Privacy Policy – Abbey Group Limited Pension and Life Assurance Scheme

ABBEY GROUP LTD PENSION AND LIFE ASSURANCE SCHEME

Pension Member Privacy Notice

Abbey Group Pension Fund Limited is committed to protecting the privacy and security of your personal data. This Privacy Notice describes how we and our affiliates, and related entities (collectively “we,” or “us”) collect and process personal data about you during and after your employment. This Privacy Notice applies to current and former members only. This privacy notice applies to members located in the UK.

This Privacy Notice describes the categories of personal data that we collect, how we use your personal data, how we secure your personal data, when we may disclose your personal data to third parties, and when we may transfer your personal data outside of your home jurisdiction.

This Privacy Notice also describes your rights regarding the personal data that we hold about you including how you can access, correct, and request erasure of your personal data.

We will only process your personal data in accordance with this Privacy Notice unless otherwise required by applicable law. We take steps to ensure that the personal data that we collect about you is adequate, relevant, not excessive, and processed for limited purposes.

Collection of Personal Data

For purposes of this Privacy Notice, personal data means any information about an identifiable individual. Personal data excludes anonymous or de-identified data that is not associated with a particular individual. To carry out our activities and obligations as an employer, we may collect, store, and process the following categories of personal data, which we require/some of which we require for the purpose of administering the employment relationship with you:

Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses.
Date of birth.
Gender.

Marital and dependent status, only when needed to administer benefits such as health insurance or pension benefits.
Beneficiary and emergency contact information.
Government identification numbers such as social insurance or other national insurance number, driver’s license number, or other identification card number.
Bank account details and payroll information.
Pension entitlement information.
Employment records (including work history, and proof of work eligibility).
Photograph for identification purposes.
Other personal details included in a cover letter or that you otherwise voluntarily provide to us.

The personal data listed in this notice is mandatory in order for us to administer the pension relationship. Failure to provide or allow us to process mandatory personal data may affect our ability to accomplish the purposes stated in this Privacy Notice.

Use of Personal Data

We only process your personal data where applicable law permits or requires it, including where the processing is necessary for the performance of our employment contract with you, where the processing is necessary to comply with a legal obligation that applies to us as your employer, for our legitimate interests or the legitimate interests of third parties, to protect your vital interests, or with your consent if applicable law requires consent. We may process your personal data for the following legitimate business purposes and for the purposes of performing the employment contract with you:

Member/Employee administration (including payroll and benefits administration).
Business management and planning.
Processing member/employee work-related claims (for example, insurance claims).
Accounting and auditing.
Complying with applicable law.
Complying with health and safety obligations.

We will only process your personal data for the purposes we collected it for or for compatible purposes. If we need to process your personal data for an incompatible purpose, we will provide notice to you and, if required by law, seek your consent. We may process your personal data without your knowledge or consent only where required by applicable law or regulation.

We may also process your personal data for our own legitimate interests, including for the following purposes:

To prevent fraud.
To ensure network and information security, including preventing unauthorised access to our computer and electronic communications systems and preventing malicious software distribution.

You will not be subject to decisions based on automated data processing without your prior consent.

Collection and Use of Special Categories of Personal Data

The following special categories of personal data are considered sensitive and may receive special protection:

Racial or ethnic origin.
Political opinions.
Religious or philosophical beliefs.
Genetic data.
Biometric data.
Data concerning health.
Data concerning sex life or sexual orientation.
Data relating to criminal convictions and offences.

We may collect and process the following special categories of personal data when you voluntarily provide them for legitimate business purposes, to carry out our obligations under employment law, for the performance of the pension/employment contract, or as applicable law otherwise permits.

Where we have a legitimate need to process special categories of personal data about you for purposes not identified above, we will only do so only after providing you with notice and, if required by law, obtaining your prior, express consent.

Data Sharing

We will only disclose your personal data to third parties where required by law or to our employees, contractors, designated agents, or third-party service providers who require such information to assist us with administering the pension relationship with you, including third-party service providers who provide services to us or on our behalf. Third-party service providers may include, but not be limited to, payroll processors, benefits administration providers, and data storage or hosting providers. These third-party service providers may be located outside of the UK.

