UPP Privacy Statements

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Introduction

The University Pension Plan Ontario (“UPP”, “we”, “us” or “our”) is a jointly sponsored pension plan designed to enhance the long-term sustainability of university pension plans in Ontario.

We may make changes to our Privacy Statements from time to time, including as necessary to ensure that Personal Information is handled appropriately and in accordance with our policies and procedures, to reflect relevant changes in legislation, and incorporate any applicable guidance from regulators and other governmental authorities. Any changes we make will become effective when we post a modified version of the Privacy Statements on our Website. The “Effective Date” indicates when it was last updated.

Member Privacy Statement

Effective Date: December 2024

This Privacy Statement applies to the personal information collected by UPP for purposes related to administering the UPP and your pension benefit, communicating with and serving you, or otherwise in accordance with your consent. This Privacy Statement applies to your interactions with us in relation to UPP, including when you access our website at www.myupp.ca or an online account access portal on which this Privacy Statement is posted (collectively, the “Website”), and when we administer your pension entitlement, the plan or otherwise provide services related to UPP (collectively, “Services”).

“Personal information” is any information about an identifiable individual. This may include, for example, your name, home address, contact information, email address, and information relating to your pension entitlement with us. It may also include more technical information, but only when this information can identify you as an individual. Information that is aggregated and/or de-identified and cannot be associated with an identifiable individual is not considered to be personal information.

In becoming a UPP plan member, sending or responding to communications or otherwise submitting information to UPP in connection with using our Services, you are providing UPP with your consent to the collection, use and disclosure of personal information as set out in this Privacy Statement.

We will generally obtain consent when we want to use personal information for a new purpose or for a purpose other than those stated at the time of collection in this Privacy Statement.

Because participation in UPP is mandatory for full-time employees, and part-time employee members cannot withdraw from UPP once they have elected to participate, members cannot entirely withdraw from our collection, use and disclosure of their personal information for purposes related to plan administration.

If you decide to leave the plan following employment (for example, by transferring your lump sum entitlement into a locked-in RRSP) we will continue to collect, use and disclose your personal information only as necessary for fulfilling our contractual obligations with participating employers to the extent permitted by applicable law, or as otherwise required or permitted by applicable law.

For those part-time employees who have elected not to participate in UPP, we retain certain personal information necessary for UPP to keep accurate records of that choice, or as otherwise required or permitted by applicable law.

Notwithstanding the above, all plan members may consent to and withdraw from the use of their personal information for non-mandatory purposes at any time.

For information on how to manage your preferences, please see Your Choices.

If you choose not to provide us with certain personal information, or if you withdraw your consent where such withdrawal is available, we may not be able to provide you with certain Services.

We limit the collection of personal information to what is required to fulfill the purposes set forth in the How we Use Personal Information section, or otherwise in accordance with your consent. Personal information we collect may include:

  • Identifiers and contact information, such as your name, employee number, email and postal addresses, telephone numbers, social insurance number and pension plan account number, and personal documentation, such as your birth certificate, driver’s license, passport, citizenship card, or marriage certificate (as applicable, where we need such documentation in order to verify certain information, we have otherwise collected from you);
  • Demographic information, such as your biological sex, gender identifier, date of birth, marital status, and languages;
  • Financial information, such as your salary, benefit amounts, tax information and banking information;
  • Plan administration information, such as your membership status, the name of your employer, powers of attorney and other legal documents, and the names of your spouse, children or other beneficiaries;
  • Browsing activity on our Website, such as pages and events viewed, clickstream data, online portal profile login events, opt-out preferences, and IP addresses (as further detailed in the How we Collect Personal Information section) if it can identify you as an individual;
  • Any other information you provide to us (as further detailed in the How we Collect Personal Information section).

We collect personal information in a variety of ways, including: directly from you, from your employer, former employer and other third parties, and through online technologies (such as when you are interacting with us through our Website).

More specifically, we collect personal information in the following ways:

a. Directly From You

You may provide personal information to us by mail, by email, over the telephone, through our Website or in any other direct manner, for instance when you activate your access to the Website, send or respond to emails, respond to a survey, make an inquiry concerning your pension entitlement, or update your personal information through our Website.

b. From Your Employer, Your Former Employer and Other Third Parties

Your employer provides UPP with your personal information when you first become a member, such as your address, social insurance number, date of birth, and salary information. Thereafter, your employer provides us with information about your salary, contributions, and other applicable member events, such as leaves of absence, termination and retirement dates, and other information that UPP and employers must coordinate and share for the proper administration of employer retiree benefit programs, on a regular basis and as your circumstances change.

When you become a member, you provide your permission for your employer to release your personal information and share it with UPP in order to determine how to administer your pension entitlement and otherwise provide Services to you, and for UPP to obtain such personal information from your employer.

Where you transition between two employers that are both sponsors of UPP, you are also granting your permission for your former employer to release your personal information and share it with UPP in order to evaluate your eligibility for the plan.

We may also receive your personal information from other sources, such as your union, with your consent or when authorized by law.

c. Through Online Technologies

We may collect certain types of information electronically when you interact with our Website or through the use of our or a third party’s technologies, which include cookies, web beacons or analytics services. This information supports the functioning of our Website and helps us understand what actions you take on our Website and whether our Website is working properly.

You may delete or disable certain of these technologies at any time, via your browser or by other means depending on the method of collection used. However, if you do so, you may not be able to use some of the features on our Website. To learn more about the choices available to you, please see Your Choices.

We may use all categories of personal information detailed in section 4 to provide you with Services or to communicate information that is beneficial or otherwise important to you, to manage the plan, to generally improve your experience with us, and as otherwise permitted or required by law.

Learn more about how we use your personal information for: providing services and information, managing our operations and the plan, and conducting research, surveys and data analytics.

We use your personal information for the following purposes:

a. Providing Services and Information

We use your personal information in a variety of ways in order to provide you with Services, including:

  • Determining your eligibility for membership;
  • Verifying your identity and your membership status;
  • Calculating your benefits and options available to you;
  • Responding to your inquiries, providing you with information about your pension entitlement or otherwise communicating with you;
  • Creating, administering, and maintaining your pension entitlement;
  • Actuarial valuations and plan performance; and
  • Fulfilling your requests.

Below are some examples of how we use personal information about you:

Social Insurance Number will be used for the purpose of reporting income and information on pension T-forms to the Canada Revenue Agency.

Salary will be used to determine your average annual salary for pension calculations and to calculate contributions if you choose to buy back service in the plan.

Banking information will be used for direct deposit of monthly pension benefits, or of lump sums where applicable, into your bank account.

Plan membership status may be used in order to fulfil regulatory filing obligations, provide statements, undertake valuations of the plan.

Power of attorney and similar legal instruments will be used to ensure that we have proper authorization to take instructions from and communicate with those that you designate as your authorized representative, legal guardian, appointed substitute decision maker, power of attorney or someone otherwise authorized by law, if necessary to administer the plan.

b. Managing Our Operations

We use your personal information for the purpose of managing our operations, including:

  • Notifying you of changes to your pension entitlement, your online portal profile or our Website services, terms, conditions or policies and to provide you administrative messages, updates, legal notices, technical notices or security alerts;
  • Communicating with you in order to improve data quality (e.g., by requesting missing spousal or beneficiary information);
  • Maintaining our Services;
  • Deploying and managing our information technology applications and systems, including managing our Website; including managing and facilitating the use of our Website, which may include using cookies and other similar technology (as further detailed in the How we Collect Personal Information section);
  • Maintaining the security of our users and our employees;
  • Protecting ourselves and third parties from errors and fraud;
  • Monitoring and investigating incidents and managing claims; and
  • Meeting our contractual, legal and regulatory obligations.

c. Conducting Research, Surveys and Data Analytics

We may use your personal information in order to conduct research, undertake surveys and perform data analytics by analyzing current or previously collected information for the following purposes:

  • Understanding member needs, preferences and behaviour, and customizing how we provide services to UPP members based on their needs and preferences;
  • Managing, improving and developing our operations and our Services;
  • Measuring the effectiveness of our methods for communicating with members, both individually and as a group; and
  • Understanding how members and visitors interact with our Website, and ensuring it works correctly. When possible, we will use your information in an aggregated and/or de-identified format.

We may share your personal information with third parties and service providers (companies operating on our behalf) for the purposes described in this Privacy Statement and in accordance with applicable law. We will not share your personal information other than as provided in this Privacy Statement or as otherwise authorized or required by applicable law. We do not sell your personal information to any organization or person.

Learn more about how we may share personal information: with third parties, with service providers, in the course of a transfer of operations or activities, for other permitted reasons, and with your consent.

a. Third Parties

We may share your personal information with third parties when such disclosures are required in order to ensure proper administration of the plan or provide Services.

Below are some specific examples of how we share personal information about you with third parties:

  • With other plans – your personal information may be shared with other pension plans if you transfer into the UPP plan from another pension plan. In the case of such transfers, you will be asked to authorize the collection, use and disclosure of your personal information by both the exporting plan and UPP, as required, for the purpose of facilitating such transfers.
  • With financial institutions – your personal information may be shared with financial institutions, for example if you decide to transfer a lump sum entitlement into another permitted registered vehicle such as a locked-in RRSP or to commence pension payments.
  • With your legal representative – your personal information may be disclosed to a legal guardian, appointed substitute decision maker, power of attorney or someone otherwise authorized by law, where such disclosure is necessary to administer the plan or your Services.
  • With medical advisors – your personal information may be disclosed to medical advisors to assess your eligibility for disability benefits, and other plan options and features based on your medical condition.
  • With your employer – personal information may be shared with your employer to provide you with Services and for the proper administration of the employer’s retiree benefit programs.
    Although we only share the personal information needed by such third parties to administer the plan or provide Services, once UPP shares such information with such organizations, it is no longer in the custody or under the control of UPP. Those organizations may use that information to contact you or for other purposes in accordance with their own privacy policies. UPP encourages you to review the privacy policies of the relevant organizations.

b. Service Providers

In the course of providing our Services, we may share one or more of the categories of personal information detailed in the section Personal Information we Collect with third party service providers. These service providers help us operate and manage our technology systems, internal procedures, and infrastructure. They provide services to us such as evaluating plan performance, sending emails and postal mail, data hosting, and analytics services. We require these service providers to limit their access to and/or use of personal information to what is required to provide their services, and to adhere to confidentiality obligations as well as security procedures and protections.

Below are some examples of third party service providers with whom we share your personal information, and for what purposes:

  • Actuarial advisors – used to perform a valuation of the plan.
  • Legal advisors – used when legal consultation is required.
  • Mailing services – used to send you statements and other communications about the plan and your benefits.
  • Survey services – used to deliver or administer surveys relating to plan administration activities and to collect survey responses.
  • Hosting and IT service providers – used to host the UPP Website that provides you with online access to your plan benefits and store information, including personal information, on our behalf.
  • Plan administrators – used to assist UPP in the administration of pension entitlements.
  • Payroll providers – used to provide UPP with services related to plan benefit payments and other disbursements.
  • Your employer, acting as our agent – We may engage the member institutions of UPP
    to act as service providers for the collection and processing of certain information for UPP, either temporarily or on an ongoing basis. For example, a university institution currently administering an online portal for plan members to access information and manage benefits may continue to provide this service as our agent.

c. Transfer of Operations or Activities

We may decide to transfer all or part of our operations, assets or activities to a third party, to merge with another entity, or to engage in another form of transaction. If your personal information is required in connection with any such events, we will comply with the legal requirements for the disclosure of personal information and ensure that the handling of your personal information complies with all applicable privacy legislation.

d. Other Permitted Reasons

Applicable laws may permit or require the use, sharing, or disclosure of personal information without consent in specific circumstances (e.g., to satisfy reporting obligations, when investigating and preventing suspected or actual illegal activities, including fraud, or to assist government and law enforcement agencies).

