1. Introduction and General Terms
(a) This Privacy Notice sets out how ICI Pensions Trustee Limited, the Trustee of the ICI Pension Fund, (“Trustee”, “we”, “us”, “our”) obtains, uses and protects any personal information that you provide to us, or that is otherwise obtained or generated by us, and which relates to you or to any individual connected with you.
(b) This Privacy Notice explains the following:
- keeping your information safe;
- what we may use your information for;
- who we may share your information with; and
- your rights regarding the personal information you provide to us.
(c) By providing us with your personal information (or by allowing your employer to provide us with your personal information), you agree to the processing of your personal information as outlined in this Privacy Notice.
(d) For the Purposes of the Data Protection Act 1998 (the Act), the data controller is ICI Pensions Trustee Limited of 3rd Floor, 38 Lombard Street, London, EC3V 9BS registered number 2512713.
2. Information we may collect about you
How do we collect personal information about you?
(a) Personal information broadly means information that identifies (or which could, with other information that we hold or are likely to hold, identify) a living individual. This would therefore include any information provided to us in relation to your actual or potential membership of the ICI Pension Fund (the “Fund”) when you or your employer contacts us online, by phone, text, email, post or any other engagement or correspondence that you or your employer may have with us.
What types of personal information may we collect about you?
(b) We may hold any or all of the following personal information about you:
- personal details such as your name, gender, age, date of birth, email address, postal address, telephone or mobile number, description of physical or mental health and identifiers such as National Insurance number and your employee number;
- family, lifestyle and social circumstances such as details about current marriage and partnerships and marital history, details of family and dependents;
- employment details such as pensionable pay, length of service, employment and career history, recruitment and termination details, attendance record, health and safety records, security records, job title and job responsibilities, financial details such as income, salary, assets and investments, bank account details to process pension payments, benefits, grants and insurance details; and
- technical information and other information about your visits to ePA (the Fund administrator’s online administration site) and our website – you can find more information about this in paragraphs 7 and 8, below.
3. Keeping your information safe
Where we have given you (or where you have chosen) a password which enables you to access ePA, you are responsible for keeping such password confidential. We ask you not to share the password with anyone. HM Government’s National Cyber Security Programme recommends making your password stronger by using three random words, and numbers/symbols if needed. Please avoid using the same password for multiple online accounts.
If you are using a computer or terminal in a public location, we recommend that you always log out and close the website browser when you complete an online session for your security.
Transfers of your information
(a) We may transfer, store, or process your personal information at a destination outside the European Economic Area (EEA). Where the countries to which your personal information is transferred may not offer an equivalent level of protection for personal information to the laws of the UK, we will take reasonable steps to ensure that your information is treated securely and in accordance with this Privacy Notice.
(b) Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the safety of your information transmitted to our website; any transmission is at your own risk. Once we have received your information, we will use reasonable procedures and security features to try to prevent unauthorised access.
4. What we may use your information for
(a) The Trustee will use your personal information for the following purposes:
- to administer the Fund including to process data to calculate and pay benefits;
- to carry out our obligations arising from any agreement that we have with, or concerning, you and to provide you with the information, benefits and services that you request from us;
- in relation to any correspondence (including queries relating to your membership of the Fund) related to the administration of the Fund;
- to notify you about our services and changes to our services;
- for statistical, financial modelling and reference purposes;
- for internal record keeping;
- risk management including credit risk analysis;
- complying with any present or future law, rule, regulation, guidance or directive, and complying with any industry or professional rules and regulations or any applicable voluntary codes;
- complying with demands or requests made by local and foreign regulators, governments and law enforcement authorities, and complying with any subpoena or court process, or in connection with any litigation;
- in connection with any sale, merger, acquisition, disposal, recognition or similar change involving the Fund;
- to use IP addresses to identify the location of users, to block disruptive use, to establish the number of visits from different countries;
- to analyse and improve the activities, services and information offered by ePA (the Fund administrator’s online administration site) or the Trustee website; and
- for any other purposes connected with the proper administration of the Fund. This may involve passing data about you to the Fund’s sponsoring employers, scheme actuary, professional advisers, administrator and third parties (including insurance companies, counterparties to Fund investments and other third parties), as may be necessary or desirable for such third party recipients to process such data for the purposes set out above and, where necessary, for any regulatory or administrative purpose. This may include your data being sent outside the EEA. If you require further information regarding the protection of your data, please contact the Fund administrator, Willis Towers Watson (whose data protection policy is available at http://www.towerswatson.com/personal-data). Your data may also be passed to The Law Debenture Corporation plc in its capacity as a corporate director of the Trustee. Their data protection policy is available at www.lawdeb.com/privacy-policy.
