OMERS Commitment to your Privacy

In the course of administering the Plans, OMERS collects different types of personal data depending on how someone interacts with us. Examples of the categories of data we may collect to provide pension services include:

• Basic contact information: home address, email, phone number;

• Personal details: date of birth, age, gender, marital status, death notices;

• Work information: job history, earnings;

• Government ID: Social Insurance Number;

• Banking information: account details for payments;

• Legal information: power of attorney documents;

• Health information: medical details needed for benefits;

• Union or association membership;

• Communication records: emails, letters, call recordings, and metadata;

• Survey responses: answers to feedback or research surveys; and

• Other information: anything shared with us by or in respect of the individual.

OMERS strives to keep personal data accurate, complete and up to date. We may use third-party sources to verify or supplement the information we hold.

OMERS uses personal data to administer the Plans, deliver pension services and improve our operations. We may use personal data to:

• Establish and maintain Plan membership and records;

• Administer pension benefits, including processing changes in status (e.g., disability entitlement) and pay benefits to Members and Survivors;

• Provide education and information about the Plan and retirement;

• Communicate with participating employers;

• Locate Members and Survivors;

• Project future cash flow requirements for Plans;

• Fulfill legal and regulatory obligations related to pension administration;

• Research, develop, and improve our services, including identifying trends and insights to support Plan decisions;

• Record and evaluate contact centre interactions for training, quality assurance, and service improvement;

• Analyze feedback from surveys, focus groups, or interviews to tailor communications and improve operations; and

• Carry out any other purpose to which an individual has consented.

OMERS collects personal data in several ways, depending on how individuals interact with us. We may collect personal data through:

• Updates from employers throughout the employment relationship, including when an individual becomes eligible or joins the Plan

• Forms, requests for information, and surveys;

• Focus groups and interviews;

• Calls to our contact centre;

• Information entered into MyOMERS; and

• Third-party sources such as participating employers, unions or associations, the Public Guardian and Trustee, the Canada Revenue Agency, and other pension plans (e.g., for plan transfers or service buy-backs).

If you provide OMERS with personal data about another individual, you must have the necessary authority or consent to allow us to collect, use and disclose that information.

Members should use their myOMERS account or call OMERS Member Experience to update their information.

OMERS may share personal data with affiliates, subsidiaries, and service providers who support our operations. The third parties we work with help us deliver pension services, manage relationships, and meet legal and regulatory obligations. Personal data may be shared with:

• Participating employers;

• Professional service advisors such as actuarial advisers, lawyers, auditors, and consultants;

• Financial service providers (e.g., banks, payroll processors);

• Medical advisors retained by OMERS;

• Relevant parties as provided for in the OMERS dispute resolution process;

• Locator firms;

• Debt collection agencies;

• Other pension plans with which the individual has a relationship;

• Government regulators and agencies, such as the Financial Services Regulatory Authority of Ontario and the Canada Revenue Agency, as well as law enforcement, when required or permitted by law;

• Information technology service providers;

• Engagement and marketing service providers such as online analytics service providers; and

• Mailing and survey services.

De-identified and Anonymized Data

We, or our service providers, may de-identify personal data by removing identifiers or aggregating it with other data. De-identified data may be used for internal business purposes. We may also anonymize personal data so that it can no longer be used to identify an individual. Anonymized data may be used for any purpose, including sharing with third parties.

Disclosure of Information to Employers for Other Purposes

Participating employers in the Plans may need pension-related details to support workforce and succession planning, or to administer other benefit programs such as long-term disability or insurance. In addition to sharing data for pension administration, OMERS may share the following information with participating employers: a Member’s current address, hire and enrolment dates, total accrued service, unreduced early retirement date, pension amounts (including disability pensions), and living or deceased status. Members who prefer not to share this information with their employer may opt out through myOMERS.

OMERS and our service providers may use artificial intelligence and machine learning tools to process personal data, including to train and improve these technologies. These tools support internal business activities such as automating tasks, analyzing data, developing and improving services, detecting fraud, and protecting systems. OMERS is committed to using personal data responsibly and has internal processes to assess and oversee the use of these tools. This includes reviewing their purpose, the type of personal data used, the potential impact on individuals’ rights and freedoms, the risk of bias, and the extent of human oversight.

Users of our online services have a shared responsibility to keep personal data secure. Please take the following steps to help secure personal data when you use computers and mobile devices to access our services:

• Login to myOMERS and to send a secure message and upload documents;

• Install the latest security updates and anti-virus software to help prevent malware and viruses;

• Use the latest version of browsers;

• Use complex passwords to lock devices and mobile applications. Complex passwords include capital letters, numbers and special symbols; and

• Do not use the same password for multiple sites.

Members should use their myOMERS account or call OMERS Member Experience to update their information. Members should keep their OMERS Member ID and myOMERS password confidential. Do not share them with others, including family members.

