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Registered Deferred Income and Savings Plans Program

Legislative Policy and Regulatory Affairs Branch
Registered Plans Directorate

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Overview & Privacy Impact Assessment (PIA) Initiation 

Government institution

Canada Revenue Agency

Government official responsible for the PIA

Soren Halverson
Assistant Commissioner
Legislative Policy and Regulatory Affairs Branch

Head of the government institution or Delegate for section 10 of the Privacy Act

Anne Marie Laurin
Director General
Access to Information and Privacy Directorate
Public Affairs Branch

Name of program or activity of the government institution

Registered Plans

Standard or institution specific class of record:

Registered Deferred Income and Savings Plans 
CRA LPRAB 117

Standard or institution specific personal information bank:

Registered Deferred Income and Savings Plans
CRA PPU 226
TBS Registration Number: 20090532

Legal authority for program or activity

The legislative authority for the Canada Revenue Agency’s Registered Deferred Income and Savings Plans Program is found in:

Registered pension plans: Sections 147.1 to 147.4 of the Income Tax Act, and Parts XLIX, LXXXIII, LXXXIV, and LXXXV of the Income Tax Regulations.

Deferred profit sharing plans: Section 147, Parts X and X.1 of the Income Tax Act, and Parts XLIX, LXXXIII, and LXXXIV of the Income Tax Regulations.

Registered education savings plans: Section 146.1, and Parts X.4, X.5, and XI.01 of the Income Tax Act, and Part XLIX of the Income Tax Regulations.

Registered disability savings plans: Section 146.4, subsection 160.21(1), Part XI.01 of the Income Tax Act, and Part XLIX of the Income Tax Regulations.

Supplementary unemployment benefit plans: Section 145 of the Income Tax Act.

Registered retirement savings plans: Section 146, subsection 160.2(1), and Parts X.1 and XI.01 of the Income Tax Act, and Sections 214, 214.1 and Part XLIX of the Income Tax Regulations.

Registered retirement income funds: Section 146.3, subsection 160.2(2), and Part XI.01 of the Income Tax Act, and Section 215 and Parts XLIX and LXXIII of the Income Tax Regulations.

Registered investments: Part X.2 of the Income Tax Act and Part XLIX of the Income Tax Regulations.

Tax-free savings accounts: Section 146.2 and Part XI.01 of the Income Tax Act, and Section 223 and Part XLIX of the Income Tax Regulations.

Pooled registered pension plans: Section 147.5 and Part X.1 of the Income Tax Act, and Section 213 of the Income Tax Regulations.

First home savings accounts: Section 146.6, subsection 160.2(2.3), and Part XI.01 of the Income Tax Act, and Section 219 and Part XLIX of the Income Tax Regulations.

Advanced deferred life annuities: Section 146.5 and Part XI of the Income Tax Act, and Section 216 of the Income Tax Regulations.

Section 61 of the Canada Revenue Agency Act provides the legislative authority for the Canada Revenue Agency to enter into contracts, agreements, and arrangements with other governments, organizations, and agencies.

Summary of the project, initiative or change

Overview of the Program or Activity

Canadians can be members of one or more of the eleven registered deferred income and savings plans by way of employment, personal savings, or both. These eleven plans include:

Submitters

To set up a plan, fund, or account, a submission must be made to the Canada Revenue Agency.

Submitters differ by type of registered deferred income and savings plan. For registered pension plans, deferred profit sharing plans, supplementary unemployment benefit plans, and pooled registered pension plans, the submitter is either the plan sponsor (employer), plan administrator, a consulting firm, insurance company, or trust company. For registered education savings plans, registered disability savings plans, registered retirement savings plans, registered retirement income funds, tax-free savings accounts, and first home savings accounts, the submitter is an insurance company, trust company, bank, or credit union. For registered investments, the submitter is a corporation or trust.

Submitters can file some forms or returns for registered deferred income and savings plans electronically.

Specimen Plans

Submitters of certain registered deferred income savings plans must send a draft specimen plan to the Canada Revenue Agency before they can sell products under that specimen. The purpose of a specimen plan is to simplify the registration process for the plan, account, or fund. Submitters must use specimen plans for registered education savings plans, registered disability savings plans, registered retirement savings plans, registered retirement income funds, tax-free savings accounts, and first home savings accounts. Some registered pension plans and deferred profit sharing plans can also be based on a specimen plan.

The submitter sends a copy of the applicable draft documents to the Registered Deferred Income and Savings Plans Program. Once these documents are received, a specimen plan number is assigned and the documents are reviewed by program officials to ensure that they comply with the legislation and related administrative rules.

For registered pension plans and deferred profit sharing plans, the draft documents include the plan text, the funding documents, the trust agreement, a list of permitted variables, and a letter requesting approval of the specimen plan.

For registered education savings plans, registered disability savings plans, registered retirement savings plans, registered retirement income funds, tax-free savings accounts, and first home savings accounts, the draft documents include the plan text and a blank version of the proposed application form. The specimen plan includes all the information about the plan or fund that will be given to the client.

After program officials approve the documents for a registered education savings plan, registered disability savings plan, registered retirement savings plan, or registered retirement income fund, they send the specimen plan number to the submitter.

For tax-free savings accounts and first home savings accounts, program officials assign the tax-free savings account or first home savings account identification number to each specimen plan accepted by the program and provide this number to the submitter.

Once the specimen plan has been approved, the submitter may open the applicable plan, account, or fund with their clients. The submitter must then send the application to register the pension plan or deferred profit sharing plan based on the approved specimen. For education savings plans, disability savings plans, retirement savings plans, retirement income funds, tax-free savings accounts, and first home savings accounts, the specimen plans themselves are not registered. Rather, the Registered Deferred Income and Savings Plans Program registers the individual contracts as registered education savings plans, registered disability savings plans, registered retirement savings plans, or registered retirement income funds. The individual tax-free savings account and first home savings account contracts are registered once the election to register the arrangement has been filed with the Assessment, Benefit, and Service Branch of the Canada Revenue Agency.

