Privacy Policy

Privacy Policy

Last updated: February 13, 2023

Your privacy and trust are of utmost importance to the Co-operative Superannuation Society (CSS). CSS and its agents are committed to protecting your privacy and the confidentiality of your personal information. 
 
Our collection, use and disclosure of your personal information is regulated by the Personal Information Protection and Electronic Documents Act (Canada), or similar privacy legislation applicable in your province, as amended from time to time. You can find more information about your privacy rights at the web site of the Office of the Privacy Commissioner of Canada (OPC), http://www.priv.gc.ca.
 

We are responsible for protecting the personal information under our control

Personal information refers to information that can identify you, such as your name, date of birth or pension information. This Privacy Policy does not apply to information that is not personal information.

 

Accountability

CSS has appointed a Privacy Officer to ensure compliance with this Privacy Policy and our personal information handling and safeguarding practices. The Privacy Officer oversees all activities related to the development, implementation, maintenance, and adherence to this Privacy Policy.

 

What this policy covers

Our aim is to be clear about how we collect, use, and disclose information about you. This Privacy Policy is provided to help you understand:

  • Why we collect, retain and use your personal information 

  • Who is bound by this policy

  • The type of personal information we collect

  • How consent is provided to CSS to collect personal information

  • How long we retain personal information

  • The ways we collect personal information

  • How we protect and safeguard your personal information

  • How to contact the CSS Privacy Officer

  • How to access your personal information

  • The application of Canada’s Anti-Spam Legislation to CSS

This Privacy Policy will continue to apply for as long as CSS holds your personal information, including after the termination of any CSS product or service you may use. By providing us with your personal information, you are consenting to the collection, use and sharing of your personal information as set out in this Privacy Policy.

This Privacy Policy may be updated periodically to reflect changes to our privacy practices. Any changes we make to this Privacy Policy will be effective when we post the revised policy on our website. We encourage you to refer to this Privacy Policy periodically for the latest information about our privacy practices.

Why we collect, use and retain your personal information

Your personal information is necessary for us to administer any CSS product or service you may use. These products and services include, but are not limited to, the provision of retirement products and services, including the CSS Pension Plan. Your personal information is necessary for us to fulfill our legal and regulatory obligations in providing these products and services. Examples of why we collect and retain your personal information include:

  • creating and maintaining a database of members and other individuals entitled to CSS products, services, and benefits;

  • producing and issuing various personalized pension statements, notices and retirement or termination options documents;

  • verifying eligibility of claims for benefit entitlement;

  • fulfilling reporting requirements and compliance with pension legislation and regulations, the Income Tax Act (Canada) and any other pension, employment, family law or other legislation applicable in your jurisdiction, to the extent that they apply;

  • verifying your identity when communicating with you;

  • managing and administering the pension plan including the collection of funds owing to the pension plan; 

  • ensuring you can vote in CSS delegate elections, when eligible; and

  • receiving your consent as permitted or required by law.

CSS is committed to using your personal information only for the purpose(s) for which it was collected. 

 

Who is bound by this policy

The CSS Pension Plan, like most organizations, relies on a number of resources to deliver the services and experiences you expect. These resources include CSS employees, employer members of CSS, as well as outside service providers with whom CSS contracts. Each of these resources is bound by this policy through a variety of measures, including:

  • Employee Code of Conduct

  • Ensuring only the information required to administer your pension benefits is shared between CSS and your employer

  • Specific privacy terms and conditions being included in agreements between CSS and the outside providers with whom CSS contracts

CSS periodically employs outside privacy experts to audit its privacy practices and policies to ensure they comply with current relevant legislation and industry best practices and that they are effectively implemented.


Types of information CSS collects

The personal information CSS collects varies depending on your relationship with us (for example, member of CSS, pension plan member, retired member, former member, prospective member, beneficiary or spouse of a pension plan member) and may include:

  • your name, address, telephone number, and other contact information;

  • biographical information such as your gender, date of birth and spousal marital status;

  • employment information including the name of your employer(s), and employment dates, and where applicable, employment category and, employment earnings;

  • the name and date of birth of your spouse, children and beneficiary, if applicable;

  • benefit amounts;

  • information included on a death certificate;

  • divorce or separation agreement information;

  • orders or judgments from a court, tribunal or similar body relating to pension entitlement;

  • declarations in connection with marriage breakdown;

  • power of attorney;

  • social insurance number and banking information; and

  • other information with your consent that is required to fulfill a legitimate identified purpose, administer your pension benefits, or as permitted or required by law.

 

Providing consent to CSS to collect personal information

Your consent to CSS’ collection, use and disclosure of personal information may be given in various ways. Consent can be explicitly expressed (for example, orally or in writing) or implied (for example, when you provide confidential information to the CSS Pension Plan by unsecure email; in this case, CSS may take this as your consent to send confidential information to you by unsecure email).

Consent may be given by your authorized representative (such as a legal guardian or a person having a power of attorney). Beneficiaries and spouses will need to consent to the use of their information to pay a survivor benefit. 

