Respecting your privacy in Canada

We may collect personal information about you by paper, electronically or verbally. You can find examples of personal information we collect and how we use it in our Global Privacy Statement. If you contact us by phone, we may record the call for monitoring, training and quality improvement. 

We collect only the personal information we need. We collect your information directly from you or with your permission, from third parties. These third parties may include medical professionals, other insurers and institutions. They may have relevant information to support our business processes such as administration, underwriting and claims adjudication. If you're a member of a group plan, your employer or plan sponsor may provide information about you necessary to administer the group plan. We use the services of the Medical Information Bureau (“MIB”), as an additional source of information to evaluate life and health insurance applications.

We may also collect publicly available personal information to help us update incomplete and outdated information on our files. We use this information to contact or locate our clients such as policyholders, accountholders, annuitants, group plan members, beneficiaries, or shareholders.

We’ll keep your personal information only as long as we need it for the intended business purpose or as required by law. We may retain your information after your relationship with us ends to meet regulatory requirements. These relate to Canadian limitation periods, tax, employment and other applicable laws.

Once the retention period has expired, we’ll securely dispose of or anonymize your information. Anonymization means that we’ll remove or modify any identifying data so that it can’t be linked to your identity.

We collect, use and disclose your personal information with your permission for the purposes we identify to you or as required by law. We identify our purposes in our Global Privacy Statement and in this Policy.

Our applications and forms include sections where we ask for your authorization to collect, use and disclose your personal information. Please take the time to read those sections carefully. We also provide you with information and may ask for your authorization through the terms of use on some of our Digital Properties.

Your permission may be express, when you agree in writing, verbally or with an electronic signature. Where appropriate, we rely on your implied consent to use your information for certain purposes based on disclosures in our Global Privacy Statement, this Policy and other interactions we have with you. 

You may withdraw your permission to collect, use and disclose your personal information at any time. This request is subject to legal and contractual restrictions and reasonable notice. In some cases, without your permission, we may be unable to provide you with the products or services you requested. Examples of such services include completing the underwriting for an insurance product or assessing your claim.

Marketing of new products and services

We may occasionally inform you of other financial, health and wellness products and services that we believe meet your changing needs. If you don’t wish to receive these offers, let us know by calling 1 877 SUN LIFE (1 877 786 5433) and we’ll update our records. If you have access to our secure client website or mobile app, you can change your contact and marketing preferences there. You can also use the unsubscribe link included in our commercial electronic messages.

Our employees can access your personal information only if they need it to provide you with products and services, or support our business operations. These employees have information technology, administration, underwriting, claims adjudication, finance and other professional roles. 

Our agents and distribution partners have access to your information needed to support product sales and account management activities. We may also grant access to your personal information to authorized third-party service providers who need it to provide services to us. If you’re a member of a group plan, your plan sponsor, benefits administrator or employer may have access to information necessary to support plan administration.

Our employees and any third parties with direct access to our systems take mandatory security and privacy training and commit to protecting the confidentiality of your personal information. 

To deliver on our Purpose of helping our clients achieve lifetime financial security and live healthier lives, we’re committed to constant innovation. This requires developing or acquiring new technology and use of data. 

When we use personal information for analysis and automation, we ensure the results are fair and unbiased. We’ll inform you if we make a material decision based exclusively on automated processing of your information. Upon request, we’ll share:

• the personal information used to make the decision, and
• the main factors that led to the decision

You can contact us by e-mail at privacyofficer@sunlife.com to provide additional information to challenge and correct that decision, as appropriate.

Some examples of how we use data to improve our products and services:

• Our digital assistant Ella displays messages related to your products and services. Ella captures additional information you may provide to make future messages more relevant.
• Our marketing teams use demographic and other information we know about our clients. That includes external aggregate data at postal code level, to create market segments and provide relevant offers.
• We continuously improve our underwriting processes using relevant medical information of existing and new clients. That results in faster approvals and fewer medical exams, in some cases. 
• We enable the use of external digital assistants if you wish to use them and connect with your Sun Life account. 
• We analyze information that we collect through our Digital Properties with other information we have about you. This ensures the best possible experience in your interactions with us. 
• We use insights from your interactions with us to be proactive in our service, prevent escalated complaints or facilitate contact with the right advisor. 
• We help answer frequently asked questions about our products through the Sun Life GO Chatbot.

In some cases, we may share your personal information with members of the Sun Life group of companies and external third parties that provide services on our behalf.

We require that these individuals and organizations comply with applicable privacy laws, regardless of where they are located. They do so in a manner that is consistent with our privacy policies and practices.

The third parties provide us with the following services:

• administration, claims and underwriting support
• distribution of products
• printing, mail and fax services
• marketing, surveys and market research
• events and meetings platform management
• regulatory compliance and fraud prevention
• records storage and destruction
• information, software, consulting and IT support
• reinsurance, medical, dental and emergency travel services
• stock transfers, recordkeeping, trading and settlement
• actuarial valuation, fund accounting, risk and investment analysis

New and innovative partnerships

Lumino Health Virtual Care, powered by Dialogue, connects Sun Life clients with virtual health care services. It facilitates appointments with health care providers and provides access to health resources. With your consent, we collect, use and disclose only information required to provide the service.

We partner with other companies to leverage their technology and data. This collaboration improves our product offering and enhances our services. 

Examples of how we use third party platforms and data sources:

• increase engagement with the general public and personalize client experience through health rewards apps 
• gather lifestyle and wellness information for product research and development through our partners in the Diabetes Solutions programs
• enable one-stop planning services and financial account consolidation services 
• understand general public demographics and how they correlate with our client base, using aggregate data for age, income, education, and other similar data from external data sources
• gather high level data to understand and analyze how engaging services of a mental health coach correlates to improved mental health and better claim experience
• facilitate digital data collection and electronic signatures on forms and documents 
• collect underwriting evidence from labs, medical professionals and underwriters, including electronic paramedical forms.

Sometimes this information is personal and linked to an identifiable individual. In those cases, we provide disclosure about the collection and the subsequent use. 

You can send us a written request to find out whether we hold any personal information about you. You can request to review that information and ask about how we collect, use or disclose it. We may not be able to provide you with all the information you request, depending on the circumstances. Sometimes, when we obtain medical information about you from a third party, we may need to release this information only through your physician.

You can submit requests to access your personal information by e-mail at privacyofficer@sunlife.com. If you authorize a third party to make a request on your behalf, we need your written consent to release your personal information to the third party. 

If you believe that any information we have about you is incorrect or incomplete, you may contact us and request to update our records. If you show that your personal information is inaccurate or incomplete, we’ll make the necessary changes, as appropriate.

If you feel we haven't dealt with your request to your satisfaction, you can contact the Problem Resolution Team. They'll engage with our client support, legal and privacy teams, as needed, to ensure we address your concerns.

You may contact Sun Life’s Privacy Officer for Canada to inquire about our privacy policies and practices. 

If you have a concern or complaint about how we handled your personal information, you can contact the Privacy Officer by: 

• e-mail at privacyofficer@sunlife.com, 
• phone at 416-408-8850, or
• mail at:

Privacy Officer, Sun Life 

1 York Street, Toronto, Ontario

M5J 0B6 Canada 

We investigate all privacy complaints and will explain our complaint handling procedure to you. If you remain dissatisfied with our response, we’ll let you know what other options may be available.