Application forms:

Registered Pension Plans, Deferred Profit Sharing Plans, Pooled Registered Pension Plans, Registered Investments, Supplementary Unemployment Benefit Plans

The Registered Deferred Income and Savings Plans Program has developed application forms that submitters must use to register pension plans, deferred profit sharing plans, or pooled pension plans or to apply for registration as a registered investment.

Submitters use these application forms to provide all the personal information that the program needs to register and administer the plans. They also send the plan text and any other documents relating to the plan terms (employee booklet, collective agreement), as well as all trust deeds, insurance contracts, agreements, documents relating to how the plan benefits are funded, including the actuarial valuation report if applicable, and all resolutions or by-laws related to these plans.

There is no mandatory registration form for employers to complete when they apply to register a supplementary unemployment benefit plan. However, there is certain information that employers must send for plan registration and administration.

Registered Education Savings Plans, Registered Disability Savings Plans, Registered Retirement Savings Plans, Registered Retirement Income Funds, Tax-Free Savings Accounts, First Home Savings Accounts

Financial institutions and other promoters offering registered education savings plans, registered disability savings plans, registered retirement savings plans, registered retirement income funds, tax-free savings accounts, and first home savings accounts use their own application form to open these plans, funds, or accounts for their clients. A blank version of this form is sent to the Registered Deferred Income and Savings Plans Program for review and approval before it is used.

The Registered Deferred Income and Savings Plans Program uses this personal information to confirm that all individuals or entities opening and participating in the plan, account, or fund meet the legislated eligibility factors and respect any associated minimums or limits.

When the financial institution submits the application for registration, they must use the mandatory form, if applicable, developed by the Registered Deferred Income and Savings Plans Program.

Registration Process

Registered Pension Plans

Although there are many different types of employer-sponsored pension plans in Canada, the registration process is largely the same for all types.

The plan administrator must send the application form and all required accompanying documents to the Registered Pension Plans Program to register the pension plan. Once a complete application to register a plan is received, the Registered Pension Plans Program will issue a plan registration number and the plan is deemed registered.

The application package is then reviewed by the Registered Pension Plans Program. Program officials use this personal information to confirm that all legislative requirements are met and, where questions arise, that they are communicating with the appropriate individuals. Once the application package is approved, the Registered Pension Plans Program will notify the plan administrator that the plan is registered.

Registration under the Income Tax Act provides favourable tax treatment for the registered pension plan. With some exceptions, in addition to being registered under the Income Tax Act, the plan must also be registered by the applicable federal or provincial pension supervisory authority which defines the minimum standards that the registered pension plan is required to meet. Although the registration processes are largely independent of one another, to ease the administrative burden on pension plan administrators, specific information is exchanged between the Canada Revenue Agency and the applicable federal or provincial pension supervisory authorities, as outlined in written collaborative agreements.

When requesting an amendment to a registered pension plan, plan administrators must submit a certified copy of the plan amendment, along with the application to amend a registered pension plan.

After a pension plan is registered, plan administrators must file a registered pension plan annual information return with the Registered Pension Plans Program every year. These returns are sent to the program either directly (for plans registered only with the Canada Revenue Agency), or indirectly by way of a harmonized annual information return. Program officials have developed joint or harmonized annual information returns with provincial pension supervisory authorities and the Office of the Superintendent of Financial Institutions for the registered pension plans under their jurisdiction. In these cases, the annual information return is filed with the applicable pension supervisory authority first who then transmits the information to the Registered Pension Plans Program.

 A defined benefit registered pension plan must also submit information related to the plan’s funded status, by way of an actuarial valuation report, to the Registered Pension Plans Program on an ongoing basis (usually every three years) so that the reasonableness of the employer contributions can be assessed. Once the employer contributions are approved (either in whole or in part) by program officials, they can be deducted by the plan sponsor. In most cases, the membership data included in these reports is grouped by five-year age and service bands and includes no personal information about individual plan members. The same is true for the Actuarial Information Summary form, developed jointly by the Canada Revenue Agency, the Financial Services Regulatory Authority of Ontario, and Retraite Québec, and submitted to the Registered Pension Plans Program on a voluntary basis.

For a specific subset of defined benefit registered pension plans, namely individual pension plans, actuarial valuation reports contain some personal information about plan members. This information is used by program officials to determine whether the actuary’s recommendation about the stated employer contributions is reasonable. Furthermore, the employer sponsoring any defined benefit registered pension plan covering members who meet the definition of a connected person under the Income Tax Act, must file the Connected Person Information Return (Form T1007) with the Canada Revenue Agency. If the form has not been filed, the Registered Pension Plans Program imposes a ‘failure to file’ penalty.

Deferred Profit Sharing Plans

A deferred profit sharing plan can be set up either as a customized plan or a specimen plan. A customized plan has plan terms and funding documents specific to the employer’s deferred profit sharing plan. A specimen plan provides choice in plan terms and investment options.

For a customized plan, the application for registration is sent to the Deferred Profit Sharing Plan Program by the plan sponsor (employer). 

The application package is reviewed by the Deferred Profit Sharing Plan Program to ensure that all legislative and administrative requirements are met and, where questions arise, that program officials are communicating with the appropriate individuals. Once the application package is approved and the plan is registered, the Deferred Profit Sharing Plan Program will issue a plan registration number and send it to the plan sponsor.

Registered Education Savings Plans and Registered Disability Savings Plans

Both the Canada Revenue Agency’s Registered Education (Disability) Savings Plans Program and the Employment and Social Development Canada’s Canada Education (Disability) Savings Program require financial institutions and other promoters to collect and send personal information to them.

Once the client’s personal information collected from the promoter or issuer’s registered education (or disability) savings plan application form is downloaded by the Canada Education (or Disability) Savings Program’s system (at Employment and Social Development Canada), it goes through an automated validation process. Once validated, the Canada Disability Savings Program’s system automatically updates the plan’s status in their database to show that the disability savings plan is registered, and sends all information to the Canada Revenue Agency.

