We know your personal data is important to you and it is important to Canada Life Reinsurance* too. This Privacy Notice is designed to provide you with information about the processing of personal data by Canada Life Reinsurance and explains your rights under data protection law.
*Note: For the purpose of this notice, the term ‘Canada Life Reinsurance’ refers only to those entities within the Great West Life group of companies, which have been designated as Data Controllers in the context of the GDPR. These entities are detailed at the end of this notice.
The General Data Protection Regulation (GDPR) applies to processing carried out by organisations operating within the European Union (EU).
Purpose for processing and legal basis for processing personal data
If you join a defined benefit pension scheme or take out an insurance policy, a promise may be made to pay a benefit to you or your family in certain pre-agreed circumstances. For example, a pension may become payable to you from date of retirement until date of death or a lump sum may be payable to your spouse in the event of your death.
Reinsurers offer insurers a method of reducing the overall risk associated with insurance products and assists them with the management of the uncertainties associated with their future payment obligations.
As reinsurers, we may receive personal data from our clients, which includes insurance companies and pension schemes operating within the EU. In the event that your insurance company or pension scheme provider enters into a reinsurance contract with us they may need to provide us with certain personal data, including but not limited to your postcode and information relating to your status as a beneficiary of an insurance or pension product.
We may receive your personal data as part of our business activities including without limitation:
- Designing, underwriting and pricing of new reinsurance contracts;
- Ensuring we meet our obligations pursuant to existing reinsurance contracts, including assessment and payment of claims and associated administration/regulatory requirements; and
- Ongoing risk management activities to measure and limit our exposure to concentration of particular risks.
Canada Life Reinsurance acts as a data controller of any personal data that it receives from your insurance company or pension scheme provider and personal data provided to us is processed in accordance with the GDPR and with this Privacy Notice. We may process some personal data outside of the European Economic Area (EEA).
Canada Life Reinsurance may use and process your personal data in the manner and for the purposes described in this Privacy Notice. We may disclose your personal data to our affiliates i.e. internal companies within our group as described below, for the legitimate interests of Canada Life Reinsurance to allow it to administer the contracts connected with the protection provided to your insurance company or pension scheme provider, to allow it to improve its models of longevity and mortality risk, and in connection with group reporting.
In order to administer pension related contracts the categories of personal data we receive can include:
- Personal information such as postcode, date of birth, gender, marital status, etc.
- Pension information such as policy number, product codes, benefits, etc.
- Financial information such as pension amount, salary information.
In order to administer life, disability and health insurance related contracts the categories of personal data we receive can include the above and in some circumstances, we can receive sensitive personal data including Health information.
If a policy will pay out to beneficiaries, we may receive information relating to those beneficiaries.
Recipients of personal data
We may share personal data with:
- Data processors:
- We may disclose your personal data to our affiliates and in particular, to Canada Life Group Services Limited, an affiliate located in Dublin, Ireland which carries out administrative services on behalf of Canada Life Reinsurance companies.
- On a limited number of contracts, we may disclose personal data to our affiliate Canada Life Assurance Company, Regina, Canada which carries out administrative services on behalf of Canada Life Reinsurance companies.
- We may provide personal data to service providers for the purpose of document management.
- The aforementioned companies act as service providers under contracts with us and only process your personal data as directly instructed by us. Your personal data is transferred securely and is not used by other data processing parties for any other reason
- Other Reinsurers:
- To assist us in meeting our obligations under our contracts, we may seek additional reinsurance cover with reinsurers in order to help us manage our risks.
- As required in order to comply with regulations and laws.
Retention, Minimisation and Anonymisation of Personal Data
Data privacy is at the heart of our processing activities. We continuously work with our clients to ensure we receive only the minimum personal data required to meet our obligations under our contracts. We:
- Delete personal data where we no longer have a lawful basis for processing. Data is deleted or anonymised in accordance with our legal, tax, audit and regulatory obligations.
- Minimise the amount of personal data received from our clients to that necessary for processing in order to fulfil contractual obligations.
- Minimise the personal data we share across our business functions to only the amount required for processing purposes to fulfil contractual obligations.
- Anonymise personal data received wherever possible to minimise the risk to the rights and freedoms of data subjects.
Transfer of personal data outside of the EEA
Your personal data is processed and stored within the EU with the exception of a small number of reinsurance contracts under which we do transfer some personal data securely to our affiliate in Regina, Canada for the purpose of contract administration. Passing your personal data to certain countries, including Canada, is allowed under an adequacy decision made by the European Commission.
We are committed to ensuring that your personal data is secure. We have implemented appropriate technical and organisational protection measures to protect the personal data under our control from unauthorised access, improper use or disclosure, unlawful destruction or accidental loss. Personal data is only processed or shared for the reasons set out in this Privacy Notice.
Data Protection Officer
You can contact our Data Protection Officer at the address below.
Data Protection Officer
Canada Life Reinsurance
Irish Life Centre
Abbey Street Lower
Telephone: +353 1 8291500
Should you have any questions about how Canada Life Reinsurance uses your personal data or if you wish to exercise any of your rights under the GDPR including but not limited to your right
- to request a copy of the personal data that we hold about you;
- to request that we correct any inaccuracies in such personal data; and
- to request that we stop processing your personal data in the manner prescribed in this Privacy Notice
please contact your insurance company in the first instance who will be able to communicate your request to Canada Life Reinsurance.
Due to the limited and restricted nature of the personal data we receive from our clients and business partners, we may be unable to identify individuals from our records. We will therefore liaise with the company who originally provided us with the data in the first instance to support any request.
You have the right to lodge a complaint with the Data Protection Officer or to the relevant data protection authority if you are not satisfied with how we have processed your personal data or if you feel your rights in respect of the GDPR have been infringed. In Ireland, the authority with responsibility for data protection is the Data Protection Commission.
Data Protection Commission,
Co Laois R32 AP23,
Telephone: + 353 761 104800
LoCall: 1890 252231
Canada Life Reinsurance
Canada Life Reinsurance is a division of The Canada Life Assurance Company and certain of its subsidiaries and affiliates. The Canada Life Assurance Company is a subsidiary of Great-West Lifeco Inc. and a member of the Power Financial Corporation group of companies.
Canada Life Reinsurance denotes the following Canada Life Reinsurance group companies covered by this Privacy Notice.
Canada Life International Re Designated Activity Company
London Life and General Reinsurance Designated Activity Company
The Canada Life Assurance Company, Barbados Branch
24 May 2018