These circumstances include situations when permitted or required by law or when necessary to fulfil UPP’s legal obligations, protect UPP, our employees, those receiving our assistance, or others. For example, we are obliged by tax laws to report certain personal information to the CRA.

Where such circumstances arise, we will not share more personal information than is reasonably required to fulfill that particular purpose.

e. With Your Consent

Other than the purposes listed above, we may, with your implied or express consent, share or disclose your personal information outside of UPP, in accordance with applicable laws.

We take the security of your personal information very seriously and are committed to protecting your privacy by using a combination of administrative, physical, and technical safeguards. While we endeavor to keep your personal information within Canada, your personal information may be stored in foreign jurisdictions, in which case it may be subject to foreign laws. We store your personal information for as long as it is necessary to provide you with our services and for a reasonable time thereafter, or as permitted or required by law.

Learn more about how we protect personal information, where we keep information and cross- border transfers, and how long we retain your information.

a. How we Protect Personal Information

We employ organizational, physical and technological measures to protect the confidentiality of personal information and to safeguard personal information against loss or theft, as well as unauthorized access, disclosure, copying, use or modification, in light of, among other things, the sensitivity of the information and the purposes for which it is to be used. These safeguards also apply when we dispose of or destroy your personal information.

b. Where we Keep Personal Information and Cross-border Transfers

While we endeavor to keep your personal information within Canada, it is not always possible to ensure or require that UPP and its service providers access, store or process your personal information entirely within Canada. We use reasonable safeguards to ensure that we, and our service providers, protect your personal information wherever it is used or stored.

As a result, when your personal information is used or stored in a jurisdiction other than where you are residing, it may be subject to the law of this foreign jurisdiction, including any law permitting or requiring disclosure of the information to the government, government agencies, courts and law enforcement in that jurisdiction.

c. Retention

We will store your personal information for as long as necessary to fulfill the purposes for which it was collected, except where otherwise required or permitted by law. Once no longer required, your personal information will be securely destroyed or anonymized (so the information no longer identifies you).

You have the right to access and correct the personal information we hold about you, subject to limited exceptions that may apply under applicable laws. Upon your request, we will provide you with access to your personal information within a reasonable timeframe, in compliance with applicable laws. It is your responsibility to provide accurate, correct and complete information.

You can request access or rectification by contacting us as described in the “How to Contact Us” section.

Investment Privacy Statement

Effective Date: December 2024

The UPP Privacy Statement for Investment Diligence (“Investment Privacy Statement”) applies to our due diligence and management of the investment relationship activities and describes UPP’s practices with respect to the collection, use and disclosure of Personal Information in the course of those activities, as well as any rights you may have with respect to your Personal Information (as defined in the Definition of “Personal Information” section).

This Investment Privacy Statement applies to the Personal Information collected by UPP for purposes relating to conducting due diligence on prospective investment partners and their personnel, managing the investment relationship, communicating with you about the foregoing or otherwise using your Personal Information in accordance with your consent. This Investment Privacy Statement applies to your interactions with us in relation to UPP, including when you access our website at www.myupp.ca, through third parties or an online account access portal on which this Investment Privacy Statement is posted (collectively, the “Website”).

The types of Personal Information we collect will depend on what you choose to provide us, but typically include:

  • General contact information such as your personal or professional address, email address, telephone number;
  • Age and date of birth;
  • Employment and professional information such as employer organization, professional role, occupational history, business relationship with UPP, work authorization, visa status or other proof of right to work;
  • Information regarding your business interests (e.g. directorships), professional affiliations, or your status as a politically exposed person; and
  • Any other personal information which may be incidentally processed if you contact us and any other information which you provide to the businesses or entities that UPP invests in or may invest in (such information being further described in the privacy notice of the relevant business), etc.

By submitting your information to us; participating in an investment or an investment opportunity with us; or providing information to a third party for due diligence activities, you consent to the collection, use, and disclosure of your Personal Information as described in this Investment Privacy Statement. Wherever possible, UPP strives to obtain your consent prior to conducting any background check processes, board-related activity or investigations.

We rely on this consent as our legal basis to process your Personal Information, but where we process Personal Information about you that we have not sourced from you we may also rely on the following legal bases:

  • Compliance with legal obligations, where use is necessary to comply with our legal or regulatory obligations (e.g., employment law, health and safety legislation, immigration law);
  • In contemplation of entering into a business transaction with your organization, provided we have entered into an agreement to limit the use of and protect your Personal Information; and
  • Legitimate interests, where use is necessary for our legitimate interests and any potential adverse effects on you are not outweighed by our legitimate interests, including UPP’s legitimate interests in running the UPP business by considering or entering into certain transactions.

In some circumstances, we’re permitted by law to use and disclose personal information about you without your consent. For example, your personal information may be used or disclosed if required by a court order. We will generally obtain consent when we want to use your Personal Information for a new purpose or for a purpose other than those stated at the time of collection in this Investment Privacy Statement.

