OMERS Commitment to your Privacy

In the course of our pension operations, OMERS collects a wide range of personal data about you and your beneficiaries. Examples of personal data that OMERS collects includes:

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

• date of birth and age

• gender

• employment history and earnings

• Social Insurance Number

• banking information

• marital status

• power of attorney

• health related information

• union or association affiliation

• interactions with our contact centre

• any other information you or related parties provide to us

When you use our websites and online services, such as myOMERS, we and our service providers automatically collect information such as the type of web browser you use; the type of device you use; your operating system and version; your IP address; your location; the pages or features you view or use; referring and exit pages; the date and time of your visit; the number of clicks to, from, within the website; the duration of your visits; detailed data about your interaction with the application; and any other information that may be passed by default from your browser to us in the normal course.

We use personal data about you, your beneficiaries, survivors and any other related parties for the purpose of administering the OMERS Pension Plan, for your individual member purposes and for broader Plan purposes. Some examples of how we use personal data include:

• Establishing and maintaining your OMERS membership

• Administering your pension benefit, including processing changes in your status, such as entitlement to disability benefits

• Paying your pensions and other benefits to you, you spouse, survivors, and others

• Providing you with education and information about the Plan and your retirement

• Communicating with your employer(s)

• Researching, developing, managing, protecting, an improving our services, including identifying trends and insights to make Plan decisions

• Recording and evaluating our interactions with you to assess your satisfaction and for training and quality assurance purposes

• Conducting and recording feedback collected from surveys, focus groups or interviews and analyzing responses to provide us with insights on our operations

• Tracking website usage, transaction history and patterns, for the purposes of improving our website and/or providing tailored messages

• Investigating and resolving technical bugs in our applications

• Improving the user experience of our membership as a whole

• Investigating specific transactions or patterns of transactions to detect unauthorized or illegal activities

• Maintaining appropriate records, including your contact information

• Facilitating the safety and security of visitors to our offices and our employees through the use of CCVS cameras

• Projecting the Plan’s future cash flow requirements

• Performing functions required or authorized by law, including meeting our statutory obligations

• For any other purpose to which you consent

The personal data that we use primarily comes from you and your employer. You provide us with your personal data when you complete forms, respond to our requests for information or participate in our surveys or focus groups. You also provide us with personal data when you call our contact center or enter your personal data on OMERS websites. OMERS websites also automatically collect usage and technical information about your visit.

If you provide us with personal data about another person such as your beneficiary, you are deemed to 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.

Your employer provides us with personal data about you when you are eligible to become a member or when you first become a member and throughout your employment relationship. We may also collect personal data about you from third party sources such as your union, the Public Guardian and Trustee and the Canada Revenue Agency.

We may also collect information about you from third parties in order to maintain your membership record, such as updating your contact information or your membership status.

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 and algorithm-based systems. These tools help us, and our service providers, in internal business activities, such as automating tasks, evaluating data, developing new products and 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.

We may share your personal data with our affiliates, subsidiaries and service providers who assist us with our business operations. Below are some examples of third parties with whom we share your personal data:

• Actuarial advisers

• Debt collection agencies

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

• Financial service providers such as banks and payroll providers

• Information technology service providers such as cloud hosting or software services

• Locator firms

• Mailing services

• Medical advisors retained by OMERS

• Other pension plans with which you have a relationship

• Your employer(s)

• Professional service advisors such as lawyers, auditors or consultants

• Survey services/Research firms

• Other government agencies in accordance with their statutory authority

• Regulators such as the Financial Services Regulatory Authority of Ontario and Canada Revenue Agency

We or our service providers may de-identify personal data by aggregating information about you with other plan members, beneficiaries, survivors or others or by removing identifiers. This de-identified information may be used by us or our services providers for internal business purposes. In addition, we or our service providers may also anonymize personal data so that it can no longer be used to identify you. This anonymized data may be used for any purpose including sharing this information with third parties.

Disclosure of information to employers for other purposes:

The OMERS Pension Plans form part of your overall employment relationship with your employer. Unlike most private sector pension plans, employers who participate in the OMERS Pension Plans do not always have information about member pension accruals, or benefit entitlements that they may require for workforce and succession planning purposes, and for the purpose of other employment related benefit plans such as long-term disability plans and insurance plans. As such, in addition to sharing information for the purposes of pension plan administration, we may share information about a member’s hire date, enrolment date, total accrued service, unreduced early retirement date, and pension amounts after retirement (including disability pensions), for workforce and succession planning purposes and for the purposes of administering other employer benefit programs in which you are enrolled. Members who prefer that this information not be shared may “opt out” on myOMERS.

When you visit our websites, 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 performing by measuring visitor traffic.

OMERS provides website visitors with notice and choice over the cookies that are placed on their browsers. Upon your first visit to an OMERS website you will be presented a banner that will allow you to set your cookies preferences. The banner also provides you with more information on the specific cookies in use on our sites which can be reviewed prior to setting your preferences. You may update your preferences at any time by navigating to the bottom of an OMERS web page and selecting the “Cookie Preferences” option.

Our website often provides links to websites that are operated by third parties not under our control. This Privacy Statement does not describe the privacy policies of any third-party websites or their 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.

How can you help to keep your personal data safe?

You have a shared responsibility to keep your personal data secure. Please take the following steps to help secure your personal data when you use your computers and mobile devices:

• Use your myOMERS account or call OMERS Member Experience to update your information

• Use your myOMERS secure communication to submit documents and communicate securely with OMERS

• Keep your OMERS Member ID and myOMERS password confidential. Do not share them with others, including family members.

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

• Use the latest version of browsers

• Change your myOMERS account password, as well as those of your email and mobile device frequently

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

• Do not use the same password for multiple sites

We and our service providers and agents may transfer, store or access your personal data outside of the jurisdiction in which it was previously been 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 your personal data.

You may request access to your personal data through myOMERS or by contacting our Member Experience team. Upon verification of your identity, we will provide you with access to your personal data, subject to applicable legal restrictions.

We try to ensure that the personal data we collect about you is accurate, complete and up-to-date. However, we rely on you and your employer to provide accurate information in the first instance, and to notify us when there is a change in your personal data. In certain circumstances we may verify personal data or obtain additional personal data through third parties.

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. Given the nature of the OMERS Pension Plans, your personal data is typically retained until the end of our obligation to you or your survivors, plus a fixed period of time thereafter.

As the law develops and as we evolve, 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, or by requesting a copy from our Head of Privacy.

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 Head of Privacy as follows:

Head of Privacy
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