Data Protection Notice

We know your personal information is important to you and it is important to Canada Life too. This Privacy Notice tells you what we use your personal information for and explains your rights around how we use it. Please read this Privacy Notice to understand how and why we use your personal information.

If you give us someone else’s personal information, please make sure you have their permission and make them aware of this Privacy Notice, as it also applies to them.

Why is protecting personal information so important?

We take the security of your personal information very seriously. We implement technical and organisational measures to ensure a level of security appropriate to the risk to the personal information we process. These measures are aimed at ensuring the on-going integrity and confidentiality of personal information. We evaluate these measures on a regular basis to ensure the security of processing.

This Privacy Notice explains how we use personal information which we collect about individuals in relation to our products and services. In this notice, ‘personal information’ means ‘personal data’ under UK data protection law. This is any information that identifies a person or could be used to identify them.

Who are we?

This Privacy Notice is issued on behalf of the Canada Life group companies within the United Kingdom, Isle of Man, and the Republic of Ireland. When we mention “Canada Life”, “we”, “us” or “our”, what we mean is the relevant company in the Canada Life group that processes your personal information.

These companies are:

  • Canada Life Limited,
  • Canada Life International Limited,
  • CLI Institutional Limited,
  • Canada Life International Assurance (Ireland) DAC,
  • Canada Life Asset Management Limited,
  • Canada Life European Real Estate Limited,
  • Stonehaven UK Limited,
  • Canada Life Platform Limited,
  • Canada Life International Services Limited (CLIS),
  • CLFIS (U.K.) Limited.

Each Canada Life group company that processes your personal information is responsible for looking after it in accordance with this Privacy Notice. The Canada Life group company (or companies) that provides the policy will be the main company responsible for your personal information, known as the Controller. Please check the documentation that we provide to you for details of the specific Canada Life company acting as Controller of your personal information. If you are unsure, please contact us. We may share your personal information with other companies in the Canada Life group in accordance with this Privacy Notice.

How do we interact with you?

You may interact with Canada Life in any one or more of the following capacities:

  • a policyholder
  • joint policyholder
  • employer policyholder
  • trustee
  • insured person
  • professional adviser
  • beneficiary
  • next of kin
  • personal representative
  • informant
  • occupier
  • executor claimant
  • member

No matter in which capacity you interact with Canada Life, you will be referred to as ‘you’ or ‘your’ in this Privacy Notice.

We protect your information by making sure that we treat any of your personal information in accordance with the applicable laws and regulations in any relevant jurisdiction relating to privacy or the use or processing of personal information of each respective Canada Life entity.

This includes:

  • any personal information you provide us with directly
  • personal information about you that’s provided by another party
  • personal information you provide us with about someone else

 

1. Personal information

It’s important to understand why we collect your personal information and how it’s used.

What is personal information?

Personal information is information that either on its own or combined with other information allows an individual to be identified. Examples of personal information include your name and address, as well as more sensitive information such as your health and financial records.

Where applicable, this includes information about other people such as your spouse, common-law partner and children.
How do we collect personal information?

We collect your personal information in three ways:

Directly from you – throughout our relationship with you we may collect personal information through paper or online applications for products and services, on the telephone, through online chat, or through email.

From other people and organisations – depending on the products and services you have with us; we may also collect your personal information from others (please see the table below).

From your use of our websites, customer/adviser portals and mobile applications (collectively Online Services) – when you visit us via Online Services, we’ll also collect your personal information using cookies. Cookies make your next visit easier by storing your preferences. You can control how we collect and use your personal information by visiting our cookie consent manager.

When we collect personal information, we’ll only collect what we need, and we’ll tell you why we need it. When applicable, the personal information we collect may also include information about your spouse, common-law partner, dependants, and beneficiaries. We’ll ask you to confirm their consent for us to collect and use this information, and to communicate with you about them.

Appointed Representatives
We recognise that we will need to communicate with appointed legal representatives and/or attorneys where the contractual formalities permit third parties to act in your interests.

An attorney can be either a power of attorney or lasting power of attorney. This is a trusted person who you’ve appointed to handle your affairs in the event that you can’t.