We collect Personal Information in a variety of ways, including the following:

Directly From You

You may provide Personal Information to us by mail, by email, through video conference, over the telephone, through our Website or in any other direct manner, for instance when you send or respond to emails, or make an inquiry concerning the investment or investment opportunity.

Through Third-Party Sources

UPP may collect Personal Information about you from other sources, such as publicly-available information or Personal Information about you provided by third parties including the partners, affiliates and third party service providers. This may include background check firms, online directories, or database services where you have previously provided your Personal Information.

Through Online Technologies

We may collect certain types of information, including some Personal Information, electronically when you interact with our Website or through the use of our or a third party’s technologies.

We may collect, use, and disclose your Personal Information in the course of conducting due diligence on you or your organization when we are contemplating entering into an investment relationship.

This may include:

  • performing conflicts checks;
  • verifying the identity of individuals;
  • undertaking due diligence and performing background checks;
  • conducting anti-money laundering checks;
  • evaluating potential transactions;
  • maintaining records of investments;
  • trade and transaction reporting;
  • administering transactions which are entered into;
  • statistical analysis and market research;
  • maintaining records of investments;
  • complying with our regulatory and legal obligations, including assessing and managing risk;
  • identifying and preventing fraud and other unlawful activity;
  • safeguarding our legal rights and interests;
  • seeking and receiving advice from our professional advisors, including accountants, lawyers and other consultants;
  • organizing and holding meetings and events;
  • general business marketing, including reporting on macro trends and other business and economic insights; and
  • sending you periodic updates about UPP’s business, our investment relationship, events, investment management, presentations and opportunities; and
  • any other purpose presented to you at the time of our collection of your Personal Information.

Improving our Processes

In certain circumstances, we may also use your information to:

  • Manage accommodation requests you submit;
  • Meet our legal obligations and comply with internal UPP policies;
  • Protect us and our stakeholders, including our property, rights, and legal interests; and
  • Improving UPP’s due diligence processes.

AI Assisted Diligence

From time to time, UPP or our service providers may use AI-based tools, including automated decision-making, to help us streamline and enhance our diligence processes. For example, these tools may help by highlighting certain investment opportunities which match UPP’s needs, values and objectives.

These tools may also help inform our diligence on individuals by assisting with background checks. These tools operate based on substantive content included in available Personal Information about an investment opportunity on the internet or other databases. UPP is committed to the ethical use of your Personal Information and has robust oversight for the use and development of these tools. 

UPP evaluates all AI tools for their appropriateness, including by considering the sensitivity of the Personal Information processed by these tools, the impact on the rights and obligations of individuals, and the potential for bias in the tools if they are being used to assist in decision making. Our use of AI does not replace human decision-making.

Conducting Research, Surveys and Data Analytics

We may use your Personal Information in order to conduct research, undertake surveys and perform data analytics by analyzing current or previously collected information for the following purposes:

  • Understanding UPP’s investment needs and diligence performance;
  • Managing, improving and developing our operations;
  • Measuring the effectiveness of our methods of our due diligence procedures; and
  • Understanding how individuals interact with our or our third party’s website(s) and ensuring they work correctly.

When possible and appropriate, we will use your Personal Information in an aggregated, anonymized or de-identified format for these purposes.

We may share your Personal Information with third parties and service providers (companies operating on our behalf) for the purposes described in this Investment Privacy Statement and in accordance with applicable law. We will not share your Personal Information other than as provided in this Investment Privacy Statement or as otherwise authorized or required by applicable law. We do not sell your Personal Information to any organization or person.

Third Parties

Below are some specific examples of how we share Personal Information about you with third parties:

  • With our portfolio, affiliate, and subsidiary companies;

  • With service providers who assist UPP with our diligence processes; or

  • otherwise authorized or required by law.

When sharing information with third parties, UPP takes appropriate contractual and operational steps to ensure the Personal Information is protected and used only in accordance with the purposes set out in this Investment Privacy Statement.

Service Providers

UPP may share one or more of the categories of Personal Information detailed in the section “Personal Information we Collect” with third party service providers as part of UPP’s due diligence activities. These service providers help us operate and manage our technology systems, and assist UPP in conducting its diligence activities.

Below are some examples of third-parties with whom we share your Personal Information, and for what purposes:

  • Entities or individuals that are conducting our background and reference checks;

  • Third-party diligence technology platforms;

  • Governmental, regulatory, or law enforcement authorities, in response to a legitimate request for information; or

  • Any third party to the extent we deem necessary to meet our legal obligations, or protect us, our property, rights, or interests.

Some parties that we share your Personal Information with may be located, or may store Personal Information, outside of Ontario, Canada. Personal Information stored in other countries may be subject to the laws of those countries.

Whenever Personal Information is transferred to a third party, we impose contractual obligations on the service provider to protect that information and to limit its use only to purposes required for the service. We perform privacy and security due diligence in respect of all third parties that are engaged to provide services to us. The purpose of this exercise is to determine whether a prospective third party service provider maintains the administrative, technical and physical measures to protect your Personal Information.

With Your Consent

Other than the purposes listed above, we may, with your implied or express consent, share or disclose your Personal Information outside of UPP, in accordance with applicable laws.

We use safeguards designed to protect your Personal Information against loss or theft, as well as unauthorized access, disclosure, copying, use or modification. Below are some examples of how we protect your Personal Information:

  • Administrative –access to Personal Information is limited to UPP employees, contractors, or other parties on a “need to know” basis as required for their business functions, and employees are trained on our privacy practices.
  • Technical –industry standard firewalls, data encryption, and information access authorization controls are used to prevent unauthorized access to information.
  • Physical –production of hard copy documents containing Personal Information is discouraged and limited to legitimate business functions.

