The purpose of this Privacy Statement is to outline the policies, procedures and measures the Public Sector Pension Investment Board and its relevant operating wholly-owned subsidiaries (“PSP Investments”) take 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.

1. Collection of Personal Information
   1. 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.
   2. 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.
   3. 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.
2. Retention and Disposal of Personal Information
   1. 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.
   2. 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.
3. 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.
4. Use and Disclosure of Personal Information
   1. 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.
   2. 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.
5. 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.
6. Access to Personal Information
   1. 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.
   2. 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.
   3. 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.
   4. 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.
   5. 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.
   6. 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.
   7. 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.
   8. 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.
7. Personal Information Corrections and Notations
   1. 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.
   2. 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.
   3. 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.
   4. 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.