Privacy Notice

About this Notice

PensionPal Limited is committed to protecting the privacy and security of personal information. This privacy notice explains how we collect and use personal information in accordance with the data protection law.

About us

Our organisation is PensionPal Limited (“PensionPal”).

The types of personal data we collect

The specific types of personal information we may collect and use about you depend on our relationship with you.

Clients

In order to provide services to our clients we will collect and process personal data about our contacts.

The types of personal data we collect include:

• Name
• Job title
• Business address
• Email Address
• Telephone number
• Records of telephone conversations
• Records of meetings
• Email correspondence

Suppliers

In order to maintain our relationship with our suppliers we will collect and process data about our contacts at the supplier.

The types of personal data we collect include:

• Name
• Job title
• Business address
• Email Address
• Telephone number
• Records of telephone conversations
• Records of meetings
• Email correspondence

Prospective clients

In order to provide information about our products and services to prospective clients we maintain a database of contact information. We obtain data from third parties including Wilmington plc (Pension Funds Online).

The types of personal data we collect include:

• Name
• Job title
• Business address
• Email Address
• Telephone number
• Records of telephone conversations
• Records of meetings
• Email correspondence

Associates and contractors

Where we enter a business relationship with an associate or contractor we collect and process data in order to maintain the relationship and honour contractual obligations.

The types of personal data we collect include:

• Name
• Address
• Email Address
• Telephone number
• Date of birth, gender, marital status and National Insurance number
• Bank account details
• Details of next of kin (including name, relationship, contact details)
• Screening information including work permits, proof of identity, proof of address, credit checks, criminal record checks, CCJs and bankruptcy
• References
• Qualifications and employment history

Job applicants

In order to consider job applications we will collect and process data from applicants.

The types of personal data we collect include:

• Name
• Address
• Email Address
• Telephone number
• Date of birth, gender and marital status
• CV and covering letter
• References
• Qualifications and employment history
• Records of telephone conversations
• Records of meetings
• Email correspondence

Professional contacts

In order to maintain relationships with professional contacts we will collect and process data about each contact.

The types of personal data we collect include:

• Name
• Address
• Email Address
• Telephone number
• Records of telephone conversations
• Records of meetings
• Email correspondence

Staff

We collect and process data about our staff. Details about the types of data we collect and the purpose of processing is provided directly to staff by our data protection representative.

Our Lawful basis for processing your data

In order to process your data legitimately we rely on several legal grounds (called lawful bases). These legal bases include obtaining your consent, processing because it is in our legitimate interest, processing to meet our obligations under a contract and in order to comply with legal obligations.

Where we rely on legitimate interest as a reason for processing data, we are required to consider whether or not those interests are overridden by your rights and freedoms. Where we adopt legitimate interests as our reason for processing data we will have concluded that our legitimate interests are not overridden by your rights and freedoms.

Consent

There may be situations where we need to obtain your explicit consent to collect and process your personal data. If we ask you for your consent you may withdraw your consent at any time.

Sharing your information

We may share your personal data, where appropriate, internally and with organisations including the following:

• Our legal advisors
• Our accountants
• Associates and contractors who require your information to fulfil a contract with us
• IT service providers
• Insurers
• Tax, audit and other authorities
• Suppliers who perform background screening on our behalf
• Payment processors and our bank
• If we merge with or are acquired by another business or company in the future, or are in meaningful discussions about such a possibility, we may share your personal data with the prospective new owners
• Competent authorities, e.g. courts, tribunals, regulators, law enforcement agencies

In instances where we share or outsource the processing of your information to a third party, we oblige them to protect your information with appropriate security measures and prohibit them from using your information for their own purposes.

We reserve the right to disclose any information we hold about you if we are compelled to do so by a court of law or requested to do so by a government entity or if we determine it is necessary or desirable to comply with the law or to protect or defend our rights or property.

Transferring your data across borders

We avoid transferring your personal data to countries outside the European Economic Area (EEA) wherever possible. Where it is not possible to avoid transferring, we will only do so where it is compliant with data protection legislation and the means of transfer provides adequate safeguards in relation to your data.

How long we will be keep your personal data

We will only keep your personal data for as long as we need to in order to fulfil the purposes for which it was collected, as set out in this statement, and for as long as we are required to by law.

We will delete your data when it is no longer required.

How we safeguard your data

We are committed to taking reasonable and appropriate steps to protect the personal data we hold from misuse, loss or unauthorised access. We do this by taking a range of appropriate technical and operational steps. These include measures to deal with any suspected data breaches. If you suspect any misuse, loss or unauthorised access to your personal data please let us know immediately.

Your rights

Under data protection legislation, you have certain rights with respect to your information, as follows:

• Right to request that we provide you with a copy of the personal data that we hold about you
• Right to request us to correct any information that we hold about you that is incorrect or out of data
• Right to request us to erase your personal data, where we no longer have a lawful basis or valid business reason to hold it
• Right to restrict the processing of your personal data
• Right to be informed about how your personal data is collected and used
• Right to object to the way we are processing your information
• Right to request that we send all or some of the personal data we hold about you to another organisation
• Right to withdraw your consent where we have obtained your consent to process personal data

If you would like to exercise any of your rights mentioned above, you can do so by writing to or emailing our data protection representative using the contact details at the start of this statement.

Opting Out

You have the right to opt out of marketing activities at any time using the contact details at the start of this statement.

Making a complaint

If you have a complaint about the way we process your personal data or you think that we have not complied with your rights you can contact us using the contact details at the start of this notice, or you can make a complaint to:

Changes to this policy

We regularly review, and where necessary, update our privacy information. Changes to our policy will be notified by email or via our website.