The Canada Disability Savings Program’s system then automatically sends an update to the financial institution’s database to show that the status of the disability savings plan has been changed to registered. Although it is the Canada Disability Savings Program’s system that confirms registration, all validations and confirmations are based on the requirements of the Registered Disability Savings Plans Program (at the Canada Revenue Agency) and the legislation this program is required to administer.

For registered education savings plans, the validated information is sent by the Canada Education Savings Program’s system to the Canada Revenue Agency to ensure that the registration process can be completed.

Twice a year, the Registered Education Savings Plans Program sends letters to each promoter to confirm which of the contracts submitted during the previous six months have met all of the requirements of the program and have thus been registered. This registration is retroactive to the signature date of the contract.

Supplementary Unemployment Benefit Plans

If an employer chooses to register their supplementary unemployment benefit plan with the Canada Revenue Agency, contributions must be made to, and benefits paid from, a trust. Plans that permit payments to be made from the employer’s general operating revenues do not qualify for registration.

The employer must send the application package (including all required documents) to the Supplementary Unemployment Benefit Plans Program. Once received, the information is manually entered in the Supplementary Unemployment Benefit Plans Program’s internal IT system.

Program officials review the documents and use this information to confirm that all legislative requirements are met. Once the application package is approved, the Supplementary Unemployment Benefit Plans Program will notify the employer that the plan is registered.

Registered Retirement Savings Plans and Registered Retirement Income Funds

The issuer (carrier) must send the application form and all required accompanying documents to the Registered Retirement Savings Plans (Registered Retirement Income Funds) Program to register a retirement savings plan (retirement income fund). After the information on the registration form is validated against an approved schema, it is transmitted directly to the Canada Revenue Agency’s internal systems. 

Once the review is complete and the documents have met all the requirements of the program, the Registered Retirement Savings Plans (Registered Retirement Income Funds) Program will notify the issuers (carriers) that the contracts have been accepted for registration as registered retirement savings plans (registered retirement income funds).

The registered retirement income fund’s carrier must file information returns each year to report amounts to the Canada Revenue Agency that Canadians must include in their income. Monetary penalties are assessed to the carriers that fail to comply with these rules.

Registered Investments

The applicant (corporation or trust) must send the application form to apply for registration as a registered investment. This application for registration must include a copy of relevant trust documents and any additional information required. The applicant sends these documents to the Registered Investments Program. Once received, the information is manually entered in the Registered Investments Program’s internal IT system.

The application package is reviewed by the Registered Investments Program to ensure that all legislative and administrative requirements are met and, where questions arise, that program officials are communicating with the appropriate individuals. Once the application package is approved, the Registered Investments Program will issue a registration number and send it to the applicant.

After an application for a registered investment has been accepted, the representative of the corporation or trust must complete and file a trust return each year. The personal and financial information collected on this form is sent to the Canada Revenue Agency. This information is captured, processed, and stored in the Canada Revenue Agency’s internal systems and is viewed and used by the Registered Investments Program.

A list containing all registered investments as of December 31st of the preceding year is published by the Registered Investments Program each year.

Tax-Free Savings Accounts and First Home Savings Accounts

Before an issuer can offer a tax-free (first home) savings account to the public, they must apply for a tax-free (first home) savings account identification number from the Tax-Free (First Home) Savings Accounts Program.

The application package is reviewed by program officials to ensure that all legislative requirements are met.

Once the review is complete and the tax-free (first home) savings account identification number has been assigned, program officials will notify the issuer of this number. Issuers can then open tax-free (first home) savings accounts with their clients.

After an issuer opens a tax-free (first home) savings account with their client, they are required to send the completed application package to the Canada Revenue Agency for review and approval. This package includes the tax-free (first home) savings account annual information return and is considered a request to file an election to register the contract as a tax-free (first home) savings account under the social insurance number or temporary tax number of the holder.

Issuers must file the tax-free (first home) savings account annual information return electronically. The personal and financial information from the return is captured, processed, and stored in the Canada Revenue Agency’s internal systems and is viewed and used by program officials by way of the Tax-Free Savings Accounts Program’s internal IT system. Once the functionality is built for the First Home Savings Accounts Program, the personal and financial information from the return will be viewed and used by program officials by way of the First Home Savings Account Program’s internal IT system. The anticipated completion date for this functionality is October 2025.

Once the tax-free (first home) savings account election is received by the Canada Revenue Agency, validation checks are performed and a confirmation number is provided electronically to the issuer. Issuers will be notified of any rejected records and if they don’t submit an amended record, the account may not be registered as a tax-free (first home) savings account, the tax-deduction for the first home savings account contribution could be disallowed, and the holder could be subject to tax on the investment earnings. When the election has been accepted, the tax-free (first home) savings account is considered registered.

Once a tax-free (first home) savings account is registered, issuers must file, with the Canada Revenue Agency every year, a tax-free (first home) savings account annual information return, regardless of the activity in the account.

Pooled Registered Pension Plans

Before a plan administrator can send, to the Pooled Registered Pensions Plan Program, an application for registration as a pooled pension plan, they must become licensed by the applicable federal or provincial pension supervisory authority and send the pooled pension plan to that supervisory authority to be registered under the Pooled Registered Pension Plans Act or a similar law of a province. Once the plan is registered under the applicable pension supervisory authority, the plan administrator must send the application form and all required accompanying documents to the Pooled Registered Pension Plans Program in the Canada Revenue Agency for the pooled pension plan to be registered under the Income Tax Act.  

The application package is reviewed by the Pooled Registered Pension Plans Program to ensure that all legislative requirements are met and, where questions arise, that program officials are communicating with the appropriate individuals. Once the application package is approved, the Pooled Registered Pension Plans Program will issue a plan registration number and send it to the plan administrator.

After a pooled pension plan has been registered, plan administrators must file a pooled registered pension plan annual information return with the Pooled Registered Pension Plans Program, or jointly with the Pooled Registered Pension Plans Program and the Office of the Superintendent of Financial Institutions, each year.

Both the Pooled Registered Pension Plans Program and the Private Pension Plans Program at the Office of the Superintendent of Financial Institutions, require plan administrators to collect and send personal information to them.

The plan administrator sends the personal information collected on the annual information return to the Private Pension Plans Division of the Office of the Superintendent of Financial Institutions who shares relevant information with the Canada Revenue Agency for the administration of the Pooled Registered Pension Plans Program. The Pooled Registered Pension Plans Program sends information to the Office of the Superintendent of Financial Institutions for the same purpose.

When requesting an amendment to a pooled registered pension plan, plan administrators must submit a certified copy of the plan amendment, along with either the stand-alone amendment form or the applicable joint form.

Plan administrators send the stand-alone registration form, amendment form, and annual information return to the Pooled Registered Pension Plans Program electronically. After the information on these forms is validated against an approved schema, it is transmitted directly to the Canada Revenue Agency’s internal IT systems.

The Office of the Superintendent of Financial Institutions is the only jurisdiction that has developed, in collaboration with the Pooled Registered Pension Plans Program, a joint pooled pension plan registration form, pooled registered pension plan amendment form, and pooled registered pension plan annual information return.

Administration

The Registered Deferred Income and Savings Plans Program is responsible for ensuring that the requirements of the Income Tax Act and those of the Income Tax Regulations are met with respect to the registration and monitoring of registered pension plans, deferred profit sharing plans, registered education savings plans, registered disability savings plans, supplementary unemployment benefit plans, registered retirement savings plans, registered retirement income funds, registered investments, tax-free savings accounts, pooled registered pension plans, and first home savings accounts. It is also responsible for creating application, amendment, and reporting forms, communication products, as well as administrative policies, and guidelines for plans, funds, or accounts (including plan or contract registration, plan amendment, specimen plans, making elections, plan funding, transfers, waivers, administrative relief, and penalties).

Employers who choose to offer registered pension plans, deferred profit sharing plans, supplementary unemployment benefit plans, or pooled registered pension plans to their employees, are responsible for ensuring that these plans are administered in accordance with all relevant legislation, circulars, and policies.

Insurance companies, trust companies, banks, or credit unions (and, in some cases, scholarship funds) are responsible for opening registered education savings plans, registered disability savings plans, registered retirement savings plans, registered retirement income funds, tax-free savings accounts, or first home savings accounts with their clients and ensuring that these plans, funds, or accounts are administered in accordance with all relevant legislation and policies.

Monitoring

There are many legislated and administrative rules that all plan administrators, employers, or organizations sponsoring a registered pension plan, deferred profit sharing plan, supplementary unemployment benefit plan, or pooled registered pension plan, and all persons and organizations participating in a registered education savings plan, registered disability savings plan, registered retirement savings plan, registered retirement income fund, tax-free savings account, and first home savings account, must follow. If these rules are not met, deductions of contributions (made by the employer or the individual) could be denied, monetary penalties could be imposed, or the registration of the registered pension plan, deferred profit sharing plan, registered education savings plan, or pooled registered pension plan could be revoked.

In the case of registered disability savings plans, if the rules are not met the legislation considers the plan to be deregistered.

For a registered retirement savings plan, registered retirement income fund, tax-free savings account, or first home savings account if the plan, fund, or account no longer meets the rules under which it was registered, the arrangement automatically ceases to be a registered retirement savings plan, registered retirement income fund, tax-free savings account, or first home savings account at the time the rules are breached (or, in some cases, as far back as the date it was opened).

There are several legislated rules that all registered investments must follow. Failure to do so will result in taxes being imposed or the revocation of the investment’s registered status. 

When the registration of a plan is revoked, the plan is deregistered, or ceases to be a registered plan, fund, or account, adverse tax consequences arise impacting all parties.

For all registered deferred income and savings plans, audit plans and risk assessment strategies are developed to identify high risk files to support both desk and field audits and to deal with non-compliance issues.

Technical assistance is provided to external clients to help them understand and meet their obligations under the Income Tax Act and Income Tax Regulations and address new and emerging trends or schemes.

In some cases, auditors and/or other program officials participate as expert witnesses in cases before the courts.

Annuity Purchases

Instead of receiving a retirement benefit from a specific type of registered pension plan, some members may elect to transfer the value of their benefit to an insurance company or licensed annuities provider to purchase an annuity. Qualifying annuities can also be purchased with the proceeds/property from a member’s pooled registered pension plan account, deferred profit sharing plan, registered retirement savings plan or from a member’s registered retirement income fund. In all cases, there are certain legislative requirements that must be met to avoid severe tax consequences.

Once the transfer of property has occurred, neither the Registered Pension Plans Program, the Deferred Profit Sharing Plans Program, the Pooled Registered Pension Plans Program, the Registered Retirement Savings Plans Program, nor the Registered Retirement Income Funds Program monitor the ongoing monthly annuity payments. However, program officials may conduct audits on the transfer and initial annuity purchase to ensure that the legislated requirements were met at the time of transfer.

Ad hoc Requests

In addition to the formal information sharing agreements between the Registered Deferred Income and Savings Plans Program and some of its stakeholders, from time to time the program receives ad-hoc requests from the media, the Department of Finance, Employment and Social Development Canada, and other federal or provincial government departments, for anonymized statistical data from one or more of the registered deferred income and savings plans. Personal information collected for these plans is used to compile the anonymized statistics for these clients.

What’s New

System updates

The Registered Deferred Income and Savings Plans Program is currently working, in conjunction with the Information Technology Branch, on an important information technology project. This project is aligned with the Canada Revenue Agency’s Secure Portals Reengineering initiative and will link the Registered Deferred Income and Savings Plans Program’s internal IT system to the Canada Revenue Agency’s secure online portals functionality. Once the project is fully implemented, all authorized parties will use their existing credentials to interact with the Registered Deferred Income and Savings Plans Program in a secure, online manner for all of their registered deferred income and savings plans transaction needs. Implementation of Phase 1 of the project is scheduled to occur sometime in 2025. Once all phases are fully implemented, most, if not all, interactions between the Registered Deferred Income and Savings Plans Program and its authorized parties will be conducted online, although paper documents will still be accepted.

