Public Service Dental Care Plan Privacy Statement

This privacy statement is effective November 1, 2024

On this page

• Definitions
• Introduction
• Privacy Statement
• Responsibilities
• Collection of personal information
• Purposes of Collection
• Notification and Consent
• Use and Disclosure
• Accuracy
• Retention
• Access to personal information
• Right of Complaint

Definitions

The following definitions are for roles and terms used in the Public Service Dental Care Plan (PSDCP) Privacy Statement. For additional definitions such as dependant, member, administrator, and dependant, refer to the Public Service Dental Care Plan Rules.

Personal Information

As defined in section 3 of the Privacy Act, personal information means information about an identifiable individual that is recorded in any form. A list of the elements of personal information collected to administer the PSDCP and deliver benefits and services to plan members can be found in this statement under Purposes of Collection.

Treasury Board of Canada Secretariat

Is the administrative arm of the Treasury Board (TB) responsible for developing and overseeing the policy framework for the management of public service employee benefits, including the PSDCP.

Board of Management

Is comprised of representatives for employees and the employer and is responsible for reviewing and rendering decisions on plan member appeals. Under the PSDCP, there are 4 Boards of Management:

1. National Joint Council Board
2. Public Service Alliance of Canada Board
3. Canadian Forces Board
4. Royal Canadian Mounted Police Board

Introduction

The Public Service Dental Care Plan (PSDCP) is a private dental benefits plan designed to reimburse members for all or part of costs they incur for eligible dental services and products.

The Treasury Board of Canada Secretariat (TBS) is accountable to Parliament and the Canadian electorate for the PSDCP’s performance and for the benefits Canada derives from the investment of public funds in the plan.

Certain responsibilities have been assigned to 3 governance bodies comprised of individuals appointed by the Treasury Board, the public service bargaining agents, and employer representatives appointed by the President of the Treasury Board, so that the PSDCP may be managed collaboratively by these parties. These governance bodies are:

1. the PSDCP Boards of Management supported by 5 components that focus on plan design and policy:
   1. National Joint Council
   2. Public Service Alliance of Canada
   3. Canadian Armed Forces Dependants
   4. Royal Canadian Mounted Police Dependants and Civilian Members
   5. Canadian Armed Forces Reserves 
2. the Treasury Board of Canada Secretariat which has responsibilities for contract management and overseeing the day-to-day administration of the PSDCP
3. Public Services and Procurement Canada (PSPC) who administers plan enrolment and contributions related to Leave Without Pay

For additional information on PSDCP benefits:

• Public Service Dental Care Plan
• Rules of the dental care plan for the public service of Canada

Privacy Statement

The objective of the PSDCP Privacy Statement is to inform individuals who are covered under the PSDCP about who is collecting their personal information; what personal information is being collected and for what purposes; when the information will be disposed of; how to get access to their personal information on file, and, if required, how to correct it. It also explains how individuals can file a complaint with the Office of the Privacy Commissioner if they are not satisfied with the way in which their personal information is handled. These provisions are consistent with the Privacy Act.

The statement applies to the employers participating in the PSDCP (participating employers) who are subject to the Privacy Act. These include TBS, departments, agencies, separate agencies, special operating agencies, and boards and commissions.

The statement does not apply to a small number of participating employers that are not subject to the Privacy Act, or the administrator. These entities may have their own privacy statements in accordance with the privacy legislation to which they are subject.  For example, the administrator, which is subject to the Personal Information Protection and Electronic Documents Act (PIPEDA), or in some cases to applicable provincial/territorial legislation in jurisdictions where it operates, makes available to the public its Privacy Policy and Privacy Code. They describe the administrator’s commitment to privacy in the daily management of the personal information of its customers including the participants of the benefits plans it administers.

The purpose of this Privacy Statement is to describe for plan members the privacy practices of participating employers that are required to handle their personal information and that of their eligible dependants pursuant to requirements under the Privacy Act.