A legal representative is someone qualified who can represent you in legal matters such as a:

  • Solicitor
  • Barrister
  • Chartered legal executives

If the matter relates to someone who is deceased, then there may be a personal representative or executor.

 

Third Parties

Reasons why

Insurance brokers or financial advisers

• To quote or set-up a policy/product

• Third parties involved in the relevant insurance policy, product or claim

Other insurers or legal advisers

• Third parties involved in the relevant insurance policy, product or claim

Appointed representatives

• We will collect information from appropriately appointed representatives acting on your behalf

Healthcare providers and medical practitioners

• To assist with claim assessment

Canada Life group companies

• May provide information in relation to other products you hold, previous claims, policies or quotes

Employers

• They provide their employees’ personal information for workplace protection products

Pension trustees

• Will provide us with membership data to allow us to accurately price, provide appropriate quotations, policy terms and administer our products

Other policyholders

• A Policyholder may need to share relevant information about associated persons i.e. dependants, occupiers & beneficiaries

Companies who work on our behalf

• Companies performing services for Canada Life may collect and share your personal information

Data brokers, e.g. Experian and

LexisNexis, and (on rare occasions) Private Investigators, Data analysts and data service providers who help develop our products and pricing

• Identification, verification and validation

• To assist with claim assessment

• Third-party data suppliers help us keep our information accurate, such as identifying deceased individuals or updating contact details for those who have moved

Research agencies, providers of research services and insight consultancy

• Customer feedback surveys

• Qualitative and Quantitative customer insights

Financial crime detection agencies, databases and sanctions lists, including the Insurance Fraud Bureau

• To meet our legal and regulatory obligations

Government agencies and regulatory bodies, including:

• Police

• Courts

• National Crime Agency

• Department for Work and Pensions (DWP)

• Companies House

• National Health Service (NHS)

• HM Revenue & Customs (HMRC)

• To meet our legal and regulatory obligations

Publicly available sources

•  To assist with policy administration

•  To assist with claim assessment

 

What types of personal information do we collect?

There are multiple types of personal information that we collect and hold, from health and lifestyle data to product data. This personal information can be provided by you or third parties. Here is a breakdown of all the categories of personal information that we might collect and hold.

Contact and lifestyle data This includes:

  • General data such as your name, date of birth and marital status.
  • Contact data including your address, contact telephone number and email address.
  • Accurate contact data which refers to information that you have changed but not updated us about, such as your address or email address. This data may be used to ensure that we have a complete understanding of your product holding and to provide you with communications about your products. It will not be used for direct marketing purposes unless it was collected by the third party expressly for that purpose and always in accordance with data protection law.
  • Behavioural data such as your general interests, including how often and where you travel. This also includes demographic data and behavioural data, such as your purchase history.
  • Appearance data including your gender, age, height and weight.
  • Health and lifestyle data including details about your alcohol consumption, whether you currently smoke or have ever smoked/use tobacco products and your body mass index. For further information see Special Category Data.

Financial data

This includes:

  • Claims data including any information gathered under an insurance claim. This refers to your information or someone else relating to the claim, such as your next of kin or another relative, your legal representative or other relevant third parties.
  • Product data such as quotes, details about your policy, schemes, claims and any other information relevant to your product.
  • Fraud, money laundering and sanctions data which we obtain through our own investigations. We carry out checks using publicly available sources such as newspapers and social media sites, as well as checking fraud databases and sanction lists.
  • Financial data including bank account details, your income, tax bands and liabilities, assets and liabilities.

Customer data

  • Data relating to vulnerable circumstances such as information about health, life events, resilience, capability and any adaptations/support requested. Whether your vulnerable circumstance is permanent or temporary, this information helps us to identify how we can better support your needs.
  • Telephone recordings and online chat transcripts refers to information obtained during recordings of telephone calls with our customer representatives and call centres.
  • Communication preferences and customer feedback including communication preferences, responses to surveys, complaints and details of your customer experience.
  • Testimonials and Feedback such as information provided to us based on your experience, relating to products and services provided.
  • Social listening – the activity of monitoring and analysing social media content that is related to, or relevant for, our product or brand, as a means of improving customer outreach and product development.

Employment data

This includes your employment information such as your salary, job title, employment status and employment history.