The Registered Deferred Income and Savings Plans Program is also currently developing functionality in its internal IT system so that program officials can view and access the personal and financial information from the First Home Savings Account return.

Digital Mailroom

All eleven registered deferred income and savings plans participate in the Canada Revenue Agency’s Digital Mailroom Project. Most documents received by mail for any of these registered deferred income and savings plans are sent to a third party to be digitized (scanned) into the Document Management Portal prior to being processed. The Document Management Portal is an electronic document and records management system hosted by a Managed Service Provider for storing incoming taxpayer correspondence and managing information in a standard format. As part of the Digital Mailroom Project, personal information contained on certain Registered Pension Plan Program forms or returns (currently the Application to Register a Pension Plan (Form T510), Application to Amend a Registered Pension Plan (Form T920), and the Registered Pension Plan Annual Information Return (Form T244)) is extracted and uploaded directly into the Registered Deferred Income and Savings Plans Program’s internal IT system.

The Registered Deferred Income and Savings Plans Program is working to incorporate the following additional documents into the Document Management Portal by late 2024 or early 2025:

Impacts to personal information resulting from implementation of the digital mailroom were assessed in a privacy protocol in 2021.

Budget Implementation Act, 2023, No. 1

Budget Implementation Act, 2023, No. 1 contained a measure that requires issuers of registered retirement savings plans and carriers of registered retirement income funds to electronically report, to the Canada Revenue Agency starting in the 2023 tax year, the fair market value of property held by the plan or fund at the end of the year. The information from the return is transmitted directly and securely to the Canada Revenue Agency. The fair market value field will be added to the existing T4RSP and T4RIF slips. The Canada Revenue Agency’s existing information technology systems are currently being updated to facilitate the capturing and/or viewing of this information. The Registered Deferred Income and Savings Plans Program will access this information to improve screening and risk assessment and to allow for more targeted compliance activities for the Registered Retirement Savings Plans and Registered Retirement Income Funds Programs.

Annuity Purchases

Effective January 2020, a new type of annuity, the advanced life deferred annuity, was made available to provide Canadians with greater flexibility in managing their retirement savings. Retirees can transfer certain amounts (up to a legislated maximum) directly from a defined contribution registered pension plan, deferred profit sharing plan, registered retirement savings plan, registered retirement income fund, or pooled registered pension plan to a licensed annuities provider to purchase an advanced life deferred annuity. This annuity is a life annuity that must start no later than the end of the year in which the individual reaches the age of 85 and reduces the risk of a retiree outliving their retirement savings.

Registered Disability Savings Plans

The Registered Disability Savings Plans Program has recently developed draft guidelines to allow RDSP beneficiaries to withdraw more than what is allowable under the maximum payment rules, in cases of financial hardship. These draft guidelines were shared with RDSP issuers in May 2024 so they know under what circumstances the waiver will be approved. Program officials have committed to publishing these guidelines by the end of 2024 and are exploring the feasibility of creating a form to facilitate this process for issuers.     

Scope of the Privacy Impact Assessment

This Privacy Impact Assessment (PIA) will focus on the administration of the Registered Deferred Income and Savings Plans Program. As such, it will identify privacy risks, develop associated mitigation strategies, and provide a solid foundation of expected privacy practices. The scope is limited to an analysis of the collection, use, retention, and disclosure of personal information for the purpose of registering and monitoring registered pension plans, deferred profit sharing plans, registered education savings plans, registered disability savings plans, supplementary unemployment benefit plans, registered retirement savings plans, registered retirement income funds, registered investments, tax-free saving accounts, pooled registered pension plans, and first home savings accounts.

The business processes of other organizations pertaining to registered deferred income and savings plans fall outside the scope of this document.

This privacy impact assessment does not cover the federal or provincial governments’ financial incentives to promote post-secondary education or to support Canadians with disabilities. These include the Canada Education Savings Program and the Canada Disability Savings Grant and Bond Incentives Program, which are administered by Employment and Social Development Canada. However, this PIA complements the following privacy assessments completed by Employment and Social Development Canada:

This assessment also aligns with the Privacy Protocol for Non-Administrative Purposes prepared by the Office of the Superintendent of Financial Institutions (June 2018) for Pooled Registered Pension Plans.

Most registered pension plans are also subject to federal and/or provincial pension benefits standards legislation which define the minimum standard of benefits that must be provided by the registered pension plan to the plan members. This privacy impact assessment does not cover the pension standards legislation administered by the Office of the Superintendent of Financial Institutions or provincial supervisory bodies. 

The information from the previously completed Privacy Impact Assessments for the Registered Disability Savings Plans Program and the Pooled Registered Pension Plans Program  have been amalgamated into this umbrella PIA.

Risk identification and categorization

A) Type of program or activity

Compliance / Regulatory investigations and enforcement   

Level of risk to privacy: 3

Details:

RESP, RDSP, RRSP, RRIF, TFSA, FHSA

The administration of the Registered Education Savings Plans, Registered Disability Savings Plans, Registered Retirement Savings Plans, Registered Retirement Income Funds, Tax-Free Savings Accounts, and First Home Savings Accounts Programs requires the collection of personal information from the taxpayer(s) opening the plan. The taxpayer gives the relevant financial institution their personal information as well as personal information for the plan beneficiary (if different from the person opening the plan). In the case of a registered disability savings plan, if the beneficiary is a child, the primary caregiver (if different than the person opening the plan) gives the registered disability savings plan financial institution their personal information. The information is used to determine if the taxpayer is eligible to open the plan, or in the case of the Registered Education Savings Plans and Registered Disability Savings Plans Programs, if the beneficiary is eligible to have either a registered education savings plan or a registered disability savings plan.