We require all our third-party service providers, by written contract, to implement appropriate security measures to protect your personal data consistent with our policies and any data security obligations applicable to us as your employer. We do not permit our third-party service providers to process your personal data for their own purposes. We only permit them to process your personal data for specified purposes in accordance with our instructions.

We may also disclose your personal data for the following additional purposes where permitted or required by applicable law:

To other members of our group of companies (including outside of your home jurisdiction) for the purposes set out in this Privacy Notice and as necessary to perform our employment contract with you.
As part of our regular reporting activities to other members of our group of companies.
To comply with legal obligations or valid legal processes such as search warrants or court orders. When we disclose your personal data to comply with a legal obligation or legal process, we will take reasonable steps to ensure that we only disclose the minimum personal data necessary for the specific purpose and circumstances.
To protect our rights and property.
During emergency situations or where necessary to protect the safety of persons.
Where the personal data is publicly available.
If a business transfer or change in ownership occurs and the disclosure is necessary to complete the transaction. In these circumstances, we will limit data sharing to what is absolutely necessary and we will anonynmise the data where possible.
For additional purposes with your consent where such consent is required by law.

Cross-Border Data Transfers

Where permitted by applicable law, we may transfer the personal data we collect about you to other jurisdictions that may not be deemed to provide the same level of data protection as our laws do, as necessary to perform our employment contract with you and for the purposes set out in this Privacy Notice.

Data Security

We have implemented appropriate physical, technical, and organisational security measures designed to secure your personal data against accidental loss and unauthorised access, use, alteration, or disclosure. In addition, we limit access to personal data to those employees, agents, contractors, and other third parties that have a legitimate business need for such access.

Data Retention

Except as otherwise permitted or required by applicable law or regulation, we will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, as required to satisfy any legal, accounting, or reporting obligations, or as necessary to resolve disputes. To determine the appropriate retention period for personal data, we consider our statutory obligations, the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes we process your personal data for, and whether we can achieve those purposes through other means.

Under some circumstances we may anonymise your personal data so that it can no longer be associated with you. We reserve the right to use such anonymous and de-identified data for any legitimate business purpose without further notice to you or your consent. Once you are no longer an pension member of the scheme, we will retain and securely destroy your personal data in accordance with applicable laws and regulations.

Rights of Access, Correction, Erasure, and Objection

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your pension relationship. By law you may have the right to request access to, correct, and erase the personal data that we hold about you, or object to the processing of your personal data under certain circumstances. You may also have the right to request that we transfer your personal data to another party. If you want to review, verify, correct, or request erasure of your personal data, object to the processing of your personal data, or request that we transfer a copy of your personal data to another party, please contact David Dawson. Any such communication must be in writing.

We may request specific information from you to help us confirm your identity and your right to access, and to provide you with the personal data that we hold about you or make your requested changes. Applicable law may allow or require us to refuse to provide you with access to some or all of the personal data that we hold about you, or we may have destroyed, erased, or made your personal data anonymous in accordance with our record retention obligations and practices. If we cannot provide you with access to your personal data, we will inform you of the reasons why, subject to any legal or regulatory restrictions.

Right to Withdraw Consent

Where you have provided your consent to the collection, processing, or transfer of your personal data, you may have the legal right to withdraw your consent under certain circumstances. To withdraw your consent, if applicable, contact David Dawson.

Changes to This Privacy Notice

We reserve the right to update this Privacy Notice at any time, and we will provide you with a new Privacy Notice when we make any updates. If we would like to use your previously collected personal data for different purposes than those we notified you about at the time of collection, we will provide you with notice and, where required by law, seek your consent, before using your personal data for a new or unrelated purpose. We may process your personal data without your knowledge or consent only where required by applicable law or regulation.

If you have any questions about our processing of your personal data or would like to make an access or other request, please contact us at: aglplas@abbeydev.co.uk.