Privacy Act Requests
PSP Investments is subject to the Privacy Act.
You can make a request under the Privacy Act by sending your completed personal information request form to:
Access to Information and Privacy Coordinator
1250 René-Lévesque Boulevard West
Canada H3B 5E9
Part I: Purpose
The Public Sector Pension Investment Board and its relevant operating wholly-owned subsidiaries (“PSP Investments”) are committed to providing websites that respect the privacy of visitors. This Privacy Notice summarizes the privacy practices for PSP Investments’ online activities. All personal information collected by this institution is governed by the Privacy Act.
The purpose of this Privacy Notice is to outline the policies, procedures and measures PSP Investments takes with respect to the collection, use, disclosure, protection and handling of personal information in order to comply with its obligations under the federal Privacy Act, the Privacy Regulations, and applicable policies, directives and guidelines of the Treasury Board of Canada Secretariat (“Treasury Board”) issued pursuant to its mandate under the Privacy Act.
Part II: Privacy Principles
- Collection of Personal Information
- PSP Investments shall not collect personal information unless it relates directly to an activity of PSP Investments within its authority and objects under the Public Sector Pension Investment Board Act and other applicable legislation. Personal information collected by PSP Investments shall be limited to what is necessary in order to carry out the permitted program or activity.
- Subject to limited exceptions under the Privacy Act, PSP Investments shall, wherever possible, collect personal information that is intended to be used for an administrative purpose directly from the individual to whom the information relates, except where the individual otherwise authorizes, or where the information is permitted to be disclosed to PSP Investments by another government institution under the Privacy Act.
- PSP Investments shall inform any individual from whom it collects personal information of the following:
- the purpose for which the information is being collected;
- the authority for the collection, including whether response is voluntary or is required by law;
- any uses or disclosures that are consistent with the original purpose;
- any uses or disclosures that are not related to the original purpose;
- of the possible legal or administrative consequences of refusing to provide the information; and
- that the individual has rights of access to, correction of and protection of the personal information under the Privacy Act.
- Retention and Disposal of Personal Information
- Personal information that has been used by PSP Investments for an administrative purpose shall be retained for at least two years following the last time the information was used for such purpose, unless the individual consents to its disposal. Where a request for access to the information has been received, the personal information subject to such request shall be retained until the requesting individual has had the opportunity to exercise all his or her rights under the Privacy Act or the Access to Information Act.
- PSP Investments shall dispose of personal information under its control in accordance with the Privacy Regulations and in accordance with any directives or guidelines issued by Treasury Board in relation to the disposal of that information. PSP Investments will also consider the provisions of the Library and Archives of Canada Act when disposing of records containing personal information.
- Accuracy of Personal Information
PSP Investments shall take all reasonable steps to ensure that personal information it uses for an administrative purpose is as accurate, up-to-date and complete as possible.
- Use and Disclosure of Personal Information
- PSP Investments shall not, without the consent of the individual to whom the personal information relates, use personal information under its control except for the purpose for which the information was obtained or compiled by PSP Investments or for a use consistent with that purpose, or for a purpose for which the information may be disclosed in accordance with the Privacy Act. i.e. This restriction does not apply to disclosures to federal investigative bodies for the purpose of law enforcement or investigations under Section 8(2)(e) of the Privacy Act.
- PSP Investments shall not, without the consent of the individual to whom the personal information relates, disclose personal information under its control except for the purpose for which the information was obtained or compiled by PSP Investments or for a use consistent with that purpose or otherwise for a purpose enumerated and permitted under the Privacy Act.
- Security and Protection of Personal Information
PSP Investments shall protect personal information in its custody or control using physical, organizational and technical security safeguards appropriate to the sensitivity of the information. The security safeguards shall protect personal information against loss or theft, as well as unauthorized access, disclosure, copying, use, or modification. More sensitive personal information shall be safeguarded by a higher level of protection.
