New mandatory breach notification and record keeping
requirements in the Personal Information Protection and
Electronic Documents Act (PIPEDA) will come into force on
November 1, 2018. Where PIPEDA applies, these new requirements will
have significant implications for the administration of pension
plans since plan administration necessarily involves the
collection, use and disclosure of the personal information of plan
beneficiaries.
Applicability of PIPEDA
PIPEDA is the federal privacy legislation that applies to the
collection, use, disclosure, maintenance and destruction of
personal information by federal undertakings (e.g.,
banks), in the course of both employment relationships and
commercial activities. It also applies to the collection, use,
disclosure, maintenance and destruction of personal information by
other private sector organizations in provinces that do not have
their own private sector privacy legislation (e.g.,
Ontario) in the course of commercial
