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Introduction
The BPA
Financial Group of Companies (“BPA”) takes the confidentiality of
your personal information entrusted to us very seriously. Any
information we receive about you or your eligible dependents is kept
private.
We know that
you are increasingly concerned about privacy, and we have therefore
established the following Privacy Code, in accordance with the
Personal Information Protection and Electronic Documents Act,
setting out the principles to which we will adhere.
We have also provided answers to questions you may have about the
procedures that we follow to protect the privacy of your personal
information.
Yours truly,
Privacy
Officer
About Us
BPA is a
Third Party Administrator specializing in the administration of
Trusteed multi-employer benefit plans. The Board of Trustees has
appointed BPA as the Administrative Agent (the “Administrative
Agent”) of your Benefit and/or Pension Plan (the “Plan”). Any
personal information we collect as the Administrative Agent is kept
private.
Privacy
Code
We adhere to
the following principles:
Accountability. We
are responsible for personal information under our control, and have
designated a Privacy Officer who is accountable for the day-to-day
compliance of these principles.
Purposes.
We collect your
personal information only for the purposes of administering your
benefits under the Plan, including the determination of eligibility,
the payment of benefits, and for routine activities such as audit,
record-keeping, and reporting. In addition, your employment history
may be shared with your Local Union(s) for the purpose of monitoring
the contributions required to be made under the terms of the
Collective Agreement.
Consent.
We obtain your
knowledgeable consent for the collection, use, or disclosure of your
personal information, except where inappropriate.
Limiting
Collection.
We limit our collection of
your personal information to that which is necessary for the
purposes we have identified, and we collect your personal
information by fair and lawful means.
Limiting
Use, Disclosure, and Retention.
We do not use or
disclose your personal information for purposes other than those for
which we have collected it, except with your consent or as required
by law. We retain your personal information only as long as
necessary for the fulfillment of those purposes.
Accuracy.
We ensure that your
personal information is as accurate, complete, and up-to-date as is
necessary for the purposes for which we use it.
Safeguards.
We protect your personal
information by security safeguards appropriate to the sensitivity of
the information.
Openness. We make
specific information about our policies and practices relating to
the management of personal information readily available to you.
Individual Access.
Upon request, we will
inform you of the existence, use, and disclosure of your personal
information and give you access to that information. You have the
right to challenge the accuracy and completeness of your personal
information and have it amended as appropriate.
Challenging Compliance.
You have the right to
address a challenge concerning our compliance with the above
principles to our Privacy Officer.
What is
Personal Information?
We consider
any identifiable information about you and your eligible dependents
to be “personal information”.
You and your
eligible dependents provide the Plan with the following personal
information:
-
Name,
-
Social
Insurance Number,
-
Home
Address,
-
Home
Telephone Number,
-
Date of
Birth,
-
Gender,
-
Marital
Status,
-
Spouse’s
Name,
-
Spouse’s
Social Insurance Number,
-
Spouse’s
Date of Birth,
-
Name of
Dependents,
-
Date of
Birth of Dependents,
-
Health
Information as it relates to your benefit entitlement,
BPA collects
information about your earnings and work history from your
Employer(s). Local Union(s) may also provide BPA with updates of
the personal information listed above. BPA may also collect other
information in order to determine your eligibility for benefits.
Who
Collects this Personal Information?
·
BPA
collects personal information on behalf of the Board of Trustees.
·
BPA will explain the
need for information, will limit the collection of information to
what is needed, will use information for those purposes only, and
will comply with this Code.
·
Your and your eligible dependents’ consent may be express or
implied.
·
You
and your eligible dependents grant consent for the collection, use
and disclosure of personal information when enrollment forms, claim
forms, retirement/termination packages and various benefit
entitlement forms are completed.
·
You
and your eligible dependents can withdraw consent at any time by
writing to the Plan’s Privacy Officer, provided there are no legal
requirements to prevent this.
·
BPA
may also collect information from Employer(s) and Local Union(s).
This will be limited to information that is required for a
particular purpose.
How is
Personal Information Protected?
·
BPA
keeps your personal information in the strictest confidence, and
uses it only for the purposes for which it is collected.
·
BPA maintains both
paper and electronic files containing personal information.
·
All
paper files maintained by BPA are kept in locked filing cabinets
and/or storage rooms.
·
Access to BPA’s offices is restricted to authorized personnel, and
only during regular business hours.
·
BPA
utilizes mainframe and network computers which are “password
protected” to maintain all electronic files.
·
Internet access to BPA’s electronic files containing personal
information is “firewall protected”.
Who has
Access to Personal Information?
·
BPA
has access to personal information provided by the Employer(s) and
the Local Union(s) in the database and paper files BPA maintains on
behalf of the Board of Trustees.
·
The
Trustees have access to such personal information as required to
permit them to carry out their fiduciary duties.
·
Access to personal information maintained by BPA on behalf of the
Plan, is on a “need to know” basis.
·
BPA’s staff only has access to the particular personal information
needed to determine the benefit entitlements payable under the terms
of the Plan.
·
BPA’s staff certifies annually that they will maintain the
confidentiality of the information entrusted to them.
Who is
Personal Information Disclosed to?
·
If
we use the expertise of an outside company to do work involving your
personal information we will select only those companies whose
privacy policies are comparable to our Code.
·
In
order to maintain and authorize the payment of benefits, BPA may
disclose personal information to benefit providers such as EAPs,
Drug Card Providers, Investment Managers, Local Union(s), Insurance
Carriers and Trust Companies.
·
Personal information may also be disclosed to the Plan’s Actuaries
and Accountants in the course of routine administration such as
audit, record-keeping, and reporting. BPA and the Board of Trustees
may disclose personal information to legal counsel as necessary to
protect the interests of BPA, the Board of Trustees, and the
beneficiaries.
·
Personal information is disclosed either in person, by mail, email,
telephone, fax or other electronic means.
·
All
such disclosure is on a “need to know” basis, and all such outsiders
are required to agree that they will comply with our Code.
·
BPA
may disclose personal information if it becomes aware of information
that it has reasonable grounds to believe can be useful in the
investigation of a contravention of the law, such as fraud.
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