Once a registered education savings plan, registered disability savings plan, registered retirement savings plan, registered retirement income fund, tax-free savings account, or first home savings account is opened by a financial institution, the financial institution sends the personal information collected on the application form to the Registered Education Savings Plans, Registered Disability Savings Plans, Registered Retirement Savings Plans, Registered Retirement Income Funds, Tax-Free Savings Accounts, or First Home Savings Accounts Program. The information is used to make sure that the registered education savings plan, registered disability savings plan, registered retirement savings plan, registered retirement income fund, tax-free savings account, or first home savings account meets the conditions in the relevant sections of the Income Tax Act and the Income Tax Regulations. Personal information will be disclosed to the financial institution, as applicable, to make sure registration, administration, and plan closure requirements are met.

If a taxpayer (beneficiary or person who opened the registered education savings plan or registered disability savings plan) or the financial institution administering the plan wishes to discuss a particular registered education savings plan or registered disability savings plan, program officials will collect personal information from them in order to retrieve information about the relevant plan from stored files. Program officials may disclose personal information to them in order to resolve their issue.

For any requests for administrative relief or waivers, the programs do not share information with the issuer, promoter, or carrier, other than what they have already submitted.

To ensure that the legislated rules are followed, the Registered Deferred Income and Savings Plans Program conducts compliance reviews, including desk audits of taxpayers (subscribers, contributors, annuitants, and/or beneficiaries) and desk or on-site audits of promoters, trustees, issuers, or carriers to determine compliance with the Income Tax Act and/or Income Tax Regulations as it relates to administration of registered education savings plans, registered disability savings plans, registered retirement savings plans, registered retirement income funds, tax-free savings accounts, and first home savings accounts. For registered education savings plans, the list of promoters and trustees selected for audit is shared between Employment and Social Development Canada and the Canada Revenue Agency, as are findings of non-compliance.

This requires access to personal information from the Canada Revenue Agency’s systems and from the financial institutions.

RPP, DPSP, PRPP, SUBP, RI

The administration of the Registered Pension Plans, Deferred Profit Sharing Plans, Pooled Registered Pension Plans, and Supplementary Unemployment Benefit Plans Programs requires the collection of personal information from the taxpayer/member(s) covered by the plan. These individuals give their employer (or plan administrator) their personal information as well as the personal information of their spouse and/or beneficiary when they become members of the particular plan.

The administration of the Registered Investments Program requires the collection of personal information from the corporation or trust applying for registration as a registered investment. These applicants give the Registered Investments Program their personal information in the application package and the annual return they must file.

Once a registered pension plan, deferred profit sharing plan, pooled registered pension plan, or supplementary unemployment benefit plan is entered into, the employer or plan administrator sends the personal information collected on the application form to the Registered Pension Plans, Deferred Profit Sharing Plans, Pooled Registered Pension Plans or Supplementary Unemployment Benefit Plans Program. In the case of a registered pension plan covering connected or related persons, personal information about these individual members is sent to the Registered Pension Plans Program. The information is used to make sure that the registered pension plan, deferred profit sharing plan, pooled registered pension plan, or supplementary unemployment benefit plan meets the conditions and restrictions in the relevant sections of the Income Tax Act and the Income Tax Regulations.

With the exception of connected or related persons covered by a registered pension plan, personal information about individual members of the above plans is not sent to the Registered Pension Plans, Deferred Profit Sharing Plans, Pooled Registered Pension Plans, or Supplementary Unemployment Benefit Plans Programs. However, this personal information is sent to other areas of the Canada Revenue Agency.

Specifically, for the Registered Pension Plans and Deferred Profit Sharing Plans Programs, pension adjustments are reported to the Canada Revenue Agency annually by the employer or plan administrator for each plan member by way of the T4 slip. Plan administrators of pooled registered pension plans report contributions made by each plan member to the Canada Revenue Agency on a PRPP contribution receipt slip each year. Benefits paid to members of registered pension plans, deferred profit sharing plans, pooled registered pension plans, or supplementary unemployment benefit plans are reported to the Canada Revenue Agency by the employer, plan administrator, or trustee on the T4A slip.

For each of these programs, this information is used by the relevant Registered Deferred Income and Savings Plans Program to develop audit plans and risk assessment strategies and to identify high risk files for audit action. To ensure that the legislated rules are followed, the Registered Deferred Income and Savings Plans Program conducts compliance reviews, including desk audits of taxpayers (plan members, beneficiaries, and/or retirees) and desk or on-site audits of employers and/or plan administrators, corporations, or trusts to determine compliance with the Income Tax Act and/or Income Tax Regulations as it relates to the administration of registered pension plans, deferred profit sharing plans, pooled registered pension plans, and to address non-compliance issues in registered investments.

For all registered deferred income and savings plans, technical assistance is provided to external clients to help them understand and meet their obligations under the legislation and to address new and emerging trends (including anti-avoidance), questionable arrangements or transfers, and other schemes. This requires access to personal information from the Canada Revenue Agency’s systems and from employers, plan administrators, trustees, financial institutions, and/or insurance companies, as applicable.

Audits of transfers from a registered pension plan, deferred profit sharing plan, registered retirement savings plan, registered retirement income fund, or pooled registered pension plan to a licensed annuities provider to purchase an advanced life deferred annuity or other annuity types, are also undertaken to ensure compliance.

In some cases, auditors and/or other program officials will participate as expert witnesses in cases before the courts.

B) Type of personal information involved and context

Social insurance number, medical, financial or other sensitive personal information and/or the context surrounding the personal information is sensitive. Personal information of minors or incompetent individuals or involving a representative acting on behalf of the individual. 

Level of risk to privacy: 3

Details:

The Registered Pension Plans, Deferred Profit Sharing Plans, Registered Education Savings Plans, Registered Disability Savings Plans, Registered Retirement Savings Plans, Registered Retirement Income Funds, Tax-Free Savings Accounts, Pooled Registered Pension Plans, and First Home Savings Accounts Programs use personal information such as Social Insurance Number, name, address, date of birth, and/or financial information to register and monitor the various plans, funds, or accounts and/or perform compliance activities, including risk assessment and audits. 

RESP and RDSP

When the information collected about a registered education savings plan is looked at together, it reveals information about a person’s identity and finances. In most cases, due to the nature of the program, the Registered Education Savings Plans Program receives personal information about minors.

