Date: 9th March 2018
This privacy notice describes how Premier Pensions Management (Premier) collects, stores and processes personal information when providing services to our clients.
Premier holds personal data about you as a member of one of the pension schemes that we manage and may hold some data about your potential beneficiaries (Spouse, partner, children or other contingent beneficiaries). This is needed for us to comply with our contractual and legal obligations.
This Privacy Notice may be updated from time to time. It is for information only and you do not need to take any action. It is available at https://premieradministration.co.uk/privacy-notice/
Please contact us if you would like to view the Privacy Notice specific to your pension scheme. The Trustee Board of the scheme is your Data Controller.
What Personal Data do we hold?
We could hold both basic and sensitive data about you and your potential beneficiaries.
- name, address, date of birth, telephone number and email address;
- National Insurance number;
- service history of the member, while employed by the sponsor of the pension scheme
- salary, details of any period of absence and working hours;
- marital status and details of any dependants and/or potential beneficiaries;
- bank details;
- information relating to your health, if you have shared this with us; and
- any other personal data which may be needed to process your benefits and are needed for the proper running and administration of your pension scheme
How do we collect this data?
Some of this data is or will have been collected directly from you (for example, when filling in forms about your pension scheme membership, or when corresponding with us or our representatives by telephone, post, email or otherwise). If you visit our website, it will automatically collect some data about you and your visit, including your IP address, your browser type and the pages on the site that you visit.
We may also collect some data from third parties. For example, from the sponsor of your pension scheme and previous administrators of your scheme. We may also occasionally obtain or have obtained data about you from other external sources (for example, HM Revenue and Customs).
In order for us to comply with our legal obligations, please notify Premier of any changes to your personal details (e.g. address, email or other details) as soon as possible. Failure to provide it could mean we are unable to process your benefits. If you have any questions about our need for your information, please raise your questions with Premier.
Telephone: 0800 122 3200 (from outside of the UK +44 20 3727 9850)
How do we use your personal data?
We use your personal data for a variety of reasons.
- Valuing your pension, the options available to you, the value of the scheme as a whole, the levels of funding that the pension scheme needs and the investment plan for the scheme;
- Maintaining records for the purpose of payment of pensions on your retirement (or earlier / later due to ill-health or other reasons, as requested by you and agreed by the Trustees as Data Controllers);
- Payment of lump sums or annuity payments. The payment(s) may be to you as a member of the scheme or to your spouse, children or any other legitimate recipient, as advised by the Trustees as Data Controllers;
- Communication of information in regards to these payments, alternatives to these payments, changes to these payments, changes to your scheme, changes to the services and legislatively required information or legislative updates;
- Analysis of statistics and member feedback for Trustee reporting and service improvements.
Lawful grounds for using your information
We have described the reasons for which we may use information about you or other relevant individuals. We are permitted to process such information in this way, in compliance with data protection legislation, by relying on one or more of the following lawful grounds:
- you or they have explicitly agreed to us processing such information for a specific reason;
- the processing is necessary to perform the agreement we have with you or them or to take steps to enter into an agreement with you or them;
- the processing is necessary for compliance with a legal obligation we have; or
- the processing is necessary for the purposes of a legitimate interest pursued by us, which might be:
- to provide our pensions services and manage the scheme;
- to prevent fraud;
- to protect our business interests;
- to ensure that complaints are investigated;
- to evaluate, develop or improve our services; or
- to keep you informed about relevant products and services, unless you have indicated at any time that you do not wish us to do so.
In relation to any sensitive data, we will generally rely on obtaining specific consent in order to process such information, although it may be necessary for us to use certain information in order to comply with our legal obligations as a regulated entity (such as in relation to an alleged offence).
Where you have consented to our processing of such information (including sensitive categories of personal data) you or they may withdraw such consent at any time, by contacting us using the contact details below. Please note, however, that in certain circumstances it may be still lawful for us to continue processing this information even where consent has been withdrawn, if one of the other legal bases described above is applicable. Please note that not providing or withdrawing consent could mean that we have insufficient evidence to assess your eligibility or continued eligibility for certain benefits.
Keeping your personal data
We keep your personal data for as long as reasonably necessary for the proper running and administration of your scheme, the performance of our legal obligations and the pursuit of our legitimate interests. This will involve us regularly reviewing our files to check that information is accurate and up-to-date and still required. Because trustees of pension schemes can commonly face complaints or questions from members, former members, other individuals or regulatory authorities many years after a member / beneficiary has ceased to be entitled or prospectively entitled to benefits, we will hold some personal data as long as it is seen to be required to defend against legal claims.
We do not carry out automated decision-making or profiling in relation to your personal data.