Data collected from your devices Canada Life uses cookies and similar tracking technologies to ensure that our websites and applications work properly, and to improve your experience of our website but not for the purposes of sales and marketing. We may collect your IP address, location, mobile device number, device type, operating system, browser, MAC address, and account activity obtained through our use of cookies. Please see our Cookie Policy for more information.

Data relating to children

There are some circumstances in which we collect personal information about children. For example, when they are covered by a policy, a child’s critical illness claim, a dependant’s pension claim, or when they are beneficiaries of a policy in trust.

Special Category Data

Sometimes we’ll request or receive personal information that is sensitive, and we call this “Special Category data”. This is information relating to your:

  • Health
  • Genetic or biometric data
  • Sex life
  • Sexual orientation
  • Racial or ethnic origin
  • Political opinions
  • Religious or philosophical beliefs and trade union membership.

It also covers:

  • Criminal offence data, including information about criminal activity
  • Allegations (including those unproven) Investigations, proceedings and penalties.

We request some sensitive information because we need it to help us with our investigations. For example, to investigate a claim made under a critical illness or income protection policy, we’ll need to ask you to provide details of your health condition. We know how sensitive this personal information is, so protecting it is a top priority. The types of Special Category data we hold and process, where relevant, includes:

  • Health data such as details of existing and previous physical or mental health conditions, test results, medical diagnoses and treatment given, prescriptions and personal habits, including smoking or consumption of alcohol. If we receive any genetic data from your treating medical professionals, we don’t actively process it, but we will hold it and keep it safe.
  • Criminal data including details of any convictions in relation to fraud.
  • Other sensitive data that we might need where relevant. For example, we may process information relating to your religious beliefs in limited circumstances.

In most cases we will seek your explicit consent to process special category data, however, in some circumstances this is not always possible. Where we are unable to obtain your explicit consent to process special category data, we will identify an appropriate basis, document our reasoning and comply with our regulatory and legal responsibilities.

Gathering personal information from public spaces We will occasionally use images, video and audio of employees, contractors and participating stakeholders in connection with its business activities, and will give all affected employees, contractors, professional advisers, members and policyholders, reasonable notice of the collection of such personal information. This personal information may be sent to or included in different formats, including but not limited to email, websites, social networks and printed materials.

How do we use your personal information?

We only use your personal information when it’s necessary and there are many reasons that we may need to. We’ve provided an explanation of all the purposes below.

Products and services

  • We communicate with you and other individuals regarding information relating to your products and services and helping you to exercise your Data Rights, see Your Rights, Section 9 below.
  • We carry out assessments and make decisions including whether to provide you with our products and services and on what terms.
  • We provide you with our products and services including administering your policies, making changes where requested or necessary, claims assessment, settlement and dispute resolution and the provision of our technologies.
  • We manage relationships with third parties such as insurers, reinsurers, brokers, financial advisers and service providers.
  • We prevent, detect and investigate fraud and other crime by carrying out fraud, sanctions and anti-money laundering checks. For further information see Financial Crime, Section 4 below.
  • We carry out data analysis to ensure data accuracy and quality and for insurance risk modelling and product and pricing refinement. For further information see Profiling and Data Analysis, Section 5 below.

Data management

  • We manage complaints to allow us to respond to any current complaints or challenges you or others might raise later. We do this for internal training and monitoring purposes and to help us to improve our complaints handling processes. We may need to forward details about your complaints, including your personal information, to the appropriate authorities, such as the relevant ombudsman.
  • We manage our business operations by carrying out internal audits, quality assurance and training, financial analysis and accounting, and performing administrative tasks in connection with the services we provide.
  • We manage commercial risk by taking out and maintaining appropriate insurance and reinsurance.

Abiding by legal and financial regulations

  • We comply with applicable legal, regulatory and professional obligations by cooperating with regulatory bodies such as the UK Financial Conduct Authority (FCA), UK Prudential Regulation Authority (PRA), Isle of Man Financial Services Authority (FSA), Central Bank of Ireland (CBI), Information Commissioner’s Office (ICO) and government authorities.
  • We establish, enforce and defend our legal rights or those of third parties by enforcing our terms and conditions, pursuing available remedies and limiting our damages.