When the information collected about a registered disability savings plan is looked at together, it reveals information about a person’s identity, health, and finances. In most cases, due to the nature of the program, the Registered Disability Savings Plans Program receives personal information about minors and persons with disabilities.

RPP, DPSP, SUBP, and PRPP

For registered pension plans, deferred profit sharing plans, and pooled registered pension plans, the registration form is used to collect the required personal information that the programs need on the plan, the plan administrator, plan sponsor, the employer(s) participating in the plan, any plan members who are connected or related persons (RPP), the authorized correspondents, details on the funding medium, insurance company, trust company, plan trustee(s), the other pension supervisory authority (RPP), previous registered pension plan, other registered pension plan or deferred profit sharing plan of the employer (or non-arm’s length employer) under which members of the DPSP will accrue benefits (if any), or specimen plan number (if applicable).

For supplementary unemployment benefit plans there is no mandatory registration form. However, employers must send the Supplementary Unemployment Benefit Plans Program a list with the name and address of all employers participating in the plan and the date they joined, and other required plan documents.

In registered pension plans covering connected or related persons, the Registered Pension Plans Program uses personal information such as social insurance number, date of birth, and financial information to register and monitor the plans and perform compliance activities, including audits. When this information is looked at together, it reveals information about a person’s identity and finances.

C) Program or activity partners and private sector involvement

Private sector organizations or international organizations or foreign governments

Level of risk to privacy: 4

Details:

For all Registered Deferred Income and Savings Plans Programs, paper documents containing personal information are stored for a specified period of time by a third-party in the private sector under contract with the Canada Revenue Agency.

Most documents received by mail for all the registered deferred income and savings plans are sent to another third party in the private sector under contract with the Canada Revenue Agency. These documents are digitized (scanned) by this third party before being processed by the Registered Deferred Income and Savings Plans Program. 

RESP and RDSP:

The Registered Education Savings Plans and Registered Disability Savings Plans Programs share personal information with financial institutions, and other federal departments (as outlined in written collaborative agreements) and with various Canada Revenue Agency programs.

The information shared is validated to ensure that the registered education savings plans and registered disability savings plans are administered in accordance with all applicable laws in the Income Tax Act, including if the beneficiary meets eligibility requirements, contribution rules, and withdrawal rules.

Data is cross-referenced between the Canada Revenue Agency and Employment and Social Development Canada on a need-to-know basis for program administration, audit and compliance purposes.

RPP and PRPP:

The Registered Pension Plans and Pooled Registered Pension Plans Programs share personal information with other federal and provincial departments (as outlined in written collaborative agreements) and access personal information about members of the Programs from financial institutions, insurance companies, and/or various areas of the Canada Revenue Agency.

Specifically, the Registered Pension Plans and Pooled Registered Pension Plans Programs will disclose information to officials of the Office of the Superintendent of Financial Institutions or provincial plan regulators on a need to know basis.

Registered Pension Plans Program officials also provide information to Statistics Canada.

Program officials will access the Canada Revenue Agency’s records or will use risk assessment strategies that do so, and may coordinate with plan administrators, accounting, or actuarial consulting firms, and/or financial institutions or insurance companies to request information for program administration, audit, and other compliance purposes.

RRSP, RRIF, TFSA, FHSA, and DPSP:

The Registered Retirement Savings Plans, Registered Retirement Income Funds, Tax-Free Savings Accounts, First Home Savings Accounts and Deferred Profit Sharing Plans Programs access personal information about members of the programs from various areas of the Canada Revenue Agency for program administration, compliance and/or audit purposes.

D) Duration of the program or activity

Long-term program 

Level of risk to privacy: 3

Details:

Registered deferred income and savings plans are generally long-term savings plans available to Canadians who are saving for major life events such as post-secondary education, the purchase of a home, retirement, or, in the case of the tax-free savings account, for whatever purpose desired.  There are other long-term savings plans among the registered deferred income and savings plans portfolio, including a program for people with severe disabilities. There is no clear “sunset” time frame for any of these programs. 

E) Program population

The program affects certain individuals for external administrative purposes.

Level of risk to privacy: 3

Details:

Registered deferred income and savings plans are available to certain Canadians as determined by various eligibility criteria that vary by program. Not all eligible Canadians will elect to take part in these programs. As an example, the Registered Disability Savings Plans Program is for disability tax credit eligible people. Not everyone who is eligible will participate in this program.

Other taxpayers may become involved in the Registered Disability Savings Plans Program if they choose to open or contribute to a registered disability savings plan for a disability tax credit eligible person (beneficiary). Similarly, other taxpayers may become involved in the Registered Education Savings Plans Program if they choose to open a registered education savings plan for a child (beneficiary). The programs may affect these taxpayers as they are responsible for paying tax in certain cases.

The primary caregiver of a child beneficiary (if different from the taxpayer opening the plan) must provide information on their identity to confirm the beneficiary’s eligibility for the Registered Disability Savings Plans Program. The same is true for a public primary caregiver of a child beneficiary in the Registered Education Savings Plans Program.

Employers who choose to offer a registered pension plan, deferred profit sharing plan, supplementary unemployment benefit plan, or a pooled registered pension plan for their employees necessarily undertake various responsibilities such as contribution and reporting obligations.

Issuers of tax-free savings accounts, first home savings accounts, or registered retirement savings plans, and carriers of registered retirement income funds also face reporting obligations and are responsible for paying tax in certain cases.

F) Technology & privacy

  1. Does the new or modified program or activity involve the implementation of a new electronic system, software or application program including collaborative software (or groupware) that is implemented to support the program or activity in terms of the creation, collection or handling of personal information?

    2. Risk to privacy: No

  2. Does the new or modified program or activity require any modifications to IT legacy systems and/or services?

    3. Risk to privacy: Yes

  3. Does the new or modified program or activity involve the implementation of one or more of the following technologies?

Enhanced identification methods - this includes biometric technology (i.e. facial recognition, gait analysis, iris scan, fingerprint analysis, voice print, radio frequency identification (RFID), etc.) as well as easy pass technology, new identification cards including magnetic stripe cards, "smart cards" (i.e. identification cards that are embedded with either an antenna or a contact pad that is connected to a microprocessor and a memory chip or only a memory chip with non-programmable logic).

