February 2021

The Privacy Policy of GFD and its subsidiaries is based on the Canadian Standards Association (CSA) Model Code for the Protection of Personal Information, and the Personal Information Protection and Electronic Documents Act (“PIPEDA”).

The Privacy Policy describes the principles that GFD will use to protect the privacy of personal information in the carrying out of commercial activities, no matter how the information is collected, stored, used or disclosed. This policy does not apply to personal information about directors, officers, employees or any volunteer or individual assigned to GFD on secondment or contract from a third party, or to information that is not personal information as defined by the legislation.

GFD is committed to the protection of personal information which is collected, used and disclosed in the course of its business.

The Objectives of This Policy Are To:

• Identify the purpose for collection, use and disclosure of personal information.
• Inform Members and other stakeholders of GFD’s data collection practices in order to protect Member and client privacy.
• Outline the process for Members and clients to be granted access to information.
• Maintain respect and integrity of GFD’s relationships with Member bereavement establishments.

Definitions

Guaranteed Funeral Deposits of Canada (Fraternal) hereinafter “GFD”, “we”, “us”, “our”.

“Member Bereavement Establishments”, means licensed funeral homes, transfer services, cemeteries and crematoriums who either have funds on deposit with GFD or who are enrolled in an insurance program offered by GFD and/or its subsidiaries, (hereinafter “Member Bereavement Establishments”).

“Clients” of Member Bereavement Establishments means individuals who have monies either held in trust by a bereavement establishment or underwritten by an insurance company through GFD and/or its subsidiaries, or by an Agent acting on behalf of GFD and/or its subsidiaries in respect to pre-paid services (“Client”). For purposes of this policy a Client may include the applicant or the owner of the services.

“Personal Information” means information about an identifiable individual as defined in the Personal Information Protection and Electronic Documents Act.

Identifying Purpose for the Collection, Use and Disclosure of Personal Information

GFD collects, uses and discloses personal information about Member Bereavement Establishments and the Clients that they serve for the purpose of collecting, holding, investing, administering and disbursing funds held in trust and for the purpose of collecting and disbursing insurance funds by the Member Bereavement Establishment on behalf of a Client.

GFD may collect personal information about a Client or a Member Bereavement Establishment, use it or disclose it for the following identified purposes:

• To confirm identity of the Client or other contact person: name, address, email, telephone number, birth date and gender.
• To determine the amount of investment.
• To establish, manage and continue the service: payment information, including credit card and bank account information and other financial and business information.
• To offer certain pay plans and insured offerings. Personal health information may be collected in relation to certain pay plans and insured offerings. When GFD collects personal health information it will be used . only for the purpose of such identified plans and insured offerings.
• To satisfy income tax and other reporting obligations: Social Insurance Number and identity information.
• To verify and report credit information to credit bureaus and credit reporting agencies: Social Insurance Number and identity information.
• To assist in the collection of a debt that may be owed to GFD.
• To respond to a complaint or inquiry by a Member Bereavement Establishment on its own behalf or on behalf of a Client.
• To satisfy and respond to a Court Order, search warrant or other legal demand or request, or to respond to the rules of production of a Court.
• To satisfy legal and regulatory requirements placed upon GFD.
• To prevent or detect fraud or criminal activity and to protect against any loss arising from such activity.
• To fulfil the contract of service with the Member Bereavement Establishment, which may include other personal information collected by the Member Bereavement Establishment and disclosed to GFD.

Information about a Client may be provided by the Member Bereavement Establishment to GFD in keeping with the stated identifying purposes. The nature and extent of the information provided will vary depending upon the type of information and services requested.

GFD may use third party service providers to process or handle personal information on our behalf and to assist with the provision of various services, including investment, marketing, postal or other services. When personal information is provided to our service providers, GFD requires them to protect the information in a manner that is consistent with GFD privacy practices. When GFD receives personal information from a third party service provider, such as another financial institution, such information will be subject to the GFD privacy practices.

Service providers may be located in another jurisdiction and that while the information is in another jurisdiction it may be accessed by the courts, law enforcement and national security authorities pursuant to the laws of that jurisdiction. To obtain information about our policies and practices with respect to any service providers outside Canada contact our Privacy Officer at the address below.