- Access to Personal Information
- Subject to and in accordance with the Privacy Act and the Privacy Regulations, PSP Investments shall, on request by an individual, give access to: (1) any personal information about that individual contained in a personal information bank; and (2) any other personal information under its control with respect to which an individual is able to provide sufficiently specific information on the location of the information so as to render it reasonably retrievable by PSP Investments. PSP Investments will respect the privacy of requesters and will limit, on a need-to-know basis, the disclosure of information that could directly or indirectly lead to the identification of a requester, unless the requester consents to such disclosure.
- Formal requests for access to personal information must be in writing to the designated officer of PSP Investments or ATIP Coordinator in the form of Access to Personal Information Request Form prescribed by Treasury Board, and must identify each personal information bank that is the subject of the request or each class of personal information that is not contained within a personal information bank, providing sufficiently specific information about the location of the information so as to render it reasonably retrievable by PSP Investments. A request that is submitted by telephone or by e-mail shall not be considered to have been submitted pursuant the terms of the Privacy Act. The designated officer of PSP Investments or ATIP Coordinator will consider whether it is appropriate to process the request on an informal basis, in which case the requester will be offered that option along with an explanation that only formal requests are subject to the provisions of the Privacy Act.
- PSP Investments will make every reasonable effort to search records under PSP Investment’s control to identify and locate the personal information that is responsive to the request.
- PSP Investments shall respond to the individual within thirty days of receipt of a formal request for access, subject to extension of time limits permitted in the Privacy Act, by:
- giving written notice as to whether or not access to the information or a part of the requested information will be given, and
- if access is to be given, giving the requesting individual access to the information or part of the information, or
- if access is refused, giving written notice that (1) the personal information does not exist, or (2) the specific provision of the Privacy Act on which the refusal was based or the provision on which a refusal could reasonably be expected to be based if the information existed, and shall state that the individual who made the request has the right to make a complaint to the Privacy Commissioner of Canada about the refusal.
- Access to personal information in the control of PSP Investments shall be subject to the permissive and mandatory exemptions set out in the Privacy Act. Under the guidance of the ATIP Coordinator, all requested personal information shall be reviewed for the purpose of identifying and severing any portions excluded from the Privacy Act or which must be exempted, and for making a decision concerning disclosure of personal information which may be exempted, and which review shall include all consultations with other government departments as required by Treasury Board policy. Exemptions will be cited on the records unless doing so would reveal the exempted information or cause the injury upon which the exemption is based.
- Before providing access to personal information, PSP Investments shall require the requesting individual to provide adequate identification. PSP Investments may require the individual to present him/herself in person for identification purposes.
- If access is to be provided, PSP Investments shall:
- permit the individual to examine the information by providing reasonable facilities for the examination and setting a time for the examination convenient for both PSP Investments and the individual, or
- provide the individual with a copy of the information, and
- if the individual requests that the information be given in a particular official language of Canada and the personal information does not exist in that language and if necessary to enable the individual to understand the information, cause the information to be translated or interpreted for the individual;
- if the individual has a sensory disability and requests that access be given in an alternative format, if it is necessary to enable the individual to exercise his or her right of access and if it is reasonable to cause the information to be converted, provide the information in an alternative format acceptable to the individual.
- PSP Investments shall consult with the appropriate institutions in all instances involving the application of sections 21, 22 and 23 of the Privacy Act.
PSP Investments shall provide assistance, as required, to individuals in exercising their rights of access under the Privacy Act.
- Personal Information Corrections and Notations
- Every individual who is given access under Section 6 above to personal information that has been used, is being used or is available for use for an administrative purpose is entitled to:
- request correction of the personal information where the individual believes there is an error or omission in the information;
- require that a notation be attached to the information reflecting any correction requested but not made, and
- require that any person or body to whom the information has been disclosed for use for an administrative purpose within two years prior to the time a correction is requested or a notation is required: (1) be notified of the correction or notation, and (2) where the disclosure is to another government institution, the institution make the correction or notation on any copy of personal information under its control.
- Formal requests for correction of personal information must be in writing to the designated officer of PSP Investments in the form of Correction Request Form prescribed by Treasury Board.