Nevertheless information about the responsibilities of the administrator and those employers not subject to the Privacy Act is referenced in sections 1 to 7 in order to provide a comprehensive picture of the roles and responsibilities of all parties handling personal information in the course of administering the PSDCP and in delivering dental benefits and services to plan members.

Privacy landscape in Canada

The Office of the Privacy Commissioner of Canada provides a large inventory of facts sheets and links regarding Privacy in Canada that can be helpful in understanding applicable privacy legislation. This information is available at the following links:

• Summary of privacy laws in Canada
• Accessing your personal information

Responsibilities

Participating employers

Participating employers subject to the Privacy Act collect personal information in order to fulfill their respective mandate. They are responsible for the protection of personal information they collect for the purposes described in section 3 of this statement and to ensure that employees involved in the collection and management of this information comply with privacy policies in the day-to-day management of such information. The Government of Canada has a Policy on Privacy Protection. Participating employers have a designated Access to Information and Privacy Coordinator responsible for ensuring compliance with the Privacy Act and Access to Information Act.

Participating employers that are not subject to the Privacy Act are responsible for the protection of personal information they collect for the purposes of administering the PSDCP. They may or may not be subject to other federal, provincial, or territorial privacy legislation. In those cases, members are encouraged to contact the person within their organization responsible for their employer's privacy practices and to access additional information describing the Summary of privacy laws in Canada.

Employees

All employees working for an employer that is subject to the Privacy Act and involved in the collection of personal information for the administration of the PSDCP are responsible to comply with procedures that are in place for the confidential and secure handling of personal information.

Administrator

The administrator is subject to the PIPEDA and to applicable provincial/territorial legislation in the jurisdictions where it does business on behalf of the PSDCP. To this end, the administrator employs privacy professionals who continually review new and existing legislation, incorporating requirements into the administrator internal practices.

Boards of Management

On behalf of the Boards of Management, the secretariats for the Canadian Armed Forces, National Joint Council, Public Service Alliance of Canada, and Royal Canadian Mounted Police components collect personal information from members, such as plan member name, plan number and certificate number, and any additional information that can assist with the review of a plan member appeal.

All personal information is redacted prior to the Board of Management meetings, including name(s), certificate number, gender, dependant names and other information not pertinent to the Board of Management’s decision-making. The Board of Management members are only provided with redacted materials where the anonymity of the plan member is assured.

Collection of personal information

The collection of personal information under the PSDCP is limited to what is required for the purposes described in this statement under Purposes of Collection.

Purposes of Collection

Participating employers subject to the Privacy Act  that have entered into an agreement with PSPC for payroll services, collect personal information from members under the PSDCP for the purposes of:

• certifying eligibility for coverage
• registering members
• determining and amending status and coverage
• administering contributions for periods of leave without pay

Pursuant to an agreement between the parties for payroll services, PSPC collects personal information from participating employers for the purposes of:

• certifying eligibility for coverage
• registering members
• determining and amending status and coverage
• providing eligibility data to the administrator
• administering contributions for periods of leave without pay

In the case of those participating employers that are subject to the Privacy Act and have not entered into an agreement with PSPC for payroll services, personal information is collected by these employers under the PSDCP for the purposes of:

• certifying eligibility for coverage
• registering members
• determining and amending status and coverage
• providing eligibility data to the administrator
• administering contributions for periods of leave without pay

PSPC collects personal information for the PSDCP on behalf of TBS for the purposes of:

• plan eligibility, enrolment, and collection of contributions as appropriate (LWOP)
• communicating with plan members
• auditing the administrator regarding plan eligibility

TBS collects personal information under the PSDCP for the purposes of:

• administering plan member appeals, overseeing claims adjudication and plan administration
• communicating with plan members
• responding to plan member enquiries

The administrator collects personal information under the PSDCP, from PSPC for the purposes of:

• administering the benefits
• adjudicating claims
• communicating with plan members
• responding to plan member enquiries
• supporting appeal administration

The secretariats from the Canadian Armed Forces, Public Service Alliance of Canada, National Joint Council and Royal Canadian Mounted Police Components on behalf of the Boards of Management collect personal information under the PSDCP for the purposes of:

• reviewing and rendering decisions on plan member appeals

Notification and Consent

At the time of joining the PSDCP, members are informed by their compensation advisors of the purposes for the collection of personal information.