Generally, by providing us with personal information, we will assume that you consent to our collection, use and disclosure of such information for the purpose identified or described in this Privacy Policy, if applicable, or otherwise at the time of collection. If you provide CSS 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 CSS.

When you become a member of CSS, enroll in the pension plan, become entitled to benefits under the pension plan, or partake in any CSS retirement product or service, your consent will be valid for so long as necessary to fulfill the purposes described in this Privacy Policy or otherwise at the time of collection, and you may not be permitted to withdraw consent to certain necessary uses and disclosures (for example, but not limited to, maintaining reasonable administration and transaction records, disclosures to government entities as required to comply with laws).

CSS collects, uses and discloses your personal information with your consent, except as permitted or required by law. We may be required or permitted under statute or regulation to collect, use or disclose personal information without your consent, for example to comply with a court order, to comply with local or federal regulations or a legally permitted inquiry by a government agency, or to collect funds owed to the pension plan.


We limit the length of time we retain your personal information

CSS 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 business or legal requirements.

 

Ways we collect and use personal information

CSS collects personal information directly from you, the devices you use to access our website, and third-party service providers, if necessary, to administer your pension benefits. When you join CSS as a member or open a pension or retirement income account, CSS may request or disclose information with your employer that is required to administer your pension benefits or to provide you with pension or retirement related products and services.

There are several ways that CSS may collect personal information from you, including:

 

1. Member Service Communications: 

From time to time, we may send you email, SMS text messages and other communications about CSS products, services, events, or other information that may be of interest to you. You can opt-out of receiving these types of email from us by following the unsubscribe instructions contained in each of our email communications.

If you contact a member service agent at CSS with a comment, question or complaint by email, text message, web chat, telephone or video chat, you may be asked for information that identifies you (such as your name, address and a phone number) along with additional information we need to help us promptly answer your question or respond to your comment or complaint. We may record the conversation or retain this information to assist you in the future and to improve our member service and, product and service offerings.

CSS periodically requests feedback from our members through surveys. As part of the survey process, we may collect personal information (such as your name, address and a phone number) so that we can follow up with you for more information on a comment you’ve provided or question you’ve raised in your survey responses. We may record the follow-up conversation or retain this information to assist you in the future and to improve our member service and, product and service offerings.

 

2. Paper and Digital Forms: 

All information forms we ask members to complete request only the information we need for regulatory purposes, income tax requirements, and to effectively deliver personalized products and services to our members. Depending on the CSS products and services used by a member, the information collected may include: name, address, phone and fax numbers, email addresses, birth date, social insurance numbers (for tax reporting purposes), financial assets and liabilities (including values), investment knowledge and financial and retirement objectives. We may also collect your banking account information to facilitate making payments to you. And, we may collect beneficiary information (for example, spouse’s name and birth date, and children’s and dependents’ names and ages).

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

 

3. Risk and Other Questionnaires: 

We may also collect your responses to a risk questionnaire and other regulatory questions that we are required by law to collect. We do not disclose any non-public personal information to any third party except as required by law, to administer your retirement and pension services and benefits, or as outlined in this Privacy Policy.

 

4. Online: 

In general, you can visit our website without indicating who you are or submitting any personal information. However, we collect and/or maintain the IP (Internet protocol) addresses of all visitors to the website and other related information such as page requests, browser type, operating system and average time spent on the website. We use this information to help us understand activity and to monitor and improve the website.

Cookies & Similar Technologies: The website uses a technology called “cookies”. A cookie is a tiny element of data that the website can send to your browser, which may then be stored on your hard drive so that you can be recognized when you return. We use cookies on the pages on the website where you are prompted to log in or that are customizable. 

If you have registered with the website, these cookies may let us know who you are and identify your browser as one that has visited the website before and may be necessary to access your account information (stored on our computers) in order to deliver products and personalized services. 

We also use cookies to provide us and our service providers with information about your use of the website that we may use to personalize the website or other content in accordance with your interests and preferences and improve your user experience. You may set your Web browser to notify you when you receive a cookie or to not accept certain cookies. However, if you decide not to accept cookies from the website, you may not be able to take advantage of all of the features of the website.

Analytics: We may use third parties, including Google Analytics, to help us gather and analyze information about the areas visited on the website in order to better understand, evaluate and improve the user experience and the convenience of the website.

Social Media: We may offer you the opportunity to engage with our content on or through third-party social networking websites, plug-ins and applications. When you engage with our content on or through third-party social networking websites, plug-ins and applications, you may allow us to have access to certain information associated with your social media account (for example, name, username, email address) to deliver the content or as part of the operation of the website, plug-in or application.

Third-party Websites: Our website may contain links to other websites that we do not own or operate. Also, links to our website may be featured on third party websites. Except as provided herein, we will not provide any of your personal information to these third parties without your consent. We provide links to third party websites as a convenience to the user. These links are not intended as an endorsement of or referral to the linked websites. The linked websites have separate and independent privacy policies, notices and terms of use, which we recommend you read carefully. We do not have any control over such websites, and therefore we have no responsibility, accountability or liability for the manner in which the organizations that operate such linked websites may collect, use or disclose, secure and otherwise treat your personal information.

