TEAMSTERS’ NATIONAL BENEFIT PLAN
TEAMSTERS’ NATIONAL PENSION PLAN
The Board of Trustees of each of the Teamsters’ National Benefit Plan (“Benefit Plan”) and of the Teamsters’ National Pension Plan (“Pension Plan” and together the “Plans”) and the Plans’ employees are committed to providing our Members with exceptional service. Providing benefits to our Plans’ Members requires the collection, use and disclosure of some personal information and protecting that personal information is one of our highest priorities.
Contact Information – means information that would enable an individual to be contacted at a place of business and includes their name, position name or title, business telephone number, business address, business email or business fax numbers. Contact information is not covered by this Policy.
Personal Information – means information about an identifiable individual including, name, age, home address and phone number, social insurance number and medical information. Personal information does not include Contact Information.
Privacy Law means the Personal Information Protection Act (British Columbia) (“PIPA”), the Federal, Consumer Protection Privacy Act (CPPA), either PIPA or CPPA as is applicable in the circumstances or any other applicable personal information protection legislation.
Privacy Officer means the individual designated by each of the Plans to be responsible for this Policy and the Plans’ respective compliance with Privacy Law.
Scope of the Policy
This Policy applies to each of the Plans and to the Plans’ employees.
The Plans will comply with Privacy Law in the course of collecting, using and disclosing Personal Information. This Policy is intended to explain, in the context of how the Plans collect, use and disclose Personal Information, how the Plans comply with Privacy Law. However, this Policy is only intended to be consistent with the Privacy Law and is not intended to expand the Plans’ legal obligations in respect of the collection, use and disclosure of Personal Information beyond that which is required by Privacy Law.
The Trustees have sole discretion to interpret and apply this Policy and may amend its terms at any time.
In no event will this Policy affect or alter the interpretation of either of the Plans. In the event of a conflict between any provision of this Policy and the text of a Plan, the text of the Plan will prevail.
To the extent that the Personal Information is required to administer the Pension Plan, nothing in this Policy detracts from the Pension Benefits Standards Act (British Columbia) (or similar provision in the PBSA or other applicable statute), which places the onus on a person seeking an entitlement under the Plan to prove his or her entitlement to Board’s satisfaction.
The Pension Plan has a Record Retention Policy which sets out how Pension Plan records will be retained, which records include Pension Plan records that contain Personal Information. To the extent that this Policy conflicts with the Record Retention Policy, the Record Retention Policy will prevail.
Part 1 – Collecting Personal Information
1.1 The Plans collect Personal Information for a wide variety of purposes related to the administration of the Plans including:
- Determining or confirming an individual’s identity;
- Determining eligibility for participation in a Plan;
- Determining eligibility for benefits from a Plan;
- Determining an individual’s employment history including whether the individuals has terminated employment;
- Ensuring compliance with statutory and regulatory requirements that apply to the Plans;
- Communicating with the members of the Plans;
- Processing payments from the Plans.
1.2 The Plans will limit their collection of Personal Information to that which is reasonably necessary to administer the Plans.
Part 2 – Consent
2.1 The Plans will strive to obtain and rely on an individual’s express consent in order to collect, use and disclose his or her Personal Information. However, the Plans may also rely upon implied or deemed consent when permitted by Privacy Law.
2.2 The Plans will strive to obtain an individual’s consent from him or her directly, but there will be circumstances (such as where a beneficiary’s Personal Information is required) where the Plans will collect Personal Information from someone other than the individual and implied consent will be relied upon. There may also be situations where an individual’s authorized representative can consent on behalf of the individual.
2.3 The Plans are not required to seek consent to collect, use or disclose Personal Information if Privacy Law allows the collection, use or disclosure without consent. Examples where consent is not required include:
- When the collection, use or disclosure is to collect a debt owed to the Plans;
- When the collection, use or disclosure is reasonable for purposes related to an investigation and seeking consent would compromise that investigation;
- When the collection, use or disclosure is to comply with a subpoena, warrant or court order;
- When the collection, use or disclosure is to a law enforcement agency concerning an offence.
2.4 The Plans may use any other method of obtaining consent permitted by Privacy Law.
2.5 An individual can provide express consent orally or in writing, and written consent can be provided using forms approved by the Plans or electronically if appropriate in the circumstances.