Customer Experience

  • We improve our products and services, provide staff training and maintain information security, including by recording and monitoring telephone calls.
  • We review our data to help us better understand our customers and improve our customer engagement. By understanding our customer’s journeys, conducting customer insight analysis, market research and focus groups, including customer segmentation, gathering customer feedback, creating digital content / customer support and engagement touchpoints and customer satisfaction surveys, we can seek to improve our processes and services.
  • We identify when our customers may need additional support to help us better meet your needs and to comply with regulatory guidance about how we meet your needs. We might identify this through our own interactions with you, infer this from your personal information, or be told by a third party.
  • Marketing Activity only where express consent is obtained, Testimonials and Feedback may be used for promotional & marketing activity.
  • Analysis helps us to improve and/or update our processes, products and services (which could include updates or changes to the models we use for pricing). The purpose of this analysis is not to make decisions about you directly, but to help us to update and/or improve our processes, products and services.

Risk assessment

  • We review actuarial pricing and mortality. The nature of our business is to provide investments, life and pensions cover, and critical illness & income protection employer-related group products. To do this, we need to use the personal information provided to carry out analysis of actuarial risks (risks of gains or losses), mortality and morbidity risks and pricing. This will be carried out in accordance with the Institute & Faculty of Actuaries’ data handling protocols. In some circumstances we use third party providers and / or software to support our analysis; where we rely on third parties we will undertake an assessment and share only data relevant for the purpose.

  • Archiving, scientific or historical research or statistical purposes – We may use data to improve risk modelling, develop new products/services, analyse long-term trends, and meet regulatory of public-interest obligations.

 Asset Management

  • Canada Life Asset Management Limited and Canada Life European Real Estate Limited process personal information to provide the services and assist the Customer in its activities relating to the sourcing, managing and the ongoing maintenance of assets under management. These services include but are not limited to:

  • making commercial loans available

  • investing in debt and securities (including fixed income securities); and/or

  • acting as a landlord and providing services in that capacity, so that we can provide investment solutions including, fixed income and real estate. We may obtain data from you from our website, from one of our partners (or the means identified below in the sharing personal information section of this notice) or from you directly (for example, if you contact us by telephone, in writing by post or email or in person). Telephone calls may be recorded for training and monitoring purposes, and to comply with applicable law and regulations. We collect information through “Cookies” to improve your experience of our website but not for the purposes of sales and marketing.

2. Our legal grounds for using your personal information

 

Third Parties

Reasons why

Performance of our contract with you or an employer

For the majority of our activities, we will rely on the performance of our contractual arrangements with you.

Processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract.

Your explicit consent (necessary)

You have given your explicit consent to the processing of those personal information for one or more specified purposes, where we are unable to procure, provide or administer insurance cover without this consent.

You are free to withdraw your consent by contacting our Data Protection Officer. However, withdrawal of this consent will impact our ability to provide insurance, products or pay claims.

Your explicit consent (optional)

You have given your explicit consent to the processing of your personal information for one or more specified purposes.

You are free to withdraw your consent, by contacting our Data Protection Officer.

For our legitimate business interests

Exceptionally, we may rely on our legitimate interests to process your personal information. When we do so, we will demonstrate compelling legitimate grounds for doing so.

This includes sending professional investors, advisers, re-insurers and institutional investors’ information about relevant products and events. With selected third-party suppliers, for the purpose of conducting statistical analysis.

Additionally, we will process your personal information to conduct customer research, including customer insight analysis, customer feedback, customer satisfaction surveys and focus groups.

To enhance our understanding of our customers and strengthen customer engagement, including through the use of analytics and profiling—such as making informed predictions and assumptions regarding your interests. We may use select third parties to help us.

To provide you with information about your products and services, including tools for managing and engaging with your products, such as digital apps. These are not marketing communications.

Where processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by your interests or fundamental rights and freedoms which require protection of personal information, in particular where you are a child.

Compliance with a legal obligation

Processing is necessary for compliance with a legal obligation to which we are subject.

In the public interest

Processing is necessary for the performance of a task carried out in the public interest.

Vital Interests

Exceptionally, we may rely on vital interests to process your personal information. When we do so, we will demonstrate compelling legitimate grounds for doing so.

 

3. Who we share your personal information with

Protecting your personal information is the most important responsibility for us.