Risk to privacy: No

Use of Surveillance - this includes surveillance technologies such as audio/video recording devices, thermal imaging, recognition devices, RFID, surreptitious surveillance/interception, computer aided monitoring including audit trails, satellite surveillance etc.

Risk to privacy: No

Use of automated personal information analysis, personal information matching and knowledge discovery techniques - for the purposes of the Directive on PIA, government institutions are to identify those activities that involve the use of automated technology to analyze, create, compare, identify or extract personal information elements. Such activities would include personal information matching, record linkage, personal information mining, personal information comparison, knowledge discovery, information filtering or analysis. Such activities involve some form of artificial intelligence and/or machine learning to uncover knowledge (intelligence), trends/patterns or to predict behavior.

Risk to privacy: Yes

G) Personal information transmission

The personal information is transmitted using wireless technologies.  

Level of risk to privacy: 4

Details:

For all eleven of the registered deferred income and savings plans, personal information is processed on paper, and/or received by mail, fax, and through digital submissions. To discourage submitters from sending personal information by fax, the Registered Deferred Income and Savings Plans Program has removed the program’s fax number from all its external correspondence. Access and circulation of hardcopy documents is restricted and monitored.

Transmittal of information to private parties and external clients by phone is done through Voice over Internet Protocol and/or Canada Revenue Agency issued cellular telephones rather than land line telephones. Effective March 6, 2023, the Canada Revenue Agency’s policy on cell phones changed to allow an employee to discuss Protected A or Protected B personal information with a taxpayer or a financial institution on their Canada Revenue Agency issued cell phone. Mail is also used to communicate with external clients. With some limited exceptions, secure digital communications (e-mails) are reserved for use within the Canada Revenue Agency.

Plan administrators, issuers, carriers, and other external clients will transmit personal information contained in letters and forms to the Registered Deferred Income and Savings Plans Program by mail or digital submission (IFT, web form, My Business Account and Represent A Client).

Data obtained in physical formats is manually captured by Registered Deferred Income and Savings Plans Program’s employees and is converted into electronic format which is then stored securely.

Requests received in writing are digitized and stored in the Document Management Portal for later access by Registered Deferred Income and Savings Plans Programs employees.

RESP and RDSP Programs

The majority of personal information transmissions for the Registered Education Savings Plan and Registered Disability Savings Plan Programs happen electronically through secured government systems. The Registered Education Savings Plan Program’s system automatically receives personal information from the Canada Education Savings Plan Program’s system at least monthly. The Registered Disability Savings Plan Program’s system automatically sends and receives personal information to/from the Canada Disability Savings Grant and Bond Incentives Program’s system on at least a monthly basis. This is done through an automated process. The Registered Disability Savings Plan Program’s system also retrieves Disability Tax Credit information from the Canada Revenue Agency’s database on a monthly basis.

Throughout the year there will be instances where the Registered Disability Savings Plans Program must transfer personal information by telephone or mail. For example, if a financial institution has several registered disability savings plans that must close, the Registered Disability Savings Plans Program prints a list of these plans and mails it to the associated financial institution and requests that they close the associated plans. The Registered Disability Savings Plans Program may also have to communicate with a financial institution, on an ad-hoc basis, about a particular registered disability savings plan for a client where the date of death, disability tax credit status, effective date, and expiry date, residency, or primary caregiver information, may be disclosed by telephone or mail.

There are instances where the Registered Plans Directorate will need to discuss a specific registered education savings plan or contract or a registered disability savings plan or contract with a financial institution, or with the Canada Education Savings Program or Canada Disability Savings Program of Employment and Social Development Canada because of an audit on that particular plan or contract. The Registered Plans Directorate will share personal information, by telephone or mail, with the Canada Education Savings Program or Canada Disability Savings Program, financial institutions, and taxpayers (registered education savings plan or registered disability savings plan holder/beneficiary) if any of these parties advises the Registered Plans Directorate of a non-compliance issue on a particular registered education savings plan or registered disability savings plan.

H) Potential risk that in the event of a privacy breach, there will be an impact on the individual or employee

Details:

The personal information collected for the administration of the Registered Deferred Income and Savings Plans Programs is classified as “Protected B”.

In the event of a privacy breach in a registered education savings plan, registered disability savings plan, registered retirement savings plan, registered retirement income fund, tax-free savings account, or first home savings account, there is a risk of financial loss (e.g. identity theft or fraud, inconvenience due to changing financial arrangements) and impacts to health (e.g. psychological impact, stress) to a contributor or a beneficiary because their personal financial affairs may be compromised.

Furthermore, in a registered disability savings plan, a breach may also cause impact to an individual’s reputation (e.g. hurt, humiliation or embarrassment) because of the sensitive medical information needed to administer this program.

In the event of a privacy breach involving a registered pension plan or a deferred profit sharing plan it is possible that, in situations where requests for administrative relief (e.g. retroactive lump-sum payments, overcontributions, overpayments, PA/ PSPA issues) are received or in cases involving Individual Pension Plans, there is a risk of financial loss (e.g. identity theft or fraud) to a plan member because their personal information and/or financial affairs may be compromised. In rare cases involving cases of wrongful dismissal, the Registered Pension Plans Program may get a request to reinstate a member of a registered pension plan. This could result in impacts to health (e.g. psychological impact, stress) for that plan member or to their reputation (e.g. hurt, humiliation or embarrassment) if the reason for dismissal was health related and the security of this sensitive information was breached. 

In the event of a privacy breach involving a supplementary unemployment benefit plan, a pooled registered pension plan, or a registered investment, there would be minimal impact on the individuals involved because of the limited amount of financial information collected for these programs. Furthermore, these programs do not collect information about any identifiable individuals.

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2024-12-24