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Privacy Notice

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:

(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:

3. Keeping your information safe

Password protection
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:

5. Who we may share your information with

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

(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 or by emailing us at

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.

8. Cookies

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.

Essential cookies
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

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.

Non-essential cookies
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.


(a) By continuing to browse our website, you are agreeing to our use of cookies.

(b) Please note that third parties (including, for example providers of external services like Google Analytics web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies, but may include other types of cookies.

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.

10. Contact

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


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