We share personal information only on the basis of the purposes for which it was collected.

This notice is intended to illustrate the instances where personal information may be shared. However, we will share your personal information only for the limited and compatible purposes for which it was originally obtained.

When we have shared your personal information with other companies or bodies, we have taken appropriate steps to ensure that they will protect your personal information as well. 

Contractual clauses are in place between Canada Life and its group entities and external suppliers and are compliant with the GDPR, which ensures that personal information provided to Canada Life is processed in accordance with our instructions and the requirements of the GDPR.

Canada Life will continue to follow and apply all appropriate data protection legislation.

 

Service providers, including:

• Property Surveyors

• Conveyancing providers

• Funding providers

• Solicitors

• Pension providers

• Trustees

• Reinsurers

• Auditors

• Regulators

• Medical professionals

• IT providers

• Third-party research agencies and providers of market research services

• Debt recovery and insolvency services

• Exceptionally, private investigators

• Electronic identity verification services

• Financial Crime and Sanctions screening tools

• Credit reference agencies

• Administrators

• Service and software suppliers

These are companies who help us provide our services to you.

They assist with:

• Policy administration

• Claim assessment

• IT provision/data storage

• Reporting and analysis

• Security services

• Legal/audit advice

• Debt recovery/insolvency services

• Customer research

• Event management services

Companies who work on our behalf to provide products to you

We use some service providers to undertake work on our behalf, such as:

• Policy administration

• Claim assessment

Medical practitioners, such as GPs

Processing is necessary for the purposes of preventive or occupational medicine, for medical diagnosis, the provision of health or social care or treatment on the basis of EU or UK law or pursuant to contract with a health professional of who is under legal or professional obligations of secrecy.

Canada Life will share your personal information with your own doctor or relevant medical professionals for insurance related products.

Intermediaries, such as Independent Financial Advisors

Quotation requests and application forms will be shared within the Canada Life group of companies to provide professional advisers with product information which may be relevant for their client’s needs and requirements

Public and professional authorities/bodies (e.g.): HM Revenue & Customs (HMRC)

Regulators (e.g. FCA, PRA, FSA, CBI, ICO, and regional equivalents)

Police

Courts

Department for Work and Pensions (DWP)

Industry bodies

Landlords, tenants, borrowers and suppliers

For legal and regulatory requirements/obligations

 

4. Financial Crime

We use your personal information to detect and prevent fraudulent practices, fight financial crime and meet our statutory and regulatory responsibilities in relation to fraud, money laundering and other financial crime.

We may also use your personal information and details of our interactions with you to help us detect fraud, including if it is committed by financial advisers or to identify where you or a third party may be at risk of fraud or other financial crime.

To prevent, detect and investigate fraud, we may:

  • Conduct online searches from websites, social media and other information sharing platforms.
  • Use databases managed by insurance industry bodies, fraud detection agencies and other reputable organisations.
  • Share personal information and undertake searches with other third parties, including electronic identity verification services, screening for high risk or criminal activity, credit references agencies, other insurers, fraud prevention agencies, law enforcement agencies, private investigators, public bodies and our regulators (which include the FCA, PRA, FSA, CBI and ICO).

This will help us verify your identity and make decisions about providing you with our products and related services, such as paying claims, and trace debtors or beneficiaries.

If you give us false or inaccurate information and we suspect fraud, we’ll record this to prevent further fraud and money laundering, and this may be shared with other parties.

We can supply on request further details of the agencies and databases we access or contribute to and how this information may be used. If you require further details, please contact us.

5. Profiling and Data Analysis

We may use, and share your personal information to perform analysis, e.g. to help us to ensure data quality and accuracy, improve our business, train our machinelearning systems and ensure we’re appropriately pricing our products. The purpose of this analysis is not to make decisions about you directly, but your information, in combination with data relating to other customers and/ or data provided by third parties, will be used to conduct data analysis. This may help us to identify trends or better understand insurance risk factors which in turn mean that we price our policies effectively. Where possible we pseudonymise the personal information in order to perform this analysis. This means that we remove information from which you can be directly identified, e.g. your name and replace it with a pseudonym. We do this to maximise the security of your information.