GFD is not made privy to, nor does it collect copies of any contract between the Client and the Bereavement Establishment. Any and all inquiries in respect of the contract must be directed to the Bereavement Establishment as GFD does not deal with Clients except in the context of an access request as described herein.

In addition, when a Member Bereavement Establishment or a Client views, applies for or enrolls in a service via a digital channel (such as online), GFD may collect information about the Client and or Member Bereavement Establishment’s computer or device, operating system, internet connection or telephone account, settings, IP address and device locational data, and transaction data, as well as personal information as described above. GFD may collect, use, disclose and retain this information in relation to the identified purposes, as well as to determine which settings are appropriate for the user’s computer system, to provide or enhance digital functionality and for security purposes, internal analysis and reporting. The Member Bereavement Establishment or Client may withhold consent to the collection, use and disclosure of personal information about itself or its Clients, however in some cases this may prevent utilization of the digital channel to apply for or use a service or to communicate with GFD, or may reduce the functionality of that channel.

Consent to Collect, Use and Disclose Personal Information

When a Client or Member Bereavement Establishment agree to obtain services from GFD the Client and the Member Bereavement Establishment agree that GFD may collect, use and disclose the information for the identified purposes.

Refusing or Withdrawing Consent

Subject to legal, regulatory and contractual requirements, Clients and Member Bereavement Establishments may refuse to consent to GFD’s collection, use or disclosure of information or may withdraw consent to further collection, use or disclosure of personal information at any time in the future upon the provision of reasonable notice. Depending on the circumstances, withdrawal of such consent may prevent GFD from providing, or continuing some or all of its services.

There may be legal, regulatory and contractual requirements that may prohibit the withdrawal of consent. Neither Clients nor Member Bereavement Establishments can refuse the collection, use and disclosure of information required by regulators, tax authorities, or third party service providers or information that is essential for the provision of the services or which is required by regulators.

GFD will act on your instructions as quickly as possible but there may be certain uses of the information, such as tax and regulatory reporting, that cannot be stopped or cannot be stopped immediately.

Retention

GFD maintains personal information for so long as is necessary to fulfill the identified purpose for which it was collected, used and disclosed and for reasonable business record retention, legal and regulatory reporting requirements.

Security

GFD undertakes reasonable and appropriate methods, including electronic and physical security measures, to protect and safeguard personal information from unauthorized access, use, and disclosure, however, GFD cannot provide complete guarantees to the protection of personal information.

Access to Information

A Client or a Member Bereavement Establishment on behalf of a client, may file an access request with GFD in respect of personal information about the Client which has been collected, used and disclosed by GFD. Where the Member Bereavement Establishment seeks access on behalf of the Client an executed consent to disclose information is required.

Access requests should be specific about the type of information required so as to ensure that the access request may be reasonably fulfilled. GFD will respond within a reasonable time and will advise what personal information GFD has, what it is being used for, and to whom it has been disclosed. If GFD is unable to provide access to some or all of the information GFD will advise as to why the access request cannot be fulfilled. Any and all third party information will be redacted from the information requested.

GFD may charge a reasonable fee in respect to processing the access request. However, GFD will not issue such fee without first advising of the cost of providing the requested information and giving the requesting party the option of withdrawing the request.

Access requests may be submitted to:

Privacy Officer
Guaranteed Funeral Deposits of Canada
PO Box 100 Lakeshore W PO
Oakville, ON L6K 0A3

Information About Member Bereavement Establishments

GFD values and respects its relationship with its Member Bereavement Establishments. Any and all information provided to GFD about a Member Bereavement Establishment, including the names of its Clients, information about its business, clients, contractual arrangements, marketing or other business information provided to GFD will be kept strictly confidential and will not be disclosed except as may be required by law.

Further Information

GFD reserves the right to change this privacy statement at any time. We will post any updated versions of the privacy statement on our website. It is your responsibility to review this privacy statement from time to time to ensure that you are aware of any changes made. By continuing to use our services, you consent to this privacy statement and any updates that may be posted from time to time.