PRIVACY STATEMENT

This privacy statement (this “Statement”) describes the practices of Benefit Plan Administrators Limited and its corporate affiliates (“BPA”, “we”, “us”, “our”) with respect to how we may collect, use, disclose, retain, dispose and otherwise process (collectively, “process”) your employees’ personal information provided to us from you as a user of (a) the website (the “Portal”) (b) any front-end software provided by us (the “Software”) and (c) the services we provide through the Software (the “Service”). This Statement is incorporated by reference to the general Terms of Use and forms an integral part of it. All capitalized terms not otherwise defined herein have the meaning provided in Terms of Use. We also govern our activities in accordance with our Privacy Policy which can be found on our website at www.bpagroup.com. We encourage you to review both this Statement as well as our Privacy Policy.

1. Introduction and General Concepts

We respect and uphold individual rights to privacy and the protection of personal information. We know how important it is to protect your employees’ personal information and have developed this Statement to explain our practices for processing the personal information that is being submitted.

1. Personal Information

   For the purposes of this Statement, “ personal information” means any information about an identifiable individual, including but not limited to an individual’s name, home address, telephone number, gender, but excludes any business contact information that is processed solely for the purpose of communicating with that person in relation to their employment or profession, any information that is anonymous or unidentifiable such as web browsing information or aggregate information, and any other information otherwise exempted pursuant to the applicable laws of Canada and other applicable jurisdictions.
   We will only process your personal information in accordance with this Statement, applicable laws and our ordinary business practices.

2. Privacy Officer

   We have appointed a Privacy Officer who is responsible for our compliance with this Statement. Information on how to contact the Privacy Officer can be found below.

2. Collection of Personal Information

When you use our Portal, Software or Service, we may collect the following personal information about your employees:

• name, Social Insurance Number, and other identifiers (e.g., union number),
• job classification, work status, salary/compensation information, hours or units of work.

To ensure our Portal, Software or Service is optimized for your use, we or our service provider (s) may save your user data in the form of cookies and use such cookies to collect standard Internet log information about how and when you use our Portal, Software or Service. This information may include but not be limited to, your IP address and location data, weblogs, time, date, your language preferences, browser used, referring web addresses, other communication data, searches conducted, pages visited. You can manage your cookie preferences, but please note that if you refuse to allow cookies certain features of our Portal, Software or Service may not be available for your use.

3. Use and Disclosure of Personal Information

We may use and disclose your employees’ personal information provided to us for the following purposes (the “Purposes”):

• to verify eligibility and authenticate the identity of your employees;
• to share the information with BPA and its affiliates’ employees, employees’ unions, and third parties involved in delivering benefit services such as insurers, benefit card companies, custodians, credit agencies, other service providers, and Canada Revenue Agency; and
• As otherwise required or permitted by law.

We will only process personal information provided to us for the Purpose(s) outlined above.

4. Consent

We will process personal information only with the knowledge and consent of those individuals whose personal information is being submitted through this portal, except where required or permitted by applicable laws. For greater clarity, you acknowledge and confirm that to the extent you are submitting personal information on someone else’s behalf that you have the legal right and consent to do so.

If you do not consent to the processing of the personal information in accordance with this Statement, please do not provide any employee personal information to us through this Portal.

You may notify us at any time that you wish to withdraw or change your consent to our processing of the employee personal information, subject to legal restrictions and reasonable notice by deleting your account within the Portal, Software or Service and stopping use of the Portal, Software or Service. However, upon your withdrawal or change to your consent, we may not be able to provide you with access to the Portal, Software, or Service.

5. Security of Personal Information

The security of personal information provided to us is important. We follow and employ generally accepted industry standards as appropriate to the sensitivity of the personal information submitted to us, both during transmission and once we receive it. We employ physical, administrative, contractual, and technological safeguards to protect personal information, and insist that our service providers do the same. We require that our employees, and those of our providers, only access and use personal information in order to properly perform those duties, and even then, only to the strict extent necessary to perform them.

However, no method of transmission over the Internet, or method of electronic storage, is 100% secure, and so we cannot guarantee the security of the personal information provided to us, and you should always exercise caution when disclosing any personal information over the Internet.

6. Employee Requests for Access to and Correction of Personal Information

Applicable Privacy Laws allow, to varying degrees, individuals the right to access, and request the correction of errors or omissions in, his or her personal information that is in our custody or under our control. This includes:

• identification of personal information under our custody or control;
• information about how personal information under our control may be or has been used by us; and
• the names of any individuals and organizations to which the individual’s personal information has been disclosed.

We will respond to requests within the time allowed by applicable privacy laws and will make every effort to respond as accurately and completely as possible. Any corrections made to personal information will be promptly sent to any organization it was disclosed to.

In certain exceptional circumstances, we may not be able to provide access to certain personal information we hold about an individual. If access cannot be provided, we will notify the individual making the request within 30 days, in writing, of the reasons for the refusal.

7. Retention of Information

We keep your employee’s information for only as long as we need it for legitimate business purposes and to meet any legal requirements. Personal information used to make a decision that directly affects an individual will be kept for at least one year after such a decision. We have retention standards that meet these parameters. We destroy the information when it is no longer needed or required to be kept, or we remove the personally identifiable information to render it anonymous

8. Updates or Changes to Privacy Statement

We may update this Statement to reflect changes to our information practices. If we make any material changes, we will provide a notice on the Portal or otherwise through the. We encourage you to periodically review this page for the latest information on our privacy practices. Any change to this Privacy Statement will become effective on the date so indicated and will apply to information collected from the date of the posting of the revised privacy Statement and to existing information held by us. The date on which the latest update was made is indicated at the bottom of this document. We recommend that you print a copy of this privacy Statement for your reference and revisit this Statement from time to time to ensure you are aware of any changes. Your continued use of the Service signifies your acceptance of any changes to this Statement.

9. Contact Information of Privacy Officer

You can direct any questions or concerns regarding our compliance with this Statement to our Privacy Officer by emailing at privacy.officer@bpagroup.com

If you are not satisfied with our Privacy Officer’s response to their question or concern you may be able to make a complaint under applicable privacy laws. Our Privacy Officer can provide you with the contact information to make such a complaint.

Privacy Officer
The BPA Financial Group of Companies
90 Burnhamthorpe Road West, Suite 300
Mississauga, Ontario L5B 3C3
Tel: (905) 275-6466
Fax: (905) 275-6461
Toll Free: 1-800-867-5615
Email: privacy.officer@bpagroup.com

10. Changes to Privacy Statement

Privacy laws continue to evolve and, as a result, this Statement may be changed by us from time to time at our full discretion without any prior notice or liability to you or any other person. The processing of your personal information by us will be governed by the version of this Statement in effect at that time.

Privacy Statement Last Updated July 26, 2023