We, our service providers and agents may transfer, store or access personal data outside of the jurisdiction in which it was previously collected, used or disclosed. For example, personal data collected in Ontario may be transferred outside of Ontario and/or Canada. When such a transfer takes place, personal data may be subject to the laws of those other jurisdictions, and in certain circumstances the courts, law enforcement agencies, regulatory agencies or security authorities in those other jurisdictions may be entitled to access that personal data.

Members and Survivors can make access requests through Secure Communications in myOMERS or alternatively, send a request in writing with signature by mail to: OMERS AC 100 Adelaide St. W, Toronto, ON M5H 4H1.

OMERS reviews and processes access requests in accordance with applicable law. Please note that OMERS is not subject to all privacy laws, and in some cases, access may be restricted or declined.

We retain personal data for only as long as it is needed to fulfill the identified purposes or as may be required to comply with applicable laws. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. Personal data related to pension entitlements and payments may be permanently retained for our mutual protection and to fulfill our legal obligations.

As the law develops and as we evolve our operations, the way in which we collect, use, store, and disclose personal data may change. When this happens, we will update our Privacy Statement to reflect the changes. You can review our updated Privacy Statement at any time by visiting our website, http://www.omers.com, or by requesting a copy from our Privacy Office.

If you have any comments or questions about our Privacy Statement, or if you believe that we have not complied with our Privacy Statement, please contact our Privacy Office as follows:

Privacy Office
900-100 Adelaide Street West
Toronto, ON M5H 0E2
Email: privacy@omers.comOpens email client

In the course of HR operations, OMERS collects personal data about you. Examples of personal data that OMERS may collect includes:

• basic contact information, such as home address, email and telephone number;

• date of birth;

• gender identity and sexual orientation;

• race and ethnicity;

• employment and education history;

• background check information;

• citizenship status;

• marital and family status;

• identification documents, such as your passport, government identification number, or driver’s license;

• banking information;

• emergency contact and beneficiary information;

• health-related information;

• job title, salary, workplace engagement, performance, disciplinary, and professional development information; and

• any other personal information you provide us.

We use personal information about you for purposes of establishing, managing, and administering our relationship with you and the work you perform for us. Some examples of how we may use your personal information include:

• workforce planning and recruitment, including business forecasting, Employee assignment planning, and budgeting;

• determining eligibility and suitability for initial and ongoing employment, including the verification of references and qualifications as part of a background check, and aptitude and personality;

• administering all HR policies and programs throughout employment, including managing talent, diversity and inclusion initiatives, Employee engagement, learning and development, health and safety, evaluation of performance, compensation, benefits and promotion;

• performance of our business operations, including allowing us to work together and collaborate, to provide our services, ensuring business continuity, enforcing our rights and protecting our operations, and pursuing available remedies and limiting any damages we may sustain;

• legal and regulatory compliance, including ensuring compliance with health & safety requirements and legal or tax obligations, investigating or auditing compliance with our policies regarding anti-money laundering, bribery, and corruption, and responding to law enforcement requests; as required by applicable law, court order, or governmental regulations;

• if applicable, providing relocation support, which may include facilitating work permits or visas;

• acquiring and transferring our businesses;

• protecting OMERS businesses against and investigating error, fraud, and misconduct;

• drawing insights from our Employee data, to improve performance and culture;

• premises security management, including using access control systems and the use of CCVS cameras;

• information security management, including controlling access to information technologies and data and preventing cybersecurity breaches and data loss;

• performing functions required or authorized by law; and

• for any other purpose to which you consent.

The personal data that we use generally comes from you. You provide us with your personal data when you complete forms, respond to our requests for information, participate in our surveys, or interact with our systems and processes. In some cases, the personal data we collect from you may be optional. If this is the case, we will let you know that you can decline to provide this information.

We may also collect personal data from third parties. For example, we may collect information from your public social media profile, recruiters, your references, background check providers, third-party assessors in the event you have a disability and require accommodation, and other third parties that assist us in managing our HR needs or the benefits programs in which you participate.

If you provide us with personal data about another person, such as your beneficiary, you represent that you have all necessary authority and/or have obtained all necessary consents from that individual to enable us to collect, use and disclose that personal data.

We monitor OMERS facilities, networks, and assets (including mobile devices) in order to detect, prevent, and investigate error, fraud, or misconduct as well as threats to the security and operation of our IT systems and our data. This may include using technologies that profile user behaviour to identify unusual activity (such as logins from unexpected country locations) or to prevent data loss (such as export or email of data that is unusual or in violation of our policies).

Our acceptable use policies may permit limited and occasional use of OMERS facilities, networks and assets for personal purposes. Please check your OMERS group company policies. If you choose to use OMERS facilities, networks and assets for personal purposes, you should have no expectation of privacy since any such use will be monitored.

Electronic monitoring data is accessible to a limited number of authorized Employees in our information technology and security teams. However, in the event of an investigation into a potential breach of our policies or other wrongdoing, electronic monitoring data may be accessed and used for the purposes of the investigation, including for disciplinary purposes up to and including termination for cause.