6. Retention of your personal information

We will keep your personal information only for so long as is necessary and for the purpose for which it was originally collected. In particular, for so long as there is any possibility that either you or we may wish to bring a legal claim, or where we are required to keep your personal information due to legal or regulatory reasons. The length of time personal information is retained varies according to the nature of the relationship and the purpose for which the information is held. Each Canada Life department has a departmental ‘Records Retention and Disposal Guide’ (RRDG), which defines the length of time that records processed by that department are retained before deletion.

7. International Transfers of your personal information

Given the global nature of our business, we use third party suppliers and outsourced services (including cloudbased

services), which will require transfers of personal information outside of the [UK, IOM or Ireland] EEA and countries that have [a UK, IOM or Ireland] an EU adequacy decision.

In doing so, we ensure there are contractual arrangements in place with those organisations who have organisational and technical measures to protect your personal information.

We will only transfer data outside of the [UK, IOM or Ireland] EEA and countries that have an [UK, IOM or Ireland] EU adequacy decision if there is an appropriate legal basis for doing so. Although this list may change from time to time, we may transfer personal information to the following countries outside of the [UK, IOM or Ireland] EEA and countries that have [a UK or] an EU adequacy decision:

  • Barbados
  • Bermuda
  • Cayman Islands
  • Hong Kong
  • India
  • USA

Communication with customers and stakeholders who are based outside of the UK, IOM or Ireland will necessitate correspondence in any global country (depending upon their location) for the purposes of our activities.

In relation to any claims commenced whilst abroad, communication with medical professionals, authorities, tax offices, embassy staff and surveillance will necessitate correspondence in any global country (depending on the location of the claimant) for the purposes of our activities. Contractual clauses in place between Canada Life and its group entities and external suppliers are compliant with the GDPR, which ensures that personal information provided to Canada Life is processed in accordance with our instructions and the requirements of the GDPR. Canada Life will continue to follow and apply all appropriate data protection legislation.

8. EU GDPR Designated Representative

The General Data Protection Regulation (‘EU GDPR’) requires that all entities processing the data of EU citizens that are not established in an EU member state designate in writing a Representative in the EU to be addressed in addition to or instead of that entity by EU citizens on all issues related to data processing.

In order to meet the above requirement, all the Canada Life entities listed above that process the personal information of EU citizens but are not established in an EU member state have designated Canada Life Irish Holding Company Limited, an Irish registered entity within the Canada Life group, as its Representative. The Representative may also be called upon to cooperate with competent supervisory authorities with regard to ensuring compliance with EU GDPR.

9. Your Rights

You may have the right to require us to:

  1. Provide you with further details on the use we make of your personal information or your special categories of data.
  2. Provide you with a copy of the personal information that you have provided to us or which we hold.
  3. Update any inaccuracies in the personal information we hold.
  4. Delete any special category of personal information or personal information for which we no longer have lawful grounds to use.
  5. Cease processing of your personal information that is based on consent, by withdrawing your consent to that particular processing.
  6. Cease any processing based on legitimate interests’ grounds, unless our reasons for undertaking that processing outweigh any prejudice to your data protection rights
  7. Restrict how we use your personal information whilst a complaint is being investigated.
  8. Provide you with a copy of your personal information for you to reuse across other services.

Important –

Please be aware that the right to deletion (4) is not absolute and has exceptions. We may not be able to comply. For example, we can only erase some or all of your personal information if it is no longer necessary for the original purpose.

The right to have a copy of your personal information (2) only entitles you to a copy of material which meets the definition of personal information. You are not entitled to other information which may or may not be stored alongside your personal information.

If you ask us to pause or cease processing your personal information (5 or 7) and you have a current product application or claim underway, we will not be able to complete the application or claim assessment.

In certain circumstances, we may need to restrict the rights listed above in order to safeguard the public interest (e.g. the prevention or detection of crime), our interests (e.g. the maintenance of our legal responsibilities) and for the performance of our contract with an employer who is the policyholder for employer-related products and services.

We reserve the right to amend or modify this DPN at any time and in response to any changes in applicable Data Protection and privacy legislation. If we decide to change our DPN, we will post these changes on our website so that you are aware of the information we collect and how we use it at all times.

