How we use and disclose your personal information

We collect, use and share personal information about you for the purposes of administering the Ontario Teachers’ Pension Plan (the “plan”) and your pension benefit, communicating with and serving you, or otherwise in accordance with your consent.

We use personal information for individual member purposes, and for broader plan purposes. Below are some examples of how we use personal information about you:

• SIN – required for the purpose of reporting income to the Canada Revenue Agency (CRA).
• Salary – used to calculate your pension contributions, to determine your average annual salary for pension calculations and to collect contributions if you choose to buy back service in the plan.
• Banking information – required so that monthly pension benefits can be directly deposited into your bank account.
• Plan membership status – may be used to send you surveys relating to plan administration activities and collecting survey responses.
• Legal disclosure – may disclose personal information to your authorized representative, legal guardian, appointed substitute decision maker, power of attorney or someone otherwise authorized by law, if necessary to administer the plan.
• Website usage – may use personal information collected while you’re logged into your Ontario Teachers’ online account to measure and analyze website usage to enhance your online experience.
• Data analytics – may use personal information to perform data analytics to improve our understanding of your needs, to improve the quality of services we offer you, and to facilitate the development of communications strategies.
• Overall plan management – may use personal information for aggregate analyses of plan liabilities and performance, and to evaluate, improve and manage the plan, our operations, and our service to you.

Your personal information may also be shared with your employer or other third parties when it’s necessary for administering the plan or for you to receive technical or other services. Below are some examples of third parties that we share your personal information with, and why:

• Actuarial advisors – used to perform a valuation of the plan.
• CRA – required by tax laws to report certain personal information to the CRA, such as your SIN and pension adjustment amount.
• Other pension plans – may be disclosed if you transfer into or out of the plan to another pension plan. You’ll be asked to authorize the disclosure of your personal information to both the exporting and importing plan, as required.
• Mailing services – used to send you statements and other communications about the plan and your benefits.
• Medical advisors – may be disclosed to medical advisors to assess your eligibility for disability benefits, and other plan options and features based on your medical condition.
• Survey services – may be disclosed to deliver or administer surveys relating to plan administration activities and to collect survey responses.
• Members’ legal representative – may be disclosed to a legal guardian, appointed substitute decision maker, power of attorney or someone otherwise authorized by law, if necessary to administer the plan.

Some third parties that provide services to us may be located, or may store personal information necessary to provide such services, outside Canada. Personal information stored outside Canada may be subject to the laws of the country in which the third party is located or the data is stored. That country may have laws requiring personal information be disclosed to government bodies or courts under different circumstances than would apply in Canada.

Whenever personal information is transferred to a third party service provider, we impose contractual obligations on such service provider to protect that information and to limit its use only to purposes required for the service. We perform privacy and security due diligence in respect of all third parties that are engaged to provide services to us. The purpose of this exercise is to determine whether a prospective third party service provider maintains the administrative, technical and physical safeguarding measures to protect your personal information while in the custody of such third party service provider, and otherwise assess privacy risks involved in the proposed service provider arrangement.

In some circumstances, we’re permitted by law to use and disclose personal information about you without your consent. For example, in addition to the personal information that’s required by law to administer the plan, your personal information may be used or disclosed to investigate and prevent fraud, to protect the rights, interests and property of Ontario Teachers’, its employees, and members of the plan, or if required by a court order.