At Morneau Sobeco, we are committed to protecting the confidentiality, security and accuracy of the personal information we receive about you. This Privacy Policy explains our approach to honouring this commitment.

Personal information is generally information about an identifiable individual, except business contact information about employees of an organization.

Why we need personal information

As a human resources consulting and outsourcing firm, Morneau Sobeco is engaged by its clients (in most cases, your employer or benefits plan sponsor) to perform services that may require personal information. We receive and use personal information about you in order to perform the services for which we have been hired to do on behalf of our clients.

Collection and Use

We will collect, use and retain only the personal information that we require in order to do the work that we are hired to do. This work generally relates to working on behalf of plan sponsors in the design, delivery, management and processing of pension, savings, benefits, and compensation programs for employees.

We typically receive personal information from two sources, plan sponsors (ie. your employer in most cases) and you directly:

From Plan Sponsors: Almost all of the personal information that we hold is provided to us by our clients and your employee plan sponsors in order to administer and process your plans. We expect that our clients have provided the necessary disclosures and obtained the required consents from you.

From Plan Participants: There are some situations where we obtain your personal information directly from you. Unless we advise you otherwise, this information will be used to assist in the administration or processing of your employee plans. By participating in the plan, you consent to such collection and use of your personal information. If we obtain personal information directly from you for purposes other than as set out in this Privacy Policy, we will disclose the reason for which we require the information and obtain your consent for such use. This consent may be express or implied.

Disclosure

In order to perform the work that we have been hired to do, it may be necessary to share your personal information with third parties. All such third parties are bound to maintain the confidentiality, security and accuracy of your personal information consistent with our Privacy Policy. In some situations, your plan sponsor may direct us to share your personal information with other organizations in connection with your benefits plans.

Finally, we may be required to disclose personal information by law or may be requested to cooperate with regulatory bodies or law enforcement officials in the course of an investigation.

Please be assured that we will not sell your personal information to anyone.

Protecting Your Personal Information

We have established and continue to develop appropriate procedural, electronic and physical security measures to protect your personal information, including:

• A formal computer systems security policy, including the use of passwords, firewalls, anti-virus detection systems, intrusion detection systems and site monitoring
• Extensive physical security features in Morneau Sobeco offices
• Access restricted on a "need to know" basis
• Confidentiality agreements signed by Morneau Sobeco employees and service providers
• Annual acknowledgement of privacy and confidentiality obligations by Morneau Sobeco employees

We will retain personal information for as long as necessary for the purpose for which it has been collected, or as required or permitted by law, including insurance laws, tax laws, pension laws, and statute of limitations laws.

A word about the Internet

We may collect information about users of Web sites hosted by us through the use of cookies. We will use this information only to enhance your current experience and improve our Web sites and/or services that we provide to you.

Responding to Your Privacy Concerns

When requested by you, we will provide you with access to the personal information that we are retaining in our files. While we endeavor to keep all personal information accurate and up-to-date as required for our purposes, if you note any inaccuracies, please contact your service representative directly in order to correct it.

If you have any concerns related to privacy issues or our handling of your personal information, or would like to withdraw a consent that you have previously provided to us, please do not hesitate to communicate in writing with our Privacy Officer: