Aon Solutions Canada Inc. (Wealth)

Why we collect, use and disclose personal information

Collecting personal information about you is essential to our being able to provide the products and services that best meet your needs (including individuals associated with you, all of whom we refer to as “you” in this Privacy Policy). While the personal information we collect may come directly from you, it may also be provided by our affiliates or other third parties (such as employers, , financial institutions, medical professionals, government, search agencies, etc.).

Personal information may be used for the following purposes that are integral to our services:

To determine eligibility and process applications for products and services and to provide information and services
To understand and assess your ongoing needs and offer products and services to meet those needs
Pension consultancy services to trustees, sponsors and members of pension schemes
For communication, service, marketing, billing and administration
For government reporting
For data analysis
For fraud detection and prevention
Other purposes disclosed in our terms of business or disclosed to you at the time of collection, use or disclosure.

Personal information may also be used for additional purposes including:

For analytics
To develop proprietary tools and databases
To comply with legal, audit, security and regulatory requirements

What information we collect

Depending on the products or services we provide, we may collect information that you, or other third parties such as your employer, provide on applications for products and services. Information that we collect may include:

Basic personal details (name, address, date of birth, age, gender, nationality)
Education and professional experience and affiliations (employment history for pension calculations)
Business activities (business activities of the client contacts)
Family, lifestyle and social circumstances (dependent details, marital status)
Basic employee HR details (date joined company, job title, role, full time or part time status)
Health, welfare and absence related data (indication of retirement through ill health, or confirmation a gap in service history is related to maternity leave)
Financial details (income details, Social Insurance Number)
Identification checks and background vetting (for AML checking)

In some cases you may provide us with information such as your email address through technological means including an online secure website. This information is used to manage the self-service password process.

We may also automatically collect information through our marketing programs through the use of cookies, beacons and other technologies that track how you use our website and marketing communications.

Consent to use personal information

We may obtain your express consent or we may determine that consent has been implied by the circumstances. Express consent can be verbal (in person or over the telephone), written or by electronic application (including email). Implied consent occurs when we can assume you have given consent by some other action you take or decide not to take. For example, if you request a specific product or service and provide us personal information in that regard, we infer that you consent to us using that personal information reasonably to provide this service. Upon enrollment in an employer’s pension plan, we infer you consent in the use of your personal information reasonably for the administration of the plan and other related legislative requirements.

If you need to provide personal information about other individuals (such as employees, dependents, etc.), you must obtain their consent for these purposes prior to your disclosure to us.

When you request services from us, we ask that you provide information that enables us to respond to your request. In doing so, you consent to our collection, use and disclosure to appropriate third parties of such personal information for these purposes. You also authorize us to use and retain this personal information for as long as it may be required for the purposes described above. Your consent remains valid even after the termination of our relationship with you, unless you provide us with written notice that such consent is withdrawn. You should note that by withdrawing your consent, or not providing it in the first place, you may limit or even prevent us from being able to provide you or an authorized third party (such as an employer) with the products or services desired.

In certain circumstances, refusing to provide personal information or withdrawing consent will mean that you will not be entitled receive the benefit of services. Additionally, in certain circumstances we will not need to obtain consent or explain the purposes for the collection, use or disclosure of personal information. For example, this exception would apply if there is an emergency that threatens the life, health or security of an individual, for fraud detection or prevention, or if we must comply with a court order.

Sharing personal information with others

Aon only discloses personal information as is required and described in this Policy or as otherwise required by law. In providing our services, we may need to disclose the personal information we collect to affiliates, subsidiaries, successors and other service providers or agents who perform various functions for us. Such parties may be located in Canada, or in other jurisdictions outside of Canada. Where information is collected in Quebec such parties to which we disclose personal information may be located in Quebec or in other jurisdictions outside of Quebec. While your personal information is always subject to confidentiality obligations, while stored in another jurisdiction, it may be subject to the laws of that jurisdiction. As a result the information may be accessed by the courts, government, law enforcement, and regulatory authorities of that country.

Depending on the products or services that we provide to you, we may disclose personal information to pension trustees, search agencies, government entities, printing services, and other parties who have a need for the information in order to make available products and services. If we are legally entitled to do so, we may share information with consumer reporting agencies and governmental authorities when requested to do so or in order to protect our business. We may also be required by law or by rules of arbitration or rules of court to share information.

Aon develops and uses proprietary platforms and databases to gather, store and use information about pension plans and participants in the plans. Aon uses and combines this information and other information collected from Aon’s clients and other individuals for the purposes of developing Aon’s products and services and Aon’s relationship with you and its clients (for example: benchmarking, market research, data analysis, and marketing of products and services that may be of interest to you and Aon’s clients) as well as for other purposes described in this Privacy Policy.

As Aon continues to develop and grow, we may buy or sell parts of a business. As our businesses consist primarily of client relationships, information regarding the particular accounts or services being purchased or sold could include personal information and be one of the transferred business assets. We may also use this personal information to assess your future needs and to offer the products and services that may best meet those needs, from ourselves, our affiliates or reputable organizations selected by us. If you do not wish to receive these offers or such information, please contact our Privacy Officer as outlined in the Contact Information section.

Last Updated: September 22, 2023

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