Safeguards are periodically reviewed to ensure they continue to be appropriate in protecting your Personal Information.

We’ll never send you unsolicited email requests for Personal Information. Should you ever receive a suspicious email that looks to be from us, don’t click on it and contact us immediately at [email protected].

Third parties that you connect with directly through hyperlinks or other information provided on our websites may link and combine information about you to other Personal Information they may have collected on you, to achieve their own goals and purposes. We do not collect, use or disclose such information, which is subject to the privacy policies of the third-party organization. UPP encourages you to review the privacy policies of such organizations as well.

We want you to clearly understand your choices and make informed decisions about your privacy and communications options. There are several options available for you to manage your preferences, including, for example: managing your preferences within your online portal profile, where this functionality is provided, contacting us directly, changing your browser settings and, where available, using third party functionality.

Changing Browser Settings

Web browsers generally allow control of cookies through the browser settings. You can, for example, disable cookies, or set your browser to notify you each time you receive a cookie, allowing you to decide if you want to accept it or not. Please note that if you do not accept a particular cookie, certain elements or features of our Website may not function correctly or completely.

Using Third Party Functionality

We may use the services of third parties that provide certain technologies to analyze your browsing behaviour as you visit our Website, such as Google Analytics. Learn about how Google uses your information. You can manage your privacy preferences with respect to such third parties by using functionality provided within their platforms, or by disabling cookies when you visit our Website. Please note that if you disable, block or delete some of these technologies, such as cookies, certain elements or features of our Website may not function correctly or completely.

You have the right to access and correct the Personal Information we hold about you, subject to limited exceptions that may apply under applicable laws. Upon your request, we will provide you with access to your Personal Information within a reasonable timeframe, in compliance with applicable laws. It is your responsibility to provide accurate, correct and complete information.

You can request access or rectification by contacting us as described in the “How to Contact Us” section.

We will retain your Personal Information for a reasonable period after our relationship with you or your organization, including as required by law

We retain this information for legal and practical reasons. This includes retaining in case of a legal challenge, to help us better understand, analyze and improve our due diligence process, and other purposes identified in this Investment Privacy Statement.  

Under some circumstances we may anonymize your Personal Information so that it can no longer be associated with you. We reserve the right to use such anonymous data for any legitimate business purpose and as permitted by law without further notice to you or your consent.

You can request access or rectification by contacting us as described in the “How to Contact Us” section.

Job Applicant Privacy Statement

Effective Date: December 2024

The UPP Privacy Statement for Job Applicants (“Job Applicant Privacy Statement”) applies to our recruitment and hiring activities and describes UPP’s practices with respect to the collection, use and disclosure of Personal Information in the course of those activities, as well as any rights you may have with respect to your Personal Information (as defined in the Definition of “Personal Information” section).

This Job Applicant Privacy Statement applies to the Personal Information collected by UPP for purposes relating to considering or recruiting you for current and potential employment opportunities at UPP, including assessing your skills, qualifications, and interests for the purposes of determining your suitability for a position, communicating with you about the foregoing, or otherwise using your Personal Information in accordance with your consent. This Job Applicant Privacy Statement applies to your interactions with us in relation to UPP during the recruitment process, including when you access our website at www.myupp.ca, through third parties (e.g. LinkedIn) or an online account access portal on which this Job Applicant Privacy Statement is posted (collectively, the “Website”).

The types of Personal Information we collect will depend on what you choose to provide us, but typically include:

  • The contact information you provide or make available, your status as a candidate and the status of your application, and the role(s) you may be interested in or suited for;
  • Your skills, experiences, certifications, work and education history, and any similar content usually found in an application package or resume; and
  • Data including demographic and accommodation information, as further detailed in the “Equity, Diversity, and Inclusion” section, below.

In, providing an application to UPP for employment, sending or responding to communications regarding your application, or otherwise submitting information to UPP in connection with such application, you are providing UPP with your consent to the collection, use and disclosure of Personal Information as set out in this Job Applicant Privacy Statement.

We will generally obtain consent when we want to use your Personal Information for a new purpose or for a purpose other than those stated at the time of collection in this Job Applicant Privacy Statement.

We collect Personal Information in a variety of ways, including: directly from you, from your former employer and other third parties (e.g. background check services), and through online technologies.

More specifically, we collect Personal Information in the following ways:

Directly From You

You may provide Personal Information to us by mail, by email, through job application, over the telephone, through our Website or in any other direct manner, for instance when you send or respond to emails, or make an inquiry concerning your application.

As Part of the Interview Process

When interviewing for a position with UPP, you may provide information to UPP regarding your job experience, qualifications, or other relevant matters. This information may be recorded by UPP and retained as part of your application package.

Through Recruitment Firms

UPP may use third party recruitment agencies to find suitable candidates for job vacancies. As part of this process, recruiters may gather Personal Information about you that you have posted publicly (e.g. LinkedIn) or may approach you directly. The Personal Information gathered by the recruiter may then be provided by UPP when UPP is considering whether to interview you as a job candidate.

Through Online Technologies

We may collect certain types of information, including some Personal Information, electronically when you interact with our Website or through the use of our or a third party’s technologies (e.g. Ceridian Dayforce, your institution’s career portal, through recruiting organizations to which you’ve provided your information, or LinkedIn).

Recruitment and Candidate Evaluation

We collect and use Personal Information for the purposes of considering or recruiting you for current and potential employment opportunities at UPP, including assessing your skills, qualifications, and interests for the purposes of determining your suitability for a position. This includes communicating with you about positions that are available, your status as a candidate, or the hiring process.

Your Personal Information will be included in your employment records if you become our employee.