Please download the Employee Privacy Statement and see Appendix 1.

We may share your personal data with our affiliates and service providers who assist us with our business operations.

Below are some examples of third parties with whom we may share your personal information:

• information technology providers, such as cloud hosting services and software services;

• professional services providers, such as auditors, lawyers and consultants;

• recruitment services and background check providers;

• workforce planning and management service providers;

• services associated with corporate culture initiatives, including inclusion and diversity programs;

• survey, feedback and poll providers;

• data analytics service providers;

• Employee coaching, training and education providers;

• travel and advisory services providers;

• expense recovery service providers;

• physical and digital safety and security service providers;

• collaboration technology service providers;

• global mobility and tax service providers;

• payroll providers;

• Employee benefits providers (including Employee health and wellness providers);

• your financial service providers such as your bank; and

• governmental agencies, such as national and regional tax authorities.

OMERS or its service providers may combine personal data that we have about you and apply advanced analytical methods to derive insights that will help us to improve our HR operations and your experience as an Employee. We may also de-identify personal information by removing identifiers and aggregating information about you with information about other Employees. OMERS and its service providers may use this de-identified information for internal business purposes. In addition, OMERS may anonymize personal information so that it can no longer be used to identify you. OMERS may use and disclose this anonymized data for any purpose including sharing this information with third parties.

OMERS and our service providers may incorporate artificial intelligence and machine learning tools to process your personal information, including using it to train and refine algorithms. These tools help us, and our service providers, in internal business activities, such as automating tasks, evaluating data, developing new HR initiatives, benefits, products or services, securing business systems, and other business purposes. OMERS is committed to the ethical use of your personal data and has developed processes and oversight for the development and use of these tools. This may require that OMERS evaluate an artificial intelligence or machine learning tool for its appropriateness, the sensitivity of the personal information processed, the impact on the rights and freedoms of individuals, and the potential for bias in the tools if they are being used to assist in decision-making.

Through our internet(s) including our careers portals, we place files called “cookies” on your internet browser. These files ensure our websites function correctly during your visit and can also help our site remember any preferences you’ve set to assist you during future visits. Cookies used on OMERS websites also help us understand how our websites are used by visitors, including analyzing traffic trends, and how websites perform.

OMERS provides website visitors with choice over the cookies that are placed on their browsers. Visitors to our websites may use browser settings to control what cookies are placed in their browsers. In some cases, our website may also provide you with a cookies consent manager that will provide you with options.

Our websites may provide links to websites that are operated by third parties external to OMERS. This Privacy Statement does not describe the privacy policies of any third-party websites on their privacy practices or their respective privacy practices. We are not responsible for how such third parties collect, use, or disclose your personal data, so it is important to familiarize yourself with their privacy policies before providing them with your personal data.

Whether in electronic or paper-based format, we implement technical and organizational measures to ensure an appropriate level of security, keeping in mind the nature, scope, context and purpose of processing, cost, and the potential risk to you. We use appropriate technology and efforts designed to safeguard your personal data from loss, theft, and unauthorized access, use or disclosure. We require our service providers and agents to protect personal data processed on our behalf.

OMERS group companies operate in many countries, and we may need to transfer personal data to different countries to consolidate and centralize HR, D&T and other business functions, to improve efficiency by leveraging international expertise and technologies, and to facilitate collaboration among international teams. Therefore, we and our service providers may store, access or otherwise process your personal data outside of the jurisdiction where you applied for employment or were employed. Transfers of personal data will be made in compliance with applicable data protection legislation and will only be made where there are suitable safeguards in place.

When a transfer takes place, personal data may be subject to the laws of those other jurisdictions, and in certain circumstances, the courts, law enforcement agencies, regulatory agencies or security authorities in those other jurisdictions may be entitled to access your personal data.

You may request access to your personal information by contacting the HR Team. Current employees may submit a WorkdayOpens new window case. Former employees and applicants may e-mail a request to peopleexperience@omers.comOpens email client. Upon verification of your identity we may provide you with access to your personal data, subject to applicable law.

We try to ensure that the personal data we collect about you is accurate, complete and up-to-date. However, we rely on you to provide accurate information in the first instance, and to notify us when there is a change in your personal data.

We retain personal data for only as long as it is needed to fulfill the identified purposes or as may be required to comply with applicable laws. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

As the law develops and as we evolve, the way in which we collect, use, and disclose personal data may change. When this happens, we will update our Privacy Statement to reflect the changes. You can review our updated Privacy Statement at any time by visiting our website, or by requesting a copy from our Privacy Officer.

We have appointed a Privacy Officer who is responsible for overseeing our compliance with applicable privacy laws. If you have any comments or questions about our Privacy Statement, or if you believe that we have not complied with our Privacy Statement, please contact our Privacy Officer as follows:

Head of Privacy
900-100 Adelaide Street West
Toronto, ON M5H 0E2
Email: privacy@omers.comOpens email client