Effective Date: Feb 1 2017
The Open Access
Open Access Limited (“Open Access”, “we”, “us” or “our”), respects your privacy and protect the confidentiality of
procedures concerning the collection, use, disclosure and retention of personal
information and reflects our commitment to compliance with applicable privacy
laws, including the federal Personal Information Protection and Electronic
Documents Act (PIPEDA).
Information We Collect
Personal information is any information
about an identifiable individual. Most of the personal information we collect
is received either directly from individual plan members (“Members”) or from sponsoring employers (“Sponsors”).
We collect personal information as
necessary to allow us to provide retirement plan and related services. We collect
name and contact information from Sponsor representatives.
In order to establish and operate
individual plan member accounts, we require various kinds of personal
information about Members including the following:
Name and contact information.
Social insurance number.
Place of employment.
Date of birth.
Family member information for
Net worth including information
about your savings, assets and investments.
Investment and retirement
Each Member is asked to complete an
Investor Profile which provides us with the personal information required to
set up and operate that Member’s account, including information that enables us
to select the correct investment portfolio and update that portfolio selection
We Use Personal Information
We use Member personal information in
order to establish, operate and maintain the Member’s account or retirement
plan. This may include verifying a Member’s identity, evaluating a Member’s
investment and retirement objectives and determining the suitability of our
products and services for that Member and communicating with the Member,
including providing periodic account statements, newsletters, and information
about other products and services.
We use personal information relating to
Sponsors and their representatives in order to establish, operate and maintain
the Sponsor’s employee benefit plan.
This includes providing plan related communications, and communications
about other products and services.
We may use personal information as
necessary to comply with our legal, regulatory, self-regulatory, audit and
insurance requirements, and for other purposes with your consent or as
permitted or required by law.
We Disclose Personal Information
We may retain third party service
providers (including affiliates and advisors acting in this capacity) to assist
us with administrative tasks related to account and plan operation and
maintenance (including for information technology, data hosting, data
processing, marketing, analytics, audit, statistical or record-keeping
purposes. Where these service providers are given access to personal
information in connection with services performed for us, they are made aware
disclosed to service providers in such circumstances will also be limited to
that required in order to fulfill the purpose(s) for which disclosure is taking
place. Some of these service providers may be located outside of Canada,
including the United States, and as a result, your personal information may be
processed and stored outside of Canada.
While outside of Canada, personal information will be subject to
applicable foreign laws, which may permit foreign government, regulatory or
national security agencies to access information in certain circumstances.
We may disclose personal information in
the context of an actual or possible corporate reorganization, merger or
amalgamation, or an actual or possible sale of all or a substantial portion of
our assets. In such circumstances, disclosure would occur on the condition that
the information only be used for the purpose of evaluating the transaction, or
on completion of the transaction, for the purposes outlined in this Privacy
We may disclose personal information as
necessary to meet legal, regulatory, industry self-regulatory, insurance, audit
and security requirements, and otherwise with your consent or as permitted or
required by law, including as necessary to comply with Canadian and foreign
laws applicable to us or our service providers. For example, we disclose to the
Canada Revenue Agency such information as is required by law for income tax
Our website may use tracking
technologies, such as “cookies”. A “cookie” is a small text file containing a
unique identification number that identifies the Internet browser of the
visitor. This information is transmitted to us each time our website is
visited. Cookies allow us to collect and store information such as the type of
Internet browser and operating system you use; the date, time and duration of
your visit to our website; the Internet address of the website from which you
linked to our website; and the pages that you visited while on our website.
Unless you actively submit personal information while on our website, however,
be able to adjust your browser settings to block cookies or to notify you
before a cookie is sent.
Consent to the collection, use and
disclosure of personal information may be given in many ways. For example, by completing and signing the
Open Access Investor Profile, Members expressly consent to the collection, use
Consent may also be implied if you provide your personal information for a
specific purpose. If you provide us with
personal information relating to someone else (for example, a spouse or
beneficiary), we will assume that you have obtained that individual’s consent
to provide their personal information to us for the purposes described in this
You may withdraw your consent to our
collection, use and disclosure of personal information at any time, subject to
contractual and legal restrictions and reasonable notice. For example, if you no longer wish to receive
our newsletters or promotional communications, you may withdraw your consent at
any time by contacting our Privacy Officer or by using the unsubscribe feature
in the message, where applicable.
However, if you withdraw your consent to certain collections, uses or
disclosures of your personal information, we may not be able to continue to
provide you with our products and services.
your Personal Information
Personal information is maintained in a file
on our servers (or those of our service providers) and will be accessible by
authorized employees, agents and representatives who require access in order to
provide products or services to you or to maintain those products or services.
We employ various physical, electronic and procedural safeguards to protect
your personal information.
of Personal information
We retain personal information for as
long as is necessary to fulfill the purpose(s) for which it was provided,
unless we are required or permitted by law to retain the information for a
longer period. Personal information that is no longer needed is securely
destroyed or made anonymous as appropriate.
You may request access to or correction
of the personal information we hold about you by writing to our Privacy Officer
using the contact information set out in the “Questions or Concerns” section
below. Your right to access or correct
personal information is subject to applicable legal restrictions. If we are unable to provide access, where
possible, we will provide reasons for our inability to do so. We may take reasonable steps to verify your
identity before granting access or making corrections.
date noted above. From time to time we
frequently to obtain the current version. Your continued provision of personal
constitutes your acceptance of any such changes.
and with applicable privacy laws is overseen by our Privacy Officer. If you
practices, please contact our Privacy Officer at:
1 Richmond Street West, Suite 800
© 2016 Open Access Ltd.