Privacy Statement

The Pension Plan of The United Church of Canada and The United Church of Canada’s Group Benefit Plans

The United Church of Canada (“The Church”) collects, uses and discloses personal information in accordance with its privacy policy, which is modelled after the principles of the federal Personal Information Protection and Electronic Documents Act (PIPEDA) and can be found here.

The United Church Benefits Centre (also referred to as “we”, “us” and similar terms throughout the Privacy Statement) administers the following plans (also referred to as “the Plans”):

The Pension Plan of The United Church of Canada (the “Pension Plan”); and The United Church of Canada’s group benefit plans (the “Benefit Plans”)

The Plans operate within the church but are governed by the policies established by the Administrator, the Executive of the General Council. This Privacy Statement describes how we collect, use, disclose and protect your personal information in connection with administering the Plans. Though our Privacy Statement is informed by The Church’s privacy policy, you should refer to The Church’s separate policy for specific information about The Church’s practices for handling your personal information.

Application of this Privacy Statement

This Privacy Statement explains how the Plans collect, use, retain and disclose your personal information. Personal information refers to information about you, where there is a serious possibility that you could be identified through the use of that information, such as your name, date of birth or pension information. This Privacy Statement does not apply to information that is not personal information.

Why do we collect, use, retain and disclose your personal information?

Your personal information is necessary in order for us to be able to administer the Plans. As a result, the Plans will collect, use, retain, and sometimes disclose your personal information for the following purposes:

• to communicate with you;
• to manage and administer the Plans;
• to calculate and pay benefits under the pension plan;
• to provide benefit coverage under the benefit plans;
• to create and maintain a database of individuals entitled to benefits under the Plans;
• to produce and issue personalized annual Member Pension Statements and retirement or termination options documents;
• to verify eligibility of claims for benefit entitlement under the Plans;
• to fulfil reporting requirements and comply with other obligations under the Ontario Pension Benefits Act, the Income Tax Act and the Family Law Act in respect of the pension plan;
• to verify your identity;
• to meet legal, regulatory, insurance, security and processing requirements; and
• for other purposes with your consent or as permitted or required by law.

What personal information do we collect?

The personal information we collect varies depending on your relationship with us (e.g. Member, Pensioner, Beneficiary or Spouse) and your status in the plan as follows:

Active Members

• information from your employer including via payroll data feeds including:
• name
• address
• Social Insurance Number
• gender
• date of birth
• employment information including the name of your employer (e.g., Community of Faith), employment category (e.g., Ministry Personnel, Lay), pensionable earnings and employment dates

Pensioners

• banking information

All members

• name
• Social Insurance Number
• date of birth
• gender
• address, telephone number, email address, and other contact information
• marital status
• benefit elections
• birth, marriage, and death certificates
• divorce or separation agreements
• power of attorney and
• other information with your consent or as permitted or required by law

Please ensure that before providing the Plan with personal information about third parties, such as your spouse or beneficiaries, you have each person's consent to provide their personal information to us.

Limiting disclosure of your personal information

We do not sell or trade any personal information collected in the administration of the Plans. Personal information will be shared with The Church and third parties as described in this Privacy Statement, or otherwise with your consent or where permitted or required by law.

The Church

If you are Ministry Personnel, we operate a two-way sharing agreement with The Church, including The Church’s Regional Council Offices, for the purposes of facilitating administration of the Plans and general co-ordination of records, including your

• employee ID
• date of birth
• telephone number, email address, and other contact information
• information respecting your status (Active, Deferred, Retired, etc.) in the pension plan or other information required for The Church’s record keeping purposes.

Our current service providers

The Plan transfers personal information to certain third-party service providers who assist us in carrying out our obligations and objectives. Such service providers currently include:

• ADP Canada (the Pastoral Charge Payroll Service) to collect pension and benefit contributions from eligible members and their employers;
• Green Shield Canada to administer our health and dental plans;
• Great West Life to insure and administer our Long-Term Disability plan and other insured benefits (i.e., life insurance and accidental death & dismemberment coverages);
• Mercer as our pension plan actuary for the creation of actuarial valuations;
• TELUS Health to provide various services to our plans and/or members and beneficiaries, as follows:
  • pension and benefit administration system,
  • Employee and Family Assistance Plan,
  • adjudication of claims under the Restorative Care Plan,
  • payment of pension benefits;
• Managed Business Solutions, an information technology service provider, who works with us to remediate data, to build and maintain a data loader, and to maintain our former administration database;
• third party service providers for the mailing of the annual statements and other plan communications as required.

These service providers are subject to additional contractual or other measures to protect your personal information.

We reserve the right to change our service providers and/or engage new service providers in our sole and absolute discretion and without advance notice or other obligation to individuals (subject to any legal requirements).

Our website

As a general policy, no personal information is automatically collected from visitors to this website, unless you submit your personal information using our registration form. However, we may receive your personal information through third parties. These third parties are usually corporations specializing in internet-related services and products. The information we use from these third parties may assist us in calculating overall site traffic patterns, analyzing user trends and to administer our site. If you wish to limit the information that we receive from these third parties, please contact us and we will do our best to assist you.

