H5
Phone:  (416) 730-3592 or 1-877-812-7989 ext. 3592 (toll free)
E-mail:   scott_perkin@otpp.com
Fax:        (416) 730-3771 or 1-800-949-8208 (toll free)

We will respond to all inquiries or complaints related to the handling of personal information. If a complaint is found to be justified, we will take appropriate measures. Complaint procedures are available from the Corporate Privacy Officer.