This Privacy Notice describes how The Pensions Partnership will collect, use and protect your personal information.
Who we are
The Pensions Partnership Ltd
33 Park Square West
1 Why we need to collect personal information
We collect personal information in order to perform our contractual and legal obligations and where there may be a legitimate reason to do so. A legitimate reason would include, for example, where we need to record details of who a scheme member may wish to benefit from their pension fund upon their death. When we need to collect, use and process sensitive personal information, such as your medical details, we will obtain your express consent at the point in time it is required.
2 What personal information do we collect
The personal information we collect about you will include amongst other items:
- Name, date of birth, gender, marital status, contact details (including residential address, telephone numbers and email addresses), nationality, country of residence and National Insurance details;
- Proof of identity;
- Details of your spouse or partner, next of kin, dependants, designated beneficiaries or trustees;
- Financial information (including income, expenditure, credit and bank details);
- Details of your professional advisers (including financial adviser(s), solicitors, accountants and estate agents);
- Employment details, including length of service, salary and tax details, place(s) and type of work undertaken; and
- All communications to and from you by telephone, email, post or otherwise and any information you choose to give us from time to time.
We will also collect details of who you would wish to benefit from your pension fund upon your death via an expression of wishes form. We will only hold this data for the purpose of assisting in determining how benefits may be payable on your death.
In cases where we collect information in connection with close family members and dependants, it will be on the understanding that you have the requisite authority to do so and will advise them of how to access this Privacy Notice.
3 How do we collect personal information
We may collect your personal information directly from a variety of sources, including:
- Written communications; or
- By any other electronic means.
We may also receive personal information from any appropriately appointed third parties, such as your financial adviser, accountant, solicitor and anyone else suitably authorised to pass on personal information on your behalf. We may also obtain information from credit reference agencies, search information providers, business partners, analytics providers, public sources or any other service providers, but in each case, as permitted by applicable law.
4 How do we use personal information
The following detail the main reasons we use your personal information:
- To manage our contractual and legal relationship with you;
- To enable you to obtain a projection or illustration;
- To process your application for the requested products or services;
- To administer the product or services provided including the payment of benefits;
- To comply with legal or regulatory requirements;
- To verify your identity and carry out anti-fraud checks;
- To detect, investigate, report, and seek to prevent financial crime;
- To notify you about changes to our products or services;
- To administer our website;
- To respond to complaints and seek to resolve them;
- To operate our business in an efficient and appropriate manner. This includes testing our systems, managing our financial position, business capability, planning, communications, corporate governance, and audit;
- To exercise our rights set out in agreements or contracts; and
- For any other purpose that we’ve agreed with you from time to time.
5 Security and retention of personal information
The security and storage of your personal information is very important to us and we strive to comply with our obligations at all times. Any personal information which is collected, recorded or used in any way, whether on paper, online or any other media, will have appropriate safeguards applied in line with our data protection obligations.
Your information is protected by controls designed to minimise loss or damage through accident, negligence or deliberate actions. Our employees also protect sensitive or confidential information when storing or transmitting information electronically.
Although we seek to protect your information via appropriate security measures, we cannot guarantee the security of your data transmitted by you or any appointed agent acting on your behalf to our email addresses, websites, and secure portals or to any other modes of receiving information. Any transmission is at your own risk.
We will keep your personal information for as long as you are a client of The Pensions Partnership Ltd.
Where we are no longer engaged to act on your behalf we will ordinarily not retain your personal information for longer than 7 years after we ceased to act on your behalf. This will include where you/we terminated our relationship or upon your death.
We may in certain circumstances retain your data for longer than 7 years if we cannot delete it for legal, regulatory or technical reasons. As an example, we are required by regulations to hold pension transfer information indefinitely. We will however, only use your personal information for such purposes and will make sure that your privacy is protected.