As part of considering you for current employment opportunities, we will use your information to administer recruitment processes, communicate with you, confirm your eligibility to work, and conduct background and reference checks. If you have opted to subscribe to UPP’s hiring updates, you can always choose to unsubscribe or opt-out from those communications. 

Equity, Diversity, and Inclusion

If you choose to provide us data including demographic and accommodation information, such as your gender identity, nationality, indigenous status, pronouns, sex, race, ethnicity, disabilities, sexual orientation, or other similar information, we may use such information for the purpose of supporting our equity and diversity initiatives and similar special programs, including measuring our progress in achieving our diversity, equity and inclusion objectives.

Providing this information is completely voluntary, and will always be used in a manner consistent with applicable law.

AI Assisted Recruitment

From time to time, UPP or our service providers may use Artificial Intelligence (“AI”) based tools to help us streamline and enhance our talent management practices and processes. For example, these tools may help by highlighting certain candidates or positions based on the perceived match between them and UPP’s needs and objectives.

These tools may also help inform our search for candidates. These tools operate based on substantive content included in resumes or other available Personal Information about a candidate. UPP is committed to the ethical use of your Personal Information and has robust oversight for the use and development of these tools. 

UPP evaluates all AI tools for their appropriateness, including by considering the sensitivity of the Personal Information processed by these tools, the impact on the rights and obligations of individuals, and the potential for bias in the tools if they are being used to assist in decision making. Our use of AI does not replace human decision-making, nor does it filter out any candidate or potential opportunity.

Conducting Research, Process Improvements, and Surveys and Data Analytics

We may use your Personal Information to conduct research, undertake surveys and perform data analytics by analyzing current or previously collected information for the following purposes:

  • Manage accommodation requests you submit;
  • Conduct analytics to identify means of improving our talent management practices, processes and tools (including AI-based tools), address skill gaps, and effectively build our talent pool;
  • Managing, improving and developing our recruitment operations, including to support our equity and diversity initiatives and similar special programs;
  • Meet our legal obligations and comply with internal UPP policies;
  • Protect us and our stakeholders, including our property, rights, and legal interests;
  • Measuring the effectiveness of our methods of our recruitment procedures; and
  • Understanding how applicants interact with our or our third party’s website(s) and ensuring it works correctly.

When possible and appropriate, we will use your Personal Information in an aggregated, de-identified, or anonymized format.

We may share your Personal Information with third parties and service providers (companies operating on our behalf) for the purposes described in this Job Applicant Privacy Statement and in accordance with applicable law. We will not share your Personal Information other than as provided in this Job Applicant Privacy Statement or as otherwise authorized or required by applicable law. We do not sell your Personal Information to any organization or person.

Third Parties

Below are some specific examples of how we share Personal Information about you with third parties:

  • General information about your employment to your institution (e.g. your university) as part of their career-office activities;
  • To external search firms which you have worked with as part of your application;
  • governmental, regulatory, or law enforcement authorities, in response to a legitimate request for information; and
  • otherwise authorized or required by law.

When sharing information with third parties, UPP takes appropriate contractual and operational steps to ensure the Personal Information is protected and used only in accordance with the purposes set out in this Job Applicant Privacy Statement.

Service Providers

UPP may share one or more of the categories of Personal Information detailed in the section “Personal Information we Collect” with third party service providers as part of UPP’s recruitment activities. These service providers help us operate and manage our technology systems, and assist UPP in finding suitable candidates.

Below are some examples of third-parties with whom we share your Personal Information, and for what purposes:

  • Entities or individuals that are conducting your background and reference checks;
  • Certain technology sub-processors to facilitate the application process (e.g. Docusign);
  • LinkedIn or other platforms when we identify you as a candidate or you apply for a role with us through the platform; and
  • Any third party to the extent we deem necessary to meet our legal obligations, or protect us, our property, rights, or interests.

Some parties that we share your Personal Information with may be located, or may store Personal Information, outside of Canada. Personal Information stored in other countries may be subject to the laws of those countries.

We perform privacy and security due diligence in respect of all third parties that are engaged to provide services to us. The purpose of this exercise is to determine whether a prospective third-party service provider maintains the administrative, technical and physical measures to protect your Personal Information.

With Your Consent

Other than the purposes listed above, we may, with your implied or express consent, share or disclose your Personal Information outside of UPP, in accordance with applicable laws.

We will generally obtain consent when we want to use your Personal Information for a new purpose or for a purpose other than those stated at the time of collection in this Job Applicant Privacy Statement.

We use safeguards designed to protect your Personal Information against loss or theft, as well as unauthorized access, disclosure, copying, use or modification. Below are some examples of how we protect your Personal Information:

  • Administrative –access to Personal Information is limited to UPP employees, contractors, or other parties on a “need to know” basis as required for their business functions, and employees are trained on our privacy practices.
  • Technical –industry standard firewalls, data encryption, multi-factor authentication, and information access authorization controls are used to prevent unauthorized access to information.
  • Physical –production of hard copy documents containing Personal Information is discouraged and limited to legitimate business functions. Any hard copy documents containing Personal Information are expressly labeled as containing Personal Information and stored in locked filing cabinets that have restricted access. Documents are shredded or otherwise destroyed when no longer needed.

Safeguards are periodically reviewed to ensure they continue to be appropriate in protecting your Personal Information.

We’ll never send you unsolicited email requests for Personal Information. Should you ever receive a suspicious email that looks to be from us, don’t click on it and contact us immediately at [email protected].

Third parties that you connect with directly through hyperlinks or other information provided on our Website may link and combine information about you to other Personal Information they may have collected on you, to achieve their own goals and purposes. We do not collect, use or disclose such information, which is subject to the privacy policies of the third-party organization. UPP encourages you to review the privacy policies of such organizations as well.

