GDPR Privacy Notice
Carey Pensions UK LLP and Carey Corporate Pensions UK Ltd “The Companies” are committed to respecting and safeguarding your privacy and the processing of your personal information for legitimate and lawful business purposes in line with the General Data Protection Regulation (GDPR) compliance.
The new regulation ensures and enforces your right to have your privacy respected and your data protected. It also enables you to have easier access to the personal information organisations hold about you to ensure it is accurate, up to date and processed lawfully and fairly.
The companies act as both a “data controller” and “data processor”.
The companies are committed to protecting the rights and freedoms of data subjects ensuring the safe and secure processing of their data in accordance with the GDPR regulations. The companies will comply with GDPR and will ensure that all personal data is fairly and lawfully obtained and processed and securely held, in accordance with this policy.
How we receive your data
The Companies receives your data either directly from you (“the data subject”) or from any other firm, for example; your appointed Independent Financial Advisor (IFA), your ceding scheme or your employer (“the third party”). Data is received either manually or electronically.
Principles of the GDPR
The data protection principles set out the main responsibilities for organisations and stipulates the following for personal data:
- Lawful, fair and transparent
- Limited for it’s purpose
- Data minimisation
- Integrity and Confidentiality
The data we hold to administer your pension scheme
We will only hold the necessary “Personal Data” that is required to establish and administer your pension scheme. We will only when absolutely necessary request and hold “Special Category Data”
For further information on the different classifications of data please refer to the ICO’s website at https://www.ico.org.uk
What we do with your data
As your pension administrator our lawful basis for processing your data is:
- Contract: the processing of your personal data is necessary for the contract we have with you to administer your pension scheme, or because you have asked us to take specific steps before entering into a contract with us.
- Legal obligation: the processing is necessary for the companies to comply with the law (not including contractual obligations). This includes Auto Enrolment whereby your employer is required to provide you with a workplace pension scheme.
When we process your data for these purposes the companies will ensure that we always keep your Personal Data rights in the highest regard and take into account all of your data protection rights in compliance with the General Data Protection Regulation and the safeguarding of your data.
Who do you share my data with?
The companies will only share data with other entities when we have received written consent from you. For a workplace pension scheme we may share your data with your Employer’s appointed IFA, if applicable. In addition to this we also have legal and regulatory obligations to share your data with government bodies (HMRC), our Regulators (the Financial Conduct Authority and the Pensions Regulator) and we may also disclose your information for fraud prevention purposes.
The companies complete Anti-Money Laundering checks inline with the 4th Money Laundering Directive on the establishment of any new scheme and your details will therefore be processed through a screening process for verification purposes.
Please note: We will not under any circumstances share or process your data for any marketing purposes unless you have opted-in for us to do so.
You as the “Data Subject” have the following:
The right to be informed
- You have the right to be informed of how we use and collect your data
The right of access
- You have the right to access your personal data
The right to rectification
- You have the right to correct any information we hold about you either verbally or in writing
The right to erase
- This is not an absolute right and only applies in certain circumstances
The right to restrict processing
- Data Subjects have the right to request the restriction of their personal data however this is not an absolute right and only applies in certain circumstances
The right to data portability
- The right to data portability allows individuals to obtain and reuse their personal data for their own purposes across different services
The right to object
Data Subjects have the right to object to;
- Processing based on legitimate interests or the performance of a task in the public interest/exercise of official authority (including profiling);
- Direct marketing
- Processing for purposes of scientific/historical research and statistics
- Data Subjects have the right to object to;
Rights in relation to automated decision making and profiling
The GDPR has provisions on:
- Automated individual decision-making (making a decision solely by automated means without any human involvement) and;
- Profiling (automated processing of personal data to evaluate certain things about an individual). Profiling can be part of an automated decision making process.
- The GDPR has provisions on:
For further information on and detail on any of the above please refer to https://www.ico.org.uk
How long do you hold my data?
We are required by law to hold your information for as long as is necessary to comply with our statutory and contractual obligations and in accordance with our legitimate interests as data controller. Retaining your personal data once your pension benefits have been settled or transferred out will assist us, should we receive contact in the future, regarding any aspect of your pension whilst it was held with us or for the establishment, exercise or defence of any legal claims in respect of your pension. The companies review retention periods periodically which will be updated on this web-page.
The company ensures that appropriate technical and organisational measures are taken to safeguard personal data.
All systems are hosted in securely managed environments where appropriate disaster recovery and backup up procedures are in place.
Subject Access Requests
Data Subjects have the right to access their personal and supplementary information. The right of access allows individuals to be aware of and verify the lawfulness of the processing. The data subject will have the right to obtain:
- Confirmation that their data is being processed
- Access to their personal data and other supplementary information.
How we keep you informed of any changes
Any policy changes either due to internal processes or future changes in regulation and legislation will be posted on this page and/or through an email or postal notification.
If you are unhappy with any aspect of how your information is has been collected and/or used, you can make a complaint to the Data Protection Officer (DPO) in writing, by email or phone:
Carey Pensions UK LLP
0330 124 1505
Carey Corporate Pensions UK Ltd
0330 124 1510
You can also make report concerns to The Information Commissioner’s Office by phone on 0330 123 1113 or further contact details can be found at https://ico.org.uk/global/contact-us/
We trust the information in this communication is clear and answers any questions you may have.
If you would like any further information on the GDPR please visit the Information Commissioners Office (ICO) web-site here https://www.ico.org.uk
Carey Pensions respect your privacy, we do not process your data unnecessarily or unfairly and are committed to keeping your data safe. Carey Pensions do not under any circumstances sell data.
Carey Pensions UK LLP: Registered Office 1st Floor Lakeside House, Shirwell Crescent, Furzton Lake, Milton Keynes, Buckinghamshire, MK4 1GA.
Company registration number: OC345142
ICO registration number: Z213288X
Authorised and regulated by the Financial Conduct Authority No: 501747
Carey Pensions Trustees UK Ltd: Registered Office 1st Floor Lakeside House, Shirwell Crescent, Furzton Lake, Milton Keynes, Buckinghamshire, MK4 1GA.
Company registration number: 06884410
ICO registration number: ZA059844
Carey Corporate Pensions UK Ltd: Registered Office 1st Floor Lakeside House, Shirwell Crescent, Furzton Lake, Milton Keynes, Buckinghamshire, MK4 1GA.
Company Registration Number: 09358998
ICO registration number: ZA093173
Authorised and regulated by The Pensions Regulator No.12006391
Carey Corporate Trustees UK Ltd: Registered Office 1st Floor Lakeside House, Shirwell Crescent, Furzton Lake, Milton Keynes, Buckinghamshire, MK4 1GA.
Company Registration Number: 09359872
ICO registration number: ZA093167