- Where a correction is made by PSP Investments pursuant to the request, within thirty days after receipt of the request, PSP Investments shall:
- notify the individual that the correction has been made;
- notify any person or body to whom the personal information has been disclosed as described in (a) above that the correction has been made, and
- if the person or body to whom the personal information has been disclosed as described in (a) above is another government institution, notify the appropriate officer of that institution of the requirement to make the correction on every copy of the personal information under the control of the institution.
- Where a request for correction is refused by PSP Investments in whole or in part, within thirty days after receipt of the request, PSP Investments shall:
- attach a notation to the personal information reflecting that a correction was requested but was refused in whole or in part;
- notify the individual that (1) the request for correction has been refused in whole or in part and set out the reasons for the refusal, (2) the notation described above has been attached to the personal information, and (3) the individual has the right under the Privacy Act to make a complaint to the Privacy Commissioner of Canada;
- notify any person or body to whom the personal information has been disclosed as described in (a) above that the required notation has been attached to the personal information, and notify the appropriate officer of any government institution to whom the personal information has been disclosed as described in (a) above that the required notation has been attached to the personal information and that the officer is required to attach such a notation to every copy of the personal information under the control of the institution.
- Every individual who is given access under Section 6 above to personal information that has been used, is being used or is available for use for an administrative purpose is entitled to:
Part III: Your Privacy and the Internet
The nature of the Internet is such that Web servers automatically collect certain information about a visit to a website, including the visitor’s Internet Protocol (IP) address. IP addresses are unique numbers assigned by Internet Service Providers (ISP) to all devices used to access the Internet. Web servers automatically log the IP addresses of visitors to their sites. The IP address, on its own, does not identify an individual. However, in certain circumstances, such as with the co-operation of an ISP for example, it could be used to identify an individual using the site. For this reason, PSP Investments considers the IP address to be personal information, particularly when combined with other data automatically collected when visitor requests a Web page such as the page or pages visited, date and time of the visit. Unless otherwise noted, PSP Investments does not automatically gather any specific information from you, such as your name, telephone number or email address. PSP Investments would obtain this type of information only if you supply it to us, for example, by email or by submitting such information to use on our Career Opportunities site. In cases where services are provided by organizations outside of PSP Investments, such as through Authoria, Inc., the service provider for our Career Opportunities site, IP addresses may be recorded by the Web server of the third-party service provider. A specific Privacy Notice governing the treatment of personal information submitted to the Career Opportunities Site is available when registering on that site.
- Communicating with PSP Investments via e-mail
If you choose to send an email, your personal information is used by PSP Investments in order to respond to your inquiry. The information you provide will only be shared with another government institution if your inquiry relates to that institution. PSP Investments does not use the information to create individual profiles nor does it disclose the information to anyone other than to those in the federal government who need to provide you with a response. Any disclosure of your personal information is in accordance with the Privacy Act. Emails and other electronic methods used to communicate with the PSP Investments may not be secure and PSP Investments cannot guarantee the confidentiality of messages that are received/sent via email. Therefore, it is recommended that you do not send sensitive personal information, such as your Social Insurance Number or your date of birth, through electronic means.
Personal information from emails is collected pursuant to Section 5 of the Public Sector Pension Investment Board Act. Such information may be used for statistical, evaluation and reporting purposes and is included in the Public Communications Personal Information Bank (PSPIB PSU 914).
- Digital Markers (including cookies)
A digital marker is a resource created by the a visited website’s Web server in order to remember certain pieces of information for the Web server to reference during the same or subsequent visit to the website. Examples of digital markers are “cookies” or HTML5 web storage. Some examples of what digital markers do are as follows:
- they allow a website to recognize a previous visit each time the visitor accesses the site;
- they track what information is viewed on a site which helps website administrators ensure visitors find what they are looking for.