Part 3 – Using and Disclosing Personal Information
3.1 The Plans will only use or disclose Personal Information to fulfill the purposes for which it was collected, and for any other purpose permitted by Privacy Law.
3.2 The Plans will not sell Member lists or Personal Information to other parties
Part 4 – Retaining Personal Information
4.1 If the Plans use Personal Information to make a decision about the individual to whom the Personal Information relates, the Plans will retain that Personal Information for a least one year so that the individual has a reasonable opportunity to request access to it.
4.2 The Plans will retain Personal Information until there is no longer a legal or business reason to retain the Personal Information. The retention period for records maintained in respect of the Pension Plan is set out in the Pension Plan’s Record Retention Policy.
Part 5 – Ensuring Accuracy of Personal Information
5.1 The Plans will make reasonable efforts to ensure that Personal Information is accurate and complete where it may be used to make a decision or disclosed to another organization.
5.2 Individuals may request correction to their Personal Information. A request to correct Personal Information is to be made in writing and is to provide sufficient detail to identify the Personal Information and the correction being sought.
5.3 If the Personal Information is demonstrated to be inaccurate or incomplete, the Plans will correct the information as required and send the corrected information to any organization to which we disclosed the Personal Information in the previous year. If the correction is not made, the Plans will note the request for a correction in the file.
Part 6 – Securing Personal Information
6.1 The Plans will maintain reasonable security arrangements to protect Personal Information from unauthorized access, collection, use, disclosure, copying, modification or disposal or similar risks.
6.2 The following security measures will be followed to protect Personal Information:
- Securing offices where personal information is held
- The use of user ID passwords
- The use of firewalls
- Restricting employee access to personal information as appropriate
6.3 The Plans will use appropriate security measures when destroying Personal Information such as shredding documents.
6.4 The Plans will continually review and update their security policies and controls as technology changes to ensure that its security obligations are met.
Part 7 – Online Privacy
7.1 This Policy outlines what individuals can expect when visiting the website maintained for the Plans (the “Website”).
7.2 We will not sell, rent or share any Personal Information provided to the Plans through the Website without consent of the individual to whom the Personal Information relates.
7.3 The Plans automatically capture your IP address, domain name, the referring Web page from which you enter our site, the pages you visit on our site and the amount of time you spend on the Website. Additional Personal Information may be provided through the Website if you choose to provide that additional Personal Information.
7.5 If an individual visits the Website the Plans may place a cookie on the individual’s computer that will allow the Plans to customize and enhance user experience and improve the services we offer at the Website, or to report Website activity. Our cookies will never be used to track user activity on any third party websites or to send spam (e.g. unsolicited) e-mail.
7.6 Use of the Website signals the user’s acceptance of the Terms and Conditions of Use found on the Website.
Part 8 – Individual Access to Personal Information
8.1 Individuals have a right to access their Personal Information as permitted by Privacy Law.
8.2 A request to access Personal Information must be made in writing and provide sufficient detail to identify the Personal Information being sought. A request to access Personal Information should be forwarded to the Privacy Officer.
8.3 Upon request, the Plans will also advise an individual as to how his or her Personal Information was used and to whom it was disclosed.
8.4 The Plans will provide the Personal Information requested in accordance with the Privacy Law.
8.5 A minimal fee may be charged for providing access to Personal Information to the extent permitted by Privacy Law. Where a fee may apply, the Plans will inform the individual of the cost and request further direction from the individual.
8.6 If a request is refused in full or in part, the Plans will notify the individual in writing, providing the reasons for refusal and the recourse available to the Member.
Part 9 – Question and Complaints: The Role of the Privacy Officer
9.1 The Privacy Officer is responsible for ensuring the Plans comply with this Policy and Privacy Law.
9.2 Any complaints, concerns or questions regarding the Plans or with this Policy should be sent in writing to the Privacy Officer.
Contact Information for the Plans Privacy Officer:
Teamsters’ National Benefit/Pension Plan
Plan Privacy Officer – Kelly Nicholson
1610 Kebet Way
Port Coquitlam, BC V3C 5W9
Revised October 2019