11.3 Disclosure of Information

Disclosure Policy

HOOPP has a policy to ensure that there is no improper disclosure of Plan and member information, and to ensure that disclosure practices within HOOPP are consistent.

Employer Requests

As a general rule, HOOPP will provide you with any information or documentation that you have submitted to HOOPP for an active member that you need to assist you in your role in administering the HOOPP benefit. You can request any Plan documents you require to administer HOOPP. Investment, member, and corporate information may be disclosed if the request is reasonable, and confidentiality issues have been addressed.

Examples of documentation that HOOPP can disclose to employers:

• Copy of your organization’s participation agreement

• Member-specific information or data that you have submitted to HOOPP

• Copies of any correspondence or emails between HOOPP and your organization

• A copy of HOOPP’s Plan Text

• Information included in HOOPP’s Annual Report

Member Requests

Members can request Plan documents, investment information, and corporate information provided the request is reasonable and consistent with their rights under the Plan terms and pension legislation, and confidentiality issues have been addressed.

Examples of documentation that can be disclosed to members:

• Enrolment forms, termination and retirement notices

• Termination, retirement and buyback option and election forms

• Beneficiary designation and change of information forms

• Written authorizations and power of attorney documents

• Any medical information submitted to apply for disability benefits

• Any correspondence that HOOPP sent to a member or received from a member

• Tax forms, such as any T4A slips issued by HOOPP or TD1 forms

• Correspondence received by a third party acting on behalf of a member (i.e. a member’s lawyer, accountant, doctor, financial advisor, spouse etc.)

HOOPP will assess any other member requests for information on a case by case basis, but will generally not disclose internal documents or employer correspondence until required to do so. HOOPP does not release copies of Independent Medical Examination (IME) reports directly to members but HOOPP will send a copy to a member’s physician upon request.

Third Party Requests

In general, with the member’s consent, HOOPP may disclose information that it would share directly with a member to a third party that the member has authorized HOOPP to share it with. This can include a member's lawyer, accountant, power of attorney or other authorized agent. HOOPP will only disclose information with the member’s consent and only to the extent that the member has provided HOOPP with authorization to share the information. A letter of authorization for this consent is available on HOOPP Connect or by contacting Member Services. However, members may also prepare and submit their own request in writing. If you receive requests about disclosure to third parties, refer the member to HOOPP for more information.