 

5. Employment:

If you inquire about or apply for a job with CSS, you may provide us with certain personal information about yourself (such as that contained in a resume, cover letter, or similar employment-related materials). We use this information for the purpose of processing and responding to your application for current and future career opportunities.

All of our positions are posted on csspen.com and may also be posted on a variety of online job boards. To assist in preventing fraud that targets potential job candidates of CSS, please note the following:

  • Do not complete any paperwork or online forms such as background checks or employment agreements unless you have verified the identity of the CSS employee that is making the request

  • CSS will never ask for any form of payment or request you to purchase equipment as part of the job application process

We continually monitor our data collection practices and encourage you to reach out to us if you have any questions or concerns about these practices.

 

Protection and safeguarding of your personal information

Your data is stored securely at CSS or on the systems of our trusted partners. We may use this data for account verification, processing service requests you make of CSS, fraud prevention, providing information on CSS products or services, tailoring your online or in-person experience, or improving and developing our website, products and services.

We will not disclose, trade, rent, sell or otherwise transfer your personal information, without your consent, except as otherwise set out in this Privacy Policy. We do not disclose any non-public personal information to any third party except as required by law, to administer your pension benefits, or as outlined in this Privacy Policy.

  • Service Providers: We may transfer your personal information to third party service providers who provide various services on our behalf such as identity verification, technology, administration, printing, member communications, hosting, data analysis, legal, actuarial or insurance services, audit and accounting. We provide service providers access to CSS members’ personal information only on a “need to know” basis in order for them to fulfill their requirements.

  • Legal: We may provide your personal information in response to a search warrant or other legally valid inquiry or order, or to another organization for the purposes of investigating a breach of an agreement or contravention of law or detecting, suppressing or preventing fraud, or as otherwise required or permitted by applicable law. We may also disclose personal information where necessary for the establishment, exercise or defence of legal claims and to investigate or prevent actual or suspect loss or harm to persons or property.

We store personal information electronically on computer servers to which only authorized persons have access, and only by means of secure passwords and other protective measures. We authorize employees and service providers to have access to members’ personal information only on a “need to know” basis in order to fulfill their job requirements.

While we cannot guarantee that a breach will never occur, we maintain reasonable (i.e., leading industry practice) administrative, technical and physical safeguards in an effort to protect personal information in our custody and control against unauthorized access, use, modification and disclosure. We train our employees to keep members’ personal information strictly private and confidential. We require all of our staff to sign our code of conduct document that obliges them to respect and protect members’ personal information. We ensure that departing staff understand they remain contractually obliged to respect the privacy of members’ personal information.

Our service providers are transferred the information they need to perform their designated functions and committed to maintaining your confidentiality. Our service providers are not permitted to use your information for any unauthorized purpose. Your personal information may be maintained and processed by third party service providers outside of Canada. In the event personal information is transferred to the US or other foreign jurisdiction, it will be subject to the laws of that jurisdiction and may be disclosed to or accessed by the courts, law enforcement and governmental authorities in accordance with the laws of those jurisdictions.

Your online access to your account is protected with a password you select. We strongly recommend that you do not disclose your password to anyone. We will never ask you for your password in any unsolicited communication (such as letters, phone calls or email messages).

We have personal information retention processes designed to retain personal information of our members and prospective members for no longer than necessary for the purposes set out in this Privacy Policy or to otherwise meet legal or regulatory requirements.

 

How to contact CSS’ Privacy Officer

CSS’ Privacy Officer is responsible for ensuring that CSS adheres to its privacy policy. The Privacy Officer is responsible for ensuring our employees are trained on our privacy policies and for monitoring the fulfillment of our privacy commitments. We invite any member or prospective member to contact our Privacy Officer at the contact information set out below for any additional clarification desired. If you wish to review your personal information in our possession, please send a written request to this effect to privacy@csspension.com.

CSS’ Privacy Officer can also be reached at:

CSS Privacy Officer

PO Box 1850

Saskatoon, SK  S7K 3S2

306-477-8500

We will provide you with access to your information

Individuals have the right to access, update, and correct personal information in CSS’ custody and control, subject to certain exceptions prescribed by law. You may update certain profile information you have provided to us by logging in to your account online and following the instructions provided on our website. Otherwise, if you wish to request access, updating and corrections of inaccuracies in personal information in our possession or control, you may send a written request to this effect to privacy@csspension.com. We may request certain personal information for the purposes of verifying the identity of the individual seeking access to their personal information records.

 

Canada’s Anti-Spam Legislation (CASL)

From time to time, CSS communicates with members via email. These email newsletters are part of the CSS’ fiduciary obligation to communicate to all members with information about the pension plan and other information of importance to members and other beneficiaries of the pension plan. These non-commercial messages are permitted under CASL, as they are in respect of a benefit plan in which you are enrolled or under which you have entitlements. The Plan does offer the option to unsubscribe from email Newsletters that are sent direct-to-member. 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 CSS and the pension plan.