Sharing your personal data
It is our policy to protect your right to privacy and we will ensure that adequate technical and organisational security measures, confidentiality obligations and compliance procedures are at all times in place to prevent inappropriate use of personal data.
We may share data with third parties for the purposes described in this notice, subject to the policies and procedures we have in place to keep your data safe.
In particular, data may be disclosed to the following third parties:
- the Trustees of your pension scheme;
- the Trustee’s actuary, legal and other professional advisers;
- insurance companies;
- any other service providers who hold or process your data on our behalf;
- third parties to whom we are required to transfer data by law or regulatory requirements (e.g. government and regulatory authorities); and
- any other person or organisation after a restructure, sale or acquisition as long as that person uses your information for the same purposes as it was originally given to us or used by us (or both).
However, we will only disclose personal data where this is reasonably necessary for the purposes of the proper running and administration of your scheme, including the provision of benefits in respect of you from the pension scheme, or where otherwise required by law or regulatory requirements.
We will only transfer your personal data outside the UK / European Economic Area, where such a transfer is permissible under Data Protection Legislation and meets our data security requirements.
Sharing your personal data outside of the EEA
Information about you or other relevant individuals in our possession may be transferred to other countries (which may include countries outside the European Economic Area) for any of the purposes described in this notice, including our transmission of such information to agents outside the European Economic Area. If any such information (including special categories of personal data) belongs to relevant individuals other than you, by providing us with such information you confirm that you have obtained any necessary permissions from such persons to the reasonable use of their information for such purposes in accordance with the following provisions, or are otherwise permitted to give us this information on their behalf.
You and they understand and accept that these countries may have differing (and potentially less stringent) laws relating to the degree of confidentiality afforded to the information it holds and that such information can become subject to the laws and disclosure requirements of such countries, including disclosure to governmental bodies, regulatory agencies and private persons, as a result of applicable governmental or regulatory inquiry, court order or other similar process. In addition, a number of countries have agreements with other countries providing for exchange of information for law enforcement, tax and other purposes.
When we, or our permitted third parties, transfer information outside the European Economic Area, we or they will impose contractual obligations on the recipients of that data to protect such information to the standard required in the European Economic Area. We or they may require the recipient to subscribe to international frameworks intended to enable secure data sharing. In the case of transfers by us, we may also transfer your information where:
- the transfer is to a country deemed to provide adequate protection of your information by the European Commission; or
- you and other relevant individuals have consented to the transfer.
If we transfer your information outside the European Economic Area in other circumstances (for example because we have to provide such information by law), we will use best endeavours to put in place appropriate safeguards to ensure that your information remains adequately protected.
Know your rights
You and other relevant individuals have a number of rights concerning the way that we use your information. You are responsible for ensuring that other relevant individuals are aware of these rights. At any time, such individuals shall have the right:
- to be informed about the processing of their personal data (i.e. for what purposes, what types, to what recipients it is disclosed, storage periods, any third party sources from which it was obtained, confirmation of whether we undertake automated decision-making, including profiling, and the logic, significance and envisaged consequences);
- to request access to, or a copy of, any personal data we hold about them;
- to request the rectification of their personal data, if they consider that it is inaccurate.;
- to request the erasure of their personal data, if they consider that we do not have the right to hold it;
- to object to their personal data being processed for a particular purpose or to request that we stop using their information;
- to request not to be subject to a decision based on automated processing and to have safeguards put in place if they are being profiled based on their personal data;
- to ask us to transfer a copy of their personal data to themselves or to another service provider or third party where technically feasible and otherwise required by applicable regulations;
- to withdraw, at any time, any consent that they have previously given to us for our use of their personal data; or
- to ask us to stop or start sending them marketing messages at any time.
Access to Your Information
You and other relevant individuals may have a right of access to some, or all, of the information we hold about you or them, or to have any inaccurate information corrected, under the data protection legislation. Any request for access to or a copy of your personal data must be in writing and we will endeavour to respond within a reasonable period and in any event within one month in compliance with data protection legislation. We will comply with our legal obligations as regards any individual’s rights as a data subject.
We aim to ensure that the information we hold about you or other relevant individuals is accurate at all times. To assist us in ensuring that such information is up to date, please let us know if the personal details of you or other relevant individuals change by contacting us using the contact details below. We will correct any incorrect or incomplete information and will stop processing personal data, or erase it, where there is no legal reason for us to continue to hold or use that information.
Telephone: 0800 122 3200 (from outside of the UK +44 20 3727 9850)
Please note that a request for us to erase your personal data or to restrict / stop us processing your personal data could impact our ability to provide your pension benefits.
You also have the right to lodge a complaint with the Information Commissioner’s Office (www.ico.org.uk) on 0303 123 1113 if you are unhappy with the way your personal data is being processed.