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Privacy Notice

1. Introduction and General Terms

(a) This data protection policy 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 data protection policy explains the following:

(c) The data controller is ICI Pensions Trustee Limited of 5th Floor, 36-38 Botolph Lane, London, EC3R 8DE, registered number 2512713.

2. Personal Information we may collect about you

What types of personal information may we collect 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 or another’s actual, past or potential membership of the ICI Pension Fund (the “Fund”).

(b) We may hold any or all of the following personal information about you:

How do we collect personal information about you?

(c) We collect your personal information when you, your employer, a member of the Fund or another person contacts us online, by phone, text, email or post. We obtain your personal information where this is provided through any other engagement or correspondence that you, your employer, a member of the Fund or another person may have with us.  We may also obtain your personal information through the use of third party tracing services where we believe that we hold inaccurate data for you.

3. Keeping your personal information safe

Password protection

(a) Where we have given you (or where you have chosen) a password which enables you to access the ePA (the Fund administrator’s online administration site), you are responsible for keeping such password confidential. We ask you not to share the password with anyone.  The ePA system has minimum password requirements which you will need to comply with.  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.

(b) 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 personal information

(c) 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 personal information is treated securely and in accordance with this data protection policy. This may include entering into data transfer agreements based on the model clauses approved by the European Commission, to ensure that third parties to whom we transfer personal information in those countries nevertheless commit to ensuring an adequate level of protection for your personal information (further information on the model clauses can be found on the following website: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en).

(d) 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 personal information transmitted to our website; any transmission is at your own risk. Once we have received your personal information, we will use reasonable procedures and security features to try to prevent unauthorised access.

4. What we may use your personal information for

(a) The Trustee may use your personal information for the following purposes:

(b) We process your personal information for the purposes described in paragraph 4(a) on the grounds that processing is necessary for compliance with a legal obligation to which we are subject and/or it is in our legitimate interest to do so including:

(c) In relation to bulk annuity “buy-in” 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 Data Protection Act 1998 or other applicable legislation.

5. How long do we retain your records

We will hold your personal information (and any personal information collected in respect of any individual connected with you) on our systems for as long as you or your family or dependants are receiving benefits from the Fund, and subsequently for such period as  the Trustee may from time to time consider appropriate. As of 25 May 2018 the Trustee has decided it is appropriate to retain all personal data on an indefinite basis.

6. Who we may share your personal information with

(a) We may share or disclose your personal information to any of the following recipients:

(b) From time to time, our website may contain links to other websites, including of our partner organisations and advertisers. 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.

7. Your rights regarding the personal information you provide to us

(a) The nature and accuracy of the information we hold about you is important to us. You have the right, in accordance with the law:

(b) If you would like to exercise any of your rights described above, please let us know by emailing us at ici@willistowerswatson.com.

8. What if you do not provide us with your personal information

(a) We may not be able to perform actions necessary to achieve the purposes set out above and you may not be able to make use of the services offered by us if:

9. Technical information that we may collect about you

(a) When you visit our website, we may collect technical information about your computer, such as your 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), page response times, length of visits to certain pages, page interaction information (such as clicks) and methods used to browse away from the page.

(b) You can find more information about the types of technical information that we collect about you in our Cookies Policy (which can be found at http://www.icipensionfund.org.uk/cookies/).

10. Changes to our data protection policy

Any changes we make to our data protection policy in the future will be posted on this page. Please check back frequently to see any updates or changes to our data protection policy. Any changes to this data protection policy will become effective when we post the revised data protection policy on our website. The date of the most recent revisions will appear on this page. Your use of the website or continued participation in the Fund following these changes means that you accept the revised data protection policy.

11. Contact

If you have any questions, comments or requests regarding any aspect of this data protection policy, please do not hesitate to contact us at:

ICI Pensions Services
PO Box 545
Redhill
Surrey
RH1 1YZ

Phone: 0800 916 8021
Email: ici@willistowerswatson.com

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