Pensioners’ Dental Services 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 Pensioners’ Dental Services Plan (PDSP) Privacy Statement. For additional definitions such as dependant, member, administrator, and eligible family member, refer to the Pensioners' Dental Services 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 personal information elements collected to administer the PDSP 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 PDSP.

Board of Management

Is comprised of 6 persons to be members of the board chosen by the President of the Treasury Board of Canada, 3 of whom are pensioner representatives, in addition to a board chair and is responsible for reviewing and rendering decisions on plan member appeals. Under the PDSP, there is 1 Board of Management.

Introduction

The Pensioners’ Dental Services Plan (PDSP) is a voluntary dental services plan established by the Government of Canada to provide dental services coverage to eligible federal pensioners and their eligible family members, including survivors. The PDSP covers only reasonable and customary dental treatment necessary to prevent or correct a dental disease or defect if the treatment is consistent with generally accepted dental practices.

The PDSP is a self-insured plan. This means that all eligible plan expenses will be covered from the contributions of the participating parties: the Government of Canada and the PDSP members. The Government of Canada has the sole legal and financial liability for the PDSP.

As of October 1, 2010, the cost of the plan is shared equally between the Government of Canada and members.

For additional information on PDSP benefits:

• Pensioners' Dental Services Plan
• Pensioners' Dental Services Plan rules

Privacy Statement

The objective of the PDSP Privacy Statement is to inform individuals who are covered under the PDSP 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 PDSP (Participating Employers) who are subject to the Privacy Act. They include the Treasury Board of Canada Secretariat (TBS), departments, agencies, separate agencies, special operating agencies, and boards and commissions.

The statement does not apply to the administrator. This entity has their own statement in accordance with 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 PDSP and 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 fact 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 - Office of the Privacy Commissioner of Canada
• Accessing your personal information

Responsibilities

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 PDSP. To this end, the administrator employs privacy professionals who continually review new and existing legislation, incorporating requirements into the administrator internal practices.

PDSP Board of Management

On behalf of the Board, TBS collects 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 meeting, 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 PDSP 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 and that have entered into an agreement with Public Services and Procurement Canada (PSPC) for pension administration and PDSP enrolment, collect personal information from members under the PDSP for the purposes of:

• certifying eligibility for coverage
• registering members
• determining and amending status and coverage
• obtaining authorization for pension deductions and refund of contributions

Pursuant to an agreement between the parties for pension administration, PSPC’s Superannuation, Pension Transition and Client Services collects personal information from participating employers and from pensioners for the purposes of:

• certifying eligibility for coverage
• registering members
• determining and amending status and coverage
• obtaining authorization for pension deductions and refund of contributions
• providing eligibility data to the administrator
• applying pension deductions

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

• certifying eligibility for coverage
• registering members
• determining and amending status and coverage
• obtaining authorization for pension deductions
• providing eligibility data to the administrator
• applying pension deductions

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

• plan eligibility, enrolment, and collection of contributions.
• communicating with plan members
• auditing the administrator regarding plan eligibility

TBS collects personal information under the PDSP from plan members 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 PDSP, from PSPC for the purposes of:

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

Notification and Consent

At the time of their application to the PDSP, members are informed by their pension office of the purposes for the collection of personal information. The use and disclosure of the member's personal information and that of their eligible dependants, by the administrator, is acknowledged by the signing of each benefits claim form, digital claims submission, and implied consent for claims submitted by the dental provider.

Use and Disclosure

Personal information under the PDSP 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 Public Service Dental Care Plan and the PDSP (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 PDSP, 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 2 years under the Privacy Act, the retention period may vary by participating employer.

Retention periods for the administrator

The administrator retention period for the PDSP 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 can 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
Access to Information and Privacy Coordinators (list of)

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.