(b) In relation to bulk annuity policies held by the Trustee or further policies under consideration, the insurers may process your data for internal compliance and business administration purposes; to fulfil their obligations under the policy, any re-insurance policy or hedging contract; and for statistical, financial modelling and reference purposes to the extent permitted by applicable law. The insurers may need to disclose your data to members of its group for those purposes, but will only do so on a strictly "need-to-know" basis and in such a way as to preserve its strictly confidential nature. Data may also be transferred to re-insurers that the insurers work with. Where appropriate, this may involve data being transferred outside the EEA for the purposes outlined in this paragraph. If your personal data is transferred in this way the insurers will ensure it is protected in accordance with the legal requirements of the Act.
(c) We will hold your personal information on our systems for as long as is necessary for the relevant activity or services although, if necessary, processing of your information may continue after you have opted out of the Fund or the cessation of any benefits provided to you by us.
5. Who we may share your information with
(a) We may share or disclose your information to any of the following recipients:
- the Fund’s administrator, sponsoring employers and the counterparties to the Fund’s investments;
- in certain circumstances, your data may be passed to the scheme actuary and Willis Towers Watson (whose data protection policy is available at http://www.towerswatson.com/personal-data). The scheme actuary and/or Willis Towers Watson may be data controllers or joint data controllers in this capacity;
- our service providers, professional advisers and auditors;
- The Law Debenture Corporation plc in its capacity as a corporate director of the Trustee;
- local or foreign regulators, governments and law enforcement authorities;
- local and foreign courts, tribunals and arbitrators or other judicial committees;
- insurance companies (such as Legal & General, Scottish Widows and Prudential) and their reinsurers; and
- persons in connection with any sale, merger, acquisition, disposal, reorganisation or similar change involving the Fund (including any potential or actual purchaser and their advisors).
(b) From time to time, our website may contain links to other websites. If you follow a link to any of these websites, please note that these websites will have their own privacy policies and that we do not accept any responsibility or liability for these organisations or their activities. Please check these policies before you submit any personal information to these websites.
6. Your rights regarding the personal information you provide to us
(a) The accuracy of the information we hold about you is important to us. Under the Act you have the right to access the information we hold about you and have any inaccuracies corrected. Any access request may be subject to a fee of £10 to meet our costs in providing you with details of the information we hold about you.
(b) If any of the information we hold about you is inaccurate or out of date or you object to us processing it, please let us know by completing the relevant forms available at http://icipensionfund.org.uk/library-and-forms or by emailing us at email@example.com.
7. Technical information that we may collect about you
When you visit our website, we may collect technical information about your computer, such as your internet protocol address (which is a number that can uniquely identify a specific computer on the internet), your login information, browser type and version, browser plug-in types and versions, operating systems and platforms. We may also collect information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs) and methods used to browse away from the page.
Cookies are small text files sent by websites to your computer, or other access device, that can be used to make a user's experience more efficient. The law states that we can store cookies on your machine if they are essential for us to provide services you have requested on this website, but that for all other cookies we need your permission to do so. We use essential cookies to ensure you get the best experience whilst using this website.
We may store information using cookies which we can access when you visit our site in future. The cookies listed below are essential to the functionality of the site. You can access them through some types of browser.
If you want to delete any cookies that are already on your computer, please refer to the instructions for your file management software to locate the file or directory that stores cookies. You can also block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. Please note, however, that deleting our cookies or disabling future cookies may prevent your access to some or all areas and features of the website.
To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit aboutcookies.org.
|Cookie Name||Cookie Description|
|csrftoken||This cookie helps to provide additional protection against Cross Site Request Forgeries.|
|epa_sessid||This cookie is used to help manage your sessions in ePA (the Fund administrator’s online administration site). Session cookies allow users to be recognized within a website so any page changes, item or data selection you do is remembered from page to page.|
|sessionid||This cookie is also used to help manage your sessions within the site.|
|cookieStatus||This cookie is used to remember if you have viewed the cookie warning.|
These cookies are used by Google Analytics to measure site traffic and help enhance the site. We don’t allow Google to use or share our analytics data and personal information is not gathered.
|Cookie Name||Cookie Description|
|utma||This cookie is used by the RSS feed generator to measure generic usage.|
|_ga||This cookie is used by Google Analytics to help us measure how many people visit this site.|
|_gat||This Google Analytics cookie is used to manage the rate at which page view requests are made.|
9. Changes to our Privacy Notice
Any changes we make to our Privacy Notice in the future will be posted on this page. Please check back frequently to see any updates or changes to our Privacy Notice. Any changes to this Privacy Notice will become effective when we post the revised Privacy Notice on our website. Your use of the website, or continued participation in the Fund, following these changes means that you accept the revised Privacy Notice.
If you have any questions, comments or requests regarding any aspect of this Privacy Notice, please do not hesitate to contact us at:
ICI Pensions Services
PO Box 545
Phone: 0800 916 8021