10. Group Insurance Products

Group Insurance products are policies taken out by an employer to provide cover for its employees. We need certain personal information to enable us to administer these insurance policies.

Canada Life requests basic personal information to be provided by an employer for the administration of a Group Insurance policy.

In addition, for pricing purposes, we will also require details of long-term absentees, current and previous claimants, and medical underwriting decisions.

The relevant Data Protection Act (The Act) permits appropriate information about employees to be provided by an employer to an insurer without individual consent. This includes details of long-term absentees, current and previous claimants, and medical underwriting decisions. The Act allows an individual to specifically withdraw their consent from their employer so that their personal information will not be passed to us. If an individual does withdraw their consent, Canada Life will not be able to provide cover for that individual.

Canada Life will not use this personal information to market directly to individuals or pass this personal information to other parts of our company in order to market directly to individuals.

There are circumstances where we will require more information from you, such as medical details to assess a claim or underwrite a particular benefit. In these circumstances, we will ask for your explicit consent to process this personal information.

We use an underwriting engine to process some applications and quotations which will use an element of automated decision making. This does not apply to claims assessment or to medical underwriting

Medical Information in employer-related products and services

Canada Life will not share your medical information with anyone other than yourself, or your treating medical professional(s), without your consent. This includes your employer, spouse, other relatives, friends or your legal advisor. In some circumstances, it may be appropriate to advise your employer about your medical information, for example, to recommend alternative supportive therapy. However, Canada Life will obtain your consent in such circumstances.

Non-Medical Information in employer-related products and services

Canada Life will not share non-medical information concerning you with your spouse, other relatives, friends or your legal advisor unless you provide your consent to us in writing. Non-medical information about you will be shared with your employer only for lawful policy and claim administration purposes.

For employer-related products and services only, some medical information related to underwriting decisions and non-medical information about you necessary for lawful policy and claim administration purposes will be shared with your employer.

11. Contact details for Data Protection bodies and Canada Life

Data Protection Officer (DPO) or Compliance Officer If you have any questions, or complaints, in relation to our use of your personal information, you should first contact the appropriate DPO or Compliance Officer, on the details below:

For Canada Life Limited, Canada Life Asset Management Limited, Canada Life European Real Estate Limited, Canada Life Platform Limited and Stonehaven UK Limited: PO Box 285, Huddersfield, HD8 1GG or by email at: dpo@canadalife.co.uk

For Canada Life International Limited, CLI Institutional Limited or Canada Life International Services Limited:

Canada Life House

Isle of Man Business Park, 

Douglas

Isle of Man IM2 2QJ or by email at: riskandcompliance@canadalife.co.uk

For Canada Life International Assurance (Ireland) DAC:

Irish Life Centre, Lower Abbey Street

Dublin 1, Ireland

or by email at: CLIAI_Compliance@canadalifeint.ie

In the event that you are dissatisfied with our response, you have the right to take the matter up with the appropriate national regulator whose addresses are:

England

Information Commissioner’s Office 

Wycliffe House 

Water Lane 

Wilmslow

Cheshire 

SK9 5AF

Telephone: 0303 123 1113 (local rate) or 01625 545 745 (national rate) Email: casework@ico.org.uk

 

Scotland

The Information Commissioner’s Office

6th floor, Quartermile One

15 Lauriston Pl

Edinburgh

EH3 9EP

Telephone: 0303 123 1115

Email: Scotland@ico.org.uk

 

Wales

Information Commissioner’s Office

2nd Floor, Churchill House

Churchill Way

Cardiff

CF10 2HH

Telephone: 0330 414 6421

Email: wales@ico.org.uk 

 

Northern Ireland

The Information Commissioner’s Office 

10th Floor

Causeway Tower

9 James Street South

Belfast

BT2 8DN

Telephone: 0303 123 1114

Email: ni@ico.org.uk

 

Ireland

Data Protection Commission

6 Pembroke Row

Dublin 2

D02 X963

Ireland

Telephone: +353 1 7650100

Email: info@dataprotection.ie

 

Isle of Man

Information Commissioner

P.O. Box 69

Douglas

Isle of Man

IM99 1EQ

Tel: +44 1624 693260

Email: ask@inforights.im

 

This DPN is dated 1 July 2026. Any future updates will be made available as described above.

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