6 Sharing personal information
We may share your personal data (including storage and transfer of data) with:
- Any third party in order to meet our contractual obligations, which will include amongst others;
- Insurance companies
- Investment organisations
- Pension providers
- Investment platforms
- External compliance advisers
- Legal advisers
- Back office system providers
- Third party software providers
- Companies and agents you ask us to share your information with and for whom you have given prior consent for us to share personal information;
- Your co-trustees and/or co-owners of your pension scheme investments;
- Any third party in order to meet our legal and regulatory obligations, including statutory or regulatory bodies, law enforcement agencies, credit reference agencies and company auditors;
- HM Revenue & Customs, regulators such as the Financial Conduct Authority and other authorities like the Information Commissioner’s Office;
- UK Financial Services Compensation Scheme;
- Organisations that introduce you to us;
- Data Brokers (e.g. Experian);
- Direct debit (DD) scheme – if you use DDs;
- Our service providers and agents who process information on our behalf in relation to, for example, payroll providers for processing pension payments, solicitors for any appropriate legal activities, accountants for any relevant financial transactions and internet service providers;
- Any third party in the context of actual or threatened legal proceedings provided we can do so lawfully; and
- Third parties to whom we sell or negotiate to sell our business or assets.
We will put in place data sharing agreements when we share data with third parties. These arrangements will outline the basis for sharing data, together with confirming that the third party will hold and process the data provided in accordance with the GDPR and UK data protection laws.
7 Transferring personal information outside the EEA
The personal information that we collect from you may be transferred to, and stored at destinations outside the European Economic Area (“EEA”). We’ll take all reasonable steps to ensure that in the event your information is transferred outside of the EEA, appropriate measures and controls are in place to protect that information in accordance with applicable data protection laws and regulations in the UK.
We will not send you any unsolicited information outside the remit of fulfilling our contractual and legal obligations without first asking for your express permission to do so.
We will not provide your personal information to any third parties for the purposes of undertaking any form of marketing activities.
9 Your rights
You have the following rights:
- Access to your personal information: You can request access to a copy of your personal information and how we use it. We will not normally charge for providing this information to you;
- Right to withdraw consent: Where you have given us your consent to use personal information, you can withdraw your consent at any time;
- Portability: You can ask us to provide you ora third party with some of the personal information we hold about you in a commonly used electronic form;
- Rectification: You can ask us to change or complete any inaccurate or incomplete personal information held about you;
- Erasure: You can ask us to delete your personal information where it is no longer necessary for us to use it, you have withdrawn consent, or where we have no lawful basis for keeping it. Note that we might be required by regulations to retain your information even if you want it to be deleted;
- Right to object: You can object to our processing of your personal information;
- Restriction: You can ask us to restrict the personal information we use about you where you have asked for it to be erased or where you have objected to our use of it; and
- Right to complain: To lodge a complaint with the Information Commissioner’s Office (ICO), the supervisory authority responsible for data protection matters.
If you withdraw your consent to the processing of your personal information or you ask for your information to be erased, we may not be able to fulfil our obligations under the terms of our contract.
The easiest way to exercise any of your rights would be to contact The Pensions Partnership at the contact details provided below. We’ll provide a response within 30 days and there’s normally no charge for exercising any of your rights.
A cookie is a small file – it’s saved onto your computer or other device when you visit our website. Cookies store small pieces of information. For example – they will remember you’ve visited our website or performed a certain action.
You can set your web browser not to accept cookies and the above website provides you with further information in this regard. However, in certain circumstances some of our website features may not function as required, if you elect to disable cookies.
11 Electronic communication
Unfortunately, sending information via e-mail is not completely secure; anything you send is done so at your own risk. Once received, we will secure your information in accordance with our security procedures and controls.
When we communicate sensitive personal information with you or your agent via any electronic means we will ensure that it is done so securely using either encrypted files or secure messaging.
12 Changes to our Privacy Notice
We may make changes to our Privacy Notice from time to time. Any changes we may make to our Privacy Notice in the future will be found on our website www.thepensionspartnership.co.uk. Hard copies of this document are also available from us by post.
13 Contact us
If you have a concern about the way in which we are collecting or using your personal information you may also contact the Information Commissioner’s Office directly at https://ico.org.uk/concerns/ or in writing to, Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.