- Web Analytics
Web analytics is the collection, analysis, measurement, and reporting of data about Web traffic and visits for purposes of understanding and optimizing Web usage. Information in digital markers may be used for the purpose of web analytics in order to remember your interactions with PSP Investments’ website.
PSP Investments uses Web analytics to improve its website. When your computer requests PSP Investments’ Web page, our institution collects the following types of information for Web analytics:
- the originating IP address
- the date and time of the request
- the type of browser used
- the page(s) visited
- the type of device used
- the frequency of visits
- the duration of visits
- the traffic sources
Data collected for Web analytics purposes may be sent to, and stored in, locations outside of Canada, such as the United States and other countries where Google’s servers are located and may be subject to the governing legislation of those countries (for example the USA Patriot Act).
Information used for the purpose of Web analytics is collected pursuant to the Section 5 of the Public Sector Pension Investment Board Act. Such data may be used for communications and information technology statistical purposes, audit, evaluation, research, planning and reporting.
- Protecting the Security of PSP Investments Websites
PSP Investments employs tools to monitor network traffic to identify unauthorized attempts to upload or change information, or otherwise cause damage. These tools receive and record the IP address of the computer that has contacted our website, the date and time of the visit and the pages visited. We make no attempt to link these addresses with the identity of individuals visiting our site unless an attempt to damage the site has been detected.
This information is collected pursuant to section 161 of the Financial Administration Act. The information may be shared with appropriate law enforcement authorities if suspected criminal activities are detected. Such information may be used for network security related statistical purposes, audit, evaluation, research, planning and reporting and is included in the Security Incidents Personal Information Bank (PSPIB PSU 939).
- Inquiring about these Practices
Any questions, comments, concerns or complaints you may have regarding the administration of the Privacy Act and privacy policies regarding PSP Investments’ Web presence may be directed to our Access to Information and Privacy by writing to her at 1250 René-Lévesque Boulevard West, Suite 900, Montreal, Quebec, Canada H3B 4W8.
If you are not satisfied with PSP Investment’ response to your privacy concern, you may wish to contact the Office of the Privacy Commissioner by telephone at 1-800-282-1376.
Part IV: Definitions
In this Privacy Notice, the following terms have the following meanings:
“administrative purpose” means the use of an individual’s personal information in a decision making process that directly affects that individual.
“ATIP Coordinator” means the PSP Investments official appointed to this position.
“personal information” means information about an identifiable individual that is recorded in any form, including (without restricting the generality of the foregoing):
- information relating to the race, national or ethnic origin, colour, religion, age or marital status of the individual; information relating to the education or the medical, criminal or employment history of the individual or information relating to financial transactions in which the individual has been involved;
- any identifying number, symbol or other particular assigned to the individual;
- the address, fingerprints or blood type of the individual;
- the personal opinions or views of the individual except where they are about another individual or about a proposal for a grant, an award or a prize to be made to another individual by a government institution or a part of a government institution specified in the regulations under the Privacy Act;
- correspondence sent to a government institution by the individual that is implicitly or explicitly of a private or confidential nature, and replies to such correspondence that would reveal the contents of the original correspondence;
- the views or opinions of another individual about the individual;
- the views or opinions of another individual about a proposal for a grant, an award or a prize to be made to the individual by an institution or a part of an institution referred to in the fifth bullet above, but excluding the name of the other individual where it appears with the views or opinions of the other individual, and
- the name of the individual where it appears with other personal information relating to the individual or where the disclosure of the name itself would reveal information about the individual.
For the purposes of use and disclosure of personal information described above, “personal information” does not include:
- certain information about officers, employees of PSP Investments and other government institutions that relates to the position or functions of the individual, as set out in more detail in the Privacy Act;
- information about an individual who is or was performing services under contract for PSP Investments that relates to the services performed, including the terms of the contract, the name of the individual and the opinions or views of the individual given in the course of the performance of those services;
- information relating to any discretionary benefit of a financial nature, including the granting of a license or permit, conferred on an individual, including the name of the individual and the exact nature of the benefit, and
- information about an individual who has been dead for more than twenty years.