We take your privacy seriously
We take your privacy seriously. It is important that you know exactly what we do with personal information that you and others provide to us, why we gather it and what it means to you. This document is being provided to you in line with our obligations under the General Data Protection Regulator (GDPR) which will came into force on 25 May 2018. From that date, the GDPR, together with applicable Irish requirements, will amend existing data protection law and place enhanced accountability and transparency obligations on organisations when using your information. The GDPR introduced changes which will give you greater control over your personal information, including a right to object to processing of your personal information where that processing is carried out for our business purposes.
Please take time to read this notice carefully. If you have any questions about how we use your information, please contact us at the details below in 7.1.
We need to collect and use personal information on behalf of the Trustees of your pension scheme. This privacy notice sets out how we collect, use and protect your personal information and your rights in relation to your information. This information is collected on behalf of your pension scheme Trustees (“data controller”) and processed by the scheme administrator (“data processor”).
Personal information is any information, or a combination of pieces of information, that could reasonably allow you to be identified.
1. Personal Information We Use
We hold or will collect personal information about you from a variety of sources, including information from you directly, information provided by your employer and information we get from other sources, including public databases.
1.1 What Information may we collect directly from you?
The categories of personal information that we collect directly from you include:
(a) personal details (for example, your name, date of birth);
(b) your bank details and Personal Public Service Number (PPSN);
(c) your contact details (for example, your address, phone number and email address);
(d) details about whom you would like us to consider paying benefits to if you die;
(e) if you have paid additional voluntary contributions or if you are a member of a defined contribution Scheme, your choice of fund for investing your contributions
1.2 What information may we collect from other sources (such as your Employer)?
These are examples of categories of information we may collect from other sources:
(a) personal details (for example, your name, date of birth, marital status);
(b) your contact details (for example, your address, phone number and email address):
(c) information necessary to calculate and pay your contributions or benefits (for example, your employment history and salary).
1.3 How will we use your personal information and why?
The ways we use your information include:
(a) identifying you and your survivors and making sure your details are up to date;
(b) communicating with you;
(c) calculating and paying your benefits;
(d) implementing trustee decisions – such as whether to agree to early retirement or how to distribute benefits after your death;
(e) if you have paid additional voluntary contributions to the scheme or if you are a member of a defined contribution scheme we may use your information to decide how to invest assets allocated to your account.
(f) If you are a member of a defined benefit scheme, calculating the actuarial liabilities of the scheme; We must have a legal reason to use your personal This will usually be one of the following:
(a) to fulfil our legal obligations (including any contractual obligations), which includes making sure that your benefits are paid correctly;
(b) to meet our legitimate interests to administer a scheme efficiently;
(c) to meet the employer’s legitimate interests in managing the scheme;
(d) because using the information is necessary in relation to a legal claim.
In a few cases, especially where you have given us information about your health, we need your consent to process your data. Where this applies, you may take back your consent at any time by contacting us using the contact details listed below in 7.1.
2. Information Sharing
2.1 We may share personal information with:
(a) our advisers (such as a scheme actuary, our auditors, and our legal advisers) and their sub- contractors to facilitate the administration of a scheme and your benefits;
(b) other medical advisers where you have requested an ill health benefit;
(c) the Revenue Commissioners, Pensions Authority and other Government organisations, including the Financial Services and Pensions Ombudsman;
(d) insurance companies or other occupational pension schemes and their advisers with a view to securing benefits through long term insurance policies or a merger of
2.2 We may also provide some of your personal information to your employer to help it to make decisions relevant to its role as sponsoring employer of a scheme. We will only do so to the extent we consider necessary for these purposes.
3. Security and Storage
We have in place measures to protect the security of your personal information and keep it confidential. We review these measures regularly to make sure they remain appropriate.
When sharing your personal information with our administrators or another third party we will make sure that they also have measures in place to protect it and keep it confidential and agree to use the personal information only for the purposes we set out.
We will keep your personal information for as long as we have a relationship with you or your survivors. When deciding how long to keep your personal information after our relationship with you has ended, we take into account our legal obligations and regulators’ expectations. We may also retain records to investigate or defend potential legal claims.
4. Your Rights
You have rights regarding your personal information, including the right in certain circumstances to access, correct, delete or transfer your personal information or to restrict or object to our use of it. We may need extra information from you to deal with any request. If you would like to discuss or exercise these rights, please contact us.
5. International Data Transfer
Your personal information may be transferred to, stored, and processed in a country that is not regarded as ensuring an adequate level of protection for personal information under European Union law. Where your personal information is to be transferred outside Ireland (for example by the administrator) we will make sure that there are appropriate safeguards in accordance with applicable legal requirements to protect the information. For more information on any safeguards in place, please contact us – as shown below.
6. Changes to this Policy
We may update this privacy notice from time to time. You will be able to see when we last updated the notice because we will include a revision date. Updates are effective from the date on which they are notified to members or posted on the website (www.alliedpensions.com ).
7. How to Contact Us
7.1 If you have questions or concerns, please contact:
Head of Compliance
Apex Business Centre Blackthorn Road
Dublin D18 N2T6
Tel: 01 2063010
7.2 If you believe that we have not resolved your concerns, you can complain to the Office of the Data Protection Commissioner at firstname.lastname@example.org
7.3 We encourage you to let us know if your personal information changes or if the informations we hold about you is out of date.