First Actuarial’s Privacy Notice where we provide services to an Employer
This notice applies to employees and/or members of a pension scheme run by an employer to which First Actuarial is providing Investment Advice and / or Actuarial Services.
Purpose of this notice
This privacy notice is issued by First Actuarial. It explains how we collect and process personal data when we provide actuarial and/or investment advice to employers.
When providing such advice, we may need to use personal data relating to:
- members of the employer’s pension scheme (active, deferred or pensioner members); and/or
- other employees who are not members of the employer’s pension scheme (for example, where we are advising the employer about setting up a new scheme).
The employer will explain in their privacy notice how they use any other personal data they hold on you. They may also give more specific information on how First Actuarial uses your personal data. If they do give more specific information you should rely on that information, in preference to information given in this notice.
It is important that you read this notice together with any other privacy notice we or the employer may provide, so that you are fully aware of how and why we are using your personal data.
We may update this privacy notice from time to time.
First Actuarial will normally act as a joint data controller, with the employer, for your personal data.
What personal data do we hold and how do we use it?
The information we hold on you may include:
- personal information including name and date of birth;
- details of your employment history, including salary information;
- information on benefits you will receive from the pension scheme;
- records of any benefits you have transferred into the scheme from other pension arrangements;
- records of any additional contributions you, or the employer on your behalf, have paid into the scheme;
- other more specific information if required for the advice we are giving.
We only hold your personal data because we need it to help the employer understand their financial commitments to the pension scheme and to comply with pension scheme regulations. Actuarial work involves giving the employer advice about things like:
- assumptions on possible future experience of the scheme to enable the employer to discuss with the trustees of the scheme how much money is needed to provide all the benefits promised to scheme members (this an “actuarial valuation”);
- financial and risk modelling of the liabilities of the scheme to provide investment advice;
- reporting to the Pensions Regulator, HMRC and other authorities as required by law or guidance;
- calculating enhanced transfer values or other benefit options when the employer and/or trustees of the scheme wish to carry out a liability management exercise;
- advising the employer about making changes to the scheme benefits;
- advising the employer about setting up a new pension arrangement.
Why do we hold this information?
The lawful reason we hold this data is because we have a legitimate interest in providing actuarial advice to the employer.
Where did we get information about you?
The personal data we hold about you was given to us either by the employer or by the trustees of your pension scheme.
Who do we share your information with?
We may share your personal data with other parties if this is necessary. Where we do share information with these parties, we remain in control of the data and will ensure that suitable data protection agreements are in place.
We may transfer your data to separate third parties. These parties are:
- official organisations to whom we have a legal obligation to provide information. This may include the Pensions Regulator and HMRC, for example;
- insurance companies, for example, if the employer is responsible for securing group life insurance cover whilst you are an employee.
We only share information about you where it is necessary to enable us to advise the employer. We do not share information about you for any other reason.
First Actuarial will not transfer data outside of the European Economic Area unless authorised by the employer or you have agreed to such a transfer.
How long do we keep your data?
We will keep information about you while we provide services to the employer. If the employer no longer requires our services, we will keep a copy of the data for a minimum of one year and a maximum of seven years. We will always store your data securely, as required by data protection laws.
You may ask for a copy of the information we and the employer hold on you. This should, normally, be done by contacting the employer.
If, at any point, you believe the information we hold on you is wrong, you can ask for it to be corrected.
In some circumstances, you may also have a right to ask us to restrict the processing of your personal data, to object to processing or to transfer or erase your personal data. You can obtain further information about these rights from the Information Commissioner’s Office at: www.ico.org.uk or via their telephone helpline (0303 123 1113).
If you wish to raise a complaint on how your personal data is handled, you may want to contact the relevant employer, as they appointed us and are in overall charge of how your data is used.
You may also raise a complaint on how your personal data is handled by contacting the employer. If you are not satisfied with their response or believe the way your personal data is processed is not in accordance with the law, you can complain to the Information Commissioner’s Office.
Keep information up to date
It is important that the information we hold about you is accurate and current. If you are aware that the information we hold is incorrect then you can get it updated. This should normally be done by contacting your employer in the first instance.
The employer who appointed us to provide advice is normally in overall control of how your data is used. If you would like further details on how your personal information is used you should contact them in the first instance.
If you are unable to contact the employer for any reason, you may contact us:
- for further details on how we use your personal information; or
- with any other questions about this privacy notice, including any requests to exercise your rights.
Our contact details are:Data Protection
First Actuarial LLP