The member provides expressed consent for use and disclosure by the administrator of the member's personal information and that of eligible dependants by signing each benefits claim form and completing positive enrolment with the administrator, and implied consent for members eligible for proactive positive enrolment.

Use and Disclosure

Personal information under the PSDCP is used and disclosed solely for the purposes for which it was collected and identified in this statement under Purposes of Collection.

In addition, your information may be shared between the plan administrator and its subcontractors in support of the Public Service Health Care Plan, the PSDCP and the Pensioners’ Dental Services Plan (whichever plans you are enrolled in) to facilitate the administration of services, including updating your information across plans so that you do not have to provide the same information multiple times.

In the event of an overpayment where the member fails to comply with the administrator on a repayment schedule, the known details of the overpayment situation will be disclosed to the appropriate government institution for the purpose of obtaining consent on the recovery of the overpayment.

Participating employers ensure that policies and procedures are in place to address any improper or unauthorized disclosure of personal information.

Accuracy

Participating employers that are subject to the Privacy Act and their employees administering personal information under the PSDCP, ensure completeness and accuracy of the personal information by having procedures in place that:

• regularly update the personal information
• keep a record of the source of the information used to make the changes
• ensure notification of the changes to other parties to whom the information was disclosed
• ensure that participants are able to access and request correction of their personal information

Retention

Personal information concerning an individual that has been used by a participating employer subject to the Privacy Act for an administrative purpose shall be retained by the employer:

• for a minimum of 2 years following the last time the personal information was used for an administrative purpose unless the individual consents to its earlier disposal
• where a request for access to the information has been received, until such time as the individual has had the opportunity to exercise all their rights under the act

Other than the required minimum two years under the Privacy Act, the retention period may vary by participating employer.

Retention periods for the administrator

The administrator retention period for the PSDCP is 10 years. This ensures compliance with the Canada Revenue Agency and the Privacy Act.

Access to personal information

Plan participants are informed and will, consistent with the Access to Information and Privacy acts, be given access, upon their request, to their personal information used and disclosed by the participating employer. Plan participants are able to challenge the accuracy and completeness of the information and request correction, by contacting the designated privacy officers listed in section 9 of this statement.

There exist several reference tools to assist members of the public in exercising their rights under the Access to Information Act and the Privacy Act.

One of these reference tools is called Info Source. It is a series of publications containing information about the Government of Canada, its organization and information holdings. It supports the government's policy to explain and promote open and accessible information regarding its activities. Other reference tools:

• Info Source: Sources of Federal Government and Employee Information
• OPC Access to Information and Privacy

Right of Complaint

Plan participants can address any questions and/or complaints regarding compliance with the above sections using the following contacts:

Treasury Board of Canada Secretariat
Director, Access to Information and Privacy
90 Elgin Street, 8th Floor
Ottawa, Ontario K1A 0R5
Telephone: 1-866-312-1511
Email: atip.aiprp@tbs-sct.gc.ca

Participating employers subject to the Privacy and Access to Information Acts
List of access to information and privacy coordinators by institution

Participating employers that are not subject to the Privacy Act
Participants can address their questions and/or complaints to their respective organization.

Public Services and Procurement Canada
Access to Information and Privacy Director
Telephone: 873-469-3721
Email: AIPRP.ATIP@tpsgc-pwgsc.gc.ca

If you are concerned with the way in which your personal information has been handled, please contact the Office of the Privacy Commissioner, by telephone at 1-800-282-1376 or the Office of the Privacy Commissioner.