Our website may also contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide while visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.

Exceptions

We do not share your personal information with third-parties without your knowledge and consent, but there are exceptions. Your information may be disclosed to law enforcement, government and regulatory authorities, and others in accordance with legal requirements, court orders, subpoenas and rules of court. We may also disclose your information to protect our rights, and to prevent or detect fraud and other breaches of law or contract.

Your consent

The Plan collects, uses and discloses your personal information with your consent, except as permitted or required by law. Consent may be given by you or your authorized representative (such as a legal guardian or a person having a power of attorney).

Your consent to the collection, use and disclosure of personal information may be given in various ways. Consent can be expressed (e.g. orally or in writing) or implied. Generally, by providing us with personal information in connection with your enrollment or participation in the Plans, we will assume that you consent to our collection, use and disclosure of such information for the purposes of administering such plans, as described in this Privacy Statement, or such other purposes as may be identified to you at the time that the information is collected.

If you provide us with personal information about a third party, such as a spouse or beneficiary, we will assume that you have the consent of that third party to provide their personal information to us for the purposes described in this Privacy Statement and/or any other purposes identified to you at the time of collection. Accordingly, it is important that you obtain consent from such persons prior to providing us with their personal information.

Your consent will be valid for so long as necessary to fulfil the purposes described in this Privacy Statement, or otherwise identified at the time of collection. Please note that you may not be able to withhold consent to certain necessary uses and disclosures of your personal information, which are required for us to administer the Plans.

We may also be required or permitted under statute or regulation to collect, use or disclose personal information without your consent, including (without limitation) to comply with a court order, to comply with provincial or federal laws and regulations or a legally permitted request by a government agency, or to collect funds owed to the Plans.

Data Retention

The Plan has developed guidelines and implemented procedures with respect to the retention of personal information. The length of time we retain your personal information may vary depending on the circumstances and the nature of the information.

We will keep your personal information in our records so long as it is needed for its identified purposes, or as required to satisfy operational or legal requirements.

Our joint responsibility for accuracy

We take steps to confirm that the information we collect remains accurate and up to date to the extent necessary for the purposes for which it is to be used. We also ask that you contact us as soon as possible to notify us of changes to your personal information, when relevant to your participation in the plans (e.g., change in address or marital status).

Throughout the year, we mail plan related correspondence directly to members. If we receive returned mail, we attempt to locate these individuals directly to confirm their current address. Members, of course, can review their personal information on their annual Pension Statement they receive each year. This is an important opportunity to confirm the accuracy of your data. Contact The United Church of Canada Benefits Centre to request that it be updated or corrected, if necessary.

Protecting your personal information

We take steps to protect your personal information by means of various physical, technological and organizational security measures designed to protect your personal information from intrusions, theft, accidental release, loss, or unauthorized disclosure, use, copying, or modification. In addition, when we destroy your personal information, we use appropriate safeguards.

Where is your personal information located?

Personal information is kept at the General Council Office of The Church and in secure offsite storage. We also maintain an electronic database of member and beneficiary personal information, whereby information is stored on servers located in Canada.

Access to your personal information

If you wish to request access to your personal information in our custody or control, you may write to the Privacy Officer at the address set out below. With satisfactory verification of your identity, we will consider your request and generally provide you with reasonable access to your personal information subject to exceptions as required or permitted by law. If your request is made through a third party, we will need satisfactory proof of your consent and authorization to release information to that third party or to make the requested changes.

Privacy Statement changes

If we intend to use or disclose personal information for purposes materially different from those described in this Privacy Statement, we will make reasonable efforts to notify affected individuals if required by applicable law or deemed appropriate by us.

We may also revise or update this Privacy Statement from time-to-time. We urge you to request and review this Privacy Statement periodically to obtain the current version. Your continued provision of personal information following any changes to this Privacy Statement constitutes your acceptance of any such changes.

This Privacy Statement is effective as of October 11, 2023.

Canada’s Anti-Spam Legislation (CASL)

From time to time, the Plans communicate with members via email. These email newsletters are part of the Plans’ fiduciary obligation to communicate to all members with information about the Plans. These non-commercial messages are permitted under CASL, as they are in respect of a plan in which you are enrolled or under which you have entitlements. The Plans offer the option to unsubscribe from email newsletters that are sent directly-to-members. It is important to note, however, that if you do unsubscribe, you may not receive timely and important information that can impact your membership in the Plans.

Accountability

The Church has appointed a Privacy Officer to oversee compliance with its privacy policy, this Privacy Statement and our personal information handling practices.

Contact Us – Complaints, questions and concerns

If you are dissatisfied with the Plan's handling of personal information, you may make a written complaint to the Privacy Officers, as described below. The Privacy Officers will generally investigate the issue and corrective action may be taken where necessary or appropriate. We will typically advise you of any steps taken to address your concerns.

If you have any other questions or concerns about this Privacy Statement or the collection, use, disclosure or security of your personal information, please contact our Privacy Officer:

Nicole Treksler, M.A., LL.B./B.C.L.
General Counsel, Office of the Moderator and General Secretary
The United Church of Canada
ntreksler@united-church.ca
416-231-7680
1-800-268-3781