You may opt out of receiving communications by contacting us directly using the contact details provided in the section How to Contact Us below, or by using the unsubscribe mechanism provided if it is an electronic communication, or by letting the individual at UPP with whom you’re corresponding know you’d like to opt-out.  

Please be advised that it may take some time for all of our records to reflect changes in your preferences (e.g., if you request that you not receive non- mandatory electronic communications from us, your preference may not be captured for a newsletter distribution already in progress).

Changing Browser Settings

Web browsers generally allow control of cookies through the browser settings. You can, for example, disable cookies, or set your browser to notify you each time you receive a cookie, allowing you to decide if you want to accept it or not. Please note that if you do not accept a particular cookie, certain elements or features of our Website may not function correctly or completely.

Using Third Party Functionality

We may use the services of third parties that provide certain technologies to analyze your browsing behaviour as you visit our Website, such as Google Analytics. Learn about how Google uses your information. You can manage your privacy preferences with respect to such third parties by usig functionality provided within their platforms, or by disabling cookies when you visit our Website. Please note that if you disable, block or delete some of these technologies, such as cookies, certain elements or features of our Website may not function correctly or completely.

You have the right to access and correct the Personal Information we hold about you, subject to limited exceptions that may apply under applicable laws. Upon your request, we will provide you with access to your Personal Information within a reasonable timeframe, in compliance with applicable laws. It is your responsibility to provide accurate, correct and complete information.

You can request access or rectification by contacting us as described in the “How to Contact Us” section.

We will generally obtain consent when we want to use your Personal Information for a new purpose or for a purpose other than those stated at the time of collection in this Job Applicant Privacy Statement.

We will retain your Personal Information for a reasonable period after our relationship with you as a candidate, including as required by the Employment Standards Act. We retain this information for legal and practical reasons, including in case of a legal challenge and to help us better understand, analyze and improve our recruitment process, and other purposes identified in this Job Applicant Privacy Statement.  

If you’re offered and accept employment with us, some of the Personal Information collected during recruitment process will become part of your employment record. In these cases, we’ll retain Personal Information as necessary for as long as you’re an employee and for a reasonable period thereafter.

Under some circumstances we may anonymize your Personal Information so that it can no longer be associated with you. We reserve the right to use such anonymous data for any legitimate business purpose and as permitted by law without further notice to you or your consent.

Website Privacy Statement

Effective Date: December 2024

This Website Privacy Statement applies to the collection, use, storage, and disclosure of Personal Information by and for the website visitors accessing our website at www.myupp.ca (the “Website”).

“Personal Information” is any information about an identifiable individual. This may include, for example, your name, address, phone number, email address, age, gender identity, opinions and preferences, as well as Internet Protocol (“IP”) address. It may also include more technical information, but only when this information can identify you as an individual. For more information see the “Personal Information we Collect” section.

By using the Website, you agree to the collection, use, and disclosure of your Personal Information as described here. Our legal basis for processing your information is typically your consent, though we may also rely on compliance with legal obligations.

You can withdraw your consent at any time by not using the Website, or by contacting UPP as set out below. This might affect the level of service we provide on the Website. You can also block web technologies on our site, but this may limit Website functionality. See Cookies below for more information. Erasure requests of your data can be made by phone or email.

The type of Personal Information we collect as part of your access to the Website may include:

  • Personal Information you choose to provide us in submitting any forms on the Website;
  • Technical information, including your IP address, your device, your browser, operating system, and the website URL referring you to our Website or how you otherwise arrived on the Website;
  • Information inferred through your browsing behaviour using Google Analytics, which may include inferences about your age, gender, interests, your geographic location, language(s) spoken;
  • Real time information about how users are interacting with our Website; and
  • Behavioural information about your interactions with the Website, including clicks, downloads, and form submissions.

We may collect information electronically when you interact with our Website using cookies, web beacons, or analytics services including Google Analytics. This information helps our Website function and lets us understand your actions and whether the Website is working properly.

We may also collect information from you when you contact us through the Website. However, any information you provide through the Member Portal are governed by the Member Privacy Statement.

When you access the Website, it collects data on the pages you view, the links you click, and other actions you perform.

You can delete or disable these technologies via your browser or other methods, but doing so may limit some Website features. For more details, refer to Your Choices.

We use all categories of Personal Information described in the “Personal Information we Collect” section to provide services, share important information, manage plans, and improve your experience, as permitted by law.

We may also use your Personal Information for research, surveys, and data analysis to:

  • Understand member needs and preferences;
  • Customize our services for UPP members;
  • Improve and develop our operations and services;
  • Measure the effectiveness of our communication methods;
  • Understand how users interact with our website; and
  • Whenever possible, we will aggregate or de-identify your information.

We may also collect information from you when you contact us through the Website. However, any information you provide through the Member Portal are governed by the Member Privacy Statement.

When you access the Website, it collects data on the pages you view, the links you click, and other actions you perform.

You can delete or disable these technologies via your browser or other methods, but doing so may limit some Website features. For more details, refer to the Your Choices section.

(a)  With Service Providers

We may share your Personal Information with third parties and service providers (companies operating on our behalf) for the purposes described in this Website Privacy Statement and in accordance with applicable law. We do not sell your Personal Information to any organization or person.

In the course of providing our Services, we may share one or more of the categories of Personal Information detailed in the “Personal Information we Collect” section with third party service providers. These service providers help us operate and manage our Website. This can occur where UPP engages those service providers to manage the website on our behalf, or where UPP uses software tools from those service providers to manage the Website directly.

We require these service providers to limit their access to and/or use of Personal Information to what is required to provide their services, and to adhere to confidentiality obligations as well as security procedures and protections.

Below are some examples of third-party service providers with whom we may share your Personal Information, and for what purposes:

  • Hosting and IT service providers – used to host the UPP Website that provides you with online access to your plan benefits and store information, including Personal Information, on our

  • Website Managers – service providers that help update or manage the Website.

  • UPP’s Auditors or Professional Advisors – to ensure, for example, that the use of Personal Information adheres to what is set out in this Website Privacy Statement, or to obtain legal or operational advice.

(b)  Other Permitted Reasons

Applicable law may permit or require the use, sharing, or disclosure of Personal Information without consent in specific circumstances (e.g., to satisfy reporting obligations, when investigating and preventing suspected or actual illegal activities, including fraud, or to assist government and law enforcement agencies).

Where such circumstances arise, we will not share more Personal Information than is reasonably required to fulfill that particular purpose.

(c)  With Your Consent

Other than the purposes listed above, we may, with your implied or express consent, share or disclose your Personal Information outside of UPP, in accordance with applicable laws.

Third parties that you connect with directly through hyperlinks or other information provided on our Website may link and combine information about you to other Personal Information they may have collected on you, to achieve their own goals and purposes. We do not collect, use or disclose such information, which is subject to the privacy policies of the third-party organization. UPP encourages you to review the privacy policies of such organizations as well.

UPP’s website uses cookies and similar technologies to analyze performance and functionality. This includes pages visited, browser type, encryption level, and visitors’ IP addresses. UPP also collects information on online activities and preferences. Examples include:

  • Web pages visited;
  • Length of visits;
  • Successful downloads of any resources;
  • How you interact with our website functions and features;
  • How you arrived on the Website;
  • Geographic and location information;
  • Your device information;
  • The time and date of your visits to the Website; and
  • Error and performance logging.

This information is utilized to assist UPP in understanding visitor interests, preferences, and needs, thereby providing a customized online experience and introducing new tools and website functions. Although UPP does not sell your Personal Information to other organizations or individuals, certain analytics tools may monitor user internet behavior, which could lead to internet-based advertising. 

You can block, delete, or disable these technologies if your device allows. Check your browser settings to manage cookies. For instance, you can opt out of tracking by Google Analytics or Adobe Analytics.

Blocking cookies or similar technologies may limit access to some site features, services, applications, or tools.

We want you to clearly understand your choices and make informed decisions about your privacy and communications options. There are several options available for you to manage your preferences, including, for example: managing your preferences within your online portal profile, where this functionality is provided; contacting us directly; changing your browser settings and, where available, using third party functionality to block tracking or other functionality.

(a)  Changing Browser Settings

Web browsers generally allow control of cookies through the browser settings. You can, for example, disable cookies, or set your browser to notify you each time you receive a cookie, allowing you to decide if you want to accept it or not. Please note that if you do not accept a particular cookie, certain elements or features of our Website may not function correctly or completely.

(b)  Using Third Party Functionality

We may use the services of third parties that provide certain technologies to analyze your browsing behaviour as you visit our Website, such as our web-host provider and Google Analytics. Learn about how Google uses your information and how Google safeguards your information. You can manage your privacy preferences with respect to such third parties by using functionality provided within their platforms, or by disabling cookies when you visit our Website. Please note that if you disable, block or delete some of these technologies, such as cookies, certain elements or features of our Website may not function correctly or completely.

We take the security of your Personal Information very seriously and are committed to protecting your privacy by using a combination of administrative, physical, and technical safeguards. While we endeavor to keep your Personal Information within Canada, your Personal Information may be stored in foreign jurisdictions, in which case it may be subject to foreign laws. We store your Personal Information for as long as it is necessary to provide you with our services and for a reasonable time thereafter, or as permitted or required by law. Where your Personal Information is stored by a third-party acting on our behalf, we take appropriate contractual measures to protect and limit the use of that information.

Learn more about how we protect Personal Information, where we keep information and cross- border transfers, and how long we retain your information.

(a)  How we Protect Personal Information

We employ organizational, physical and technological measures to protect the confidentiality of Personal Information and to safeguard Personal Information against loss or theft, as well as unauthorized access, disclosure, copying, use or modification, in light of, among other things, the sensitivity of the information and the purposes for which it is to be used. These safeguards also apply when we dispose of or destroy your Personal Information.

(b)  Where we Keep Personal Information and Cross-border Transfers

It is not always possible to ensure or require that UPP and its service providers access, store or process your Personal Information entirely within Canada. We use reasonable safeguards to ensure that we, and our service providers, protect your Personal Information wherever it is used or stored.

As a result, when your Personal Information is used or stored in a jurisdiction other than where you are residing, it may be subject to the law of this foreign jurisdiction, including any law permitting or requiring disclosure of the information to the government, government agencies, courts and law enforcement in that jurisdiction.

(c)  Retention

We will store your Personal Information for as long as necessary to fulfill the purposes for which it was collected, except where otherwise required or permitted by law. Once no longer required, the Personal Information described in this Website Privacy Statement will be securely destroyed.

You have the right to access and correct the Personal Information we hold about you, subject to limited exceptions that may apply under applicable laws. Upon your request, and where technically feasible, we will provide you with access to your Personal Information within a reasonable timeframe, in compliance with applicable laws. It is your responsibility to provide accurate, correct and complete information.

You can request access or rectification by contacting us as described in the “How to Contact Us” section.

How to Contact Us

If you have any questions or concerns about how we handle your Personal Information, please contact us as indicated below. If your use of one of our Services involves a third party, the third party may hold your Personal Information. In this case, we will direct you to the appropriate party so that you may make enquiries as to that party’s privacy policies and practices.

Toll-free number: 1-866-781-5012

By emailing: [email protected]

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