We respect privacy and your rights to control your personal data. Our principle guidelines are simple. We will be clear about the data we collect and why. We do not and will not sell your data to Third Parties. This Privacy Notice describes why and how we collect and use your personal data and provides information about your rights. It applies to personal data provided to us, both by individuals themselves or by others. We may use personal data provided to us for any of the purposes described in this Privacy Notice, or as otherwise stated at the point of collection.
In this Privacy Notice, your information is sometimes called “personal data” or “personal information”, and is any information relating to an identified or identifiable living person. We also sometimes collectively refer to handling, collecting, protecting or storing your personal information as “processing” such personal information. We process personal data for numerous purposes, and the means of collection, lawful basis of processing, use, disclosure, and retention periods for each purpose may differ.
When collecting and using personal data, our policy is to be transparent about why and how we process personal data. To find out more about our specific processing activities, please go to the relevant sections of this Notice.
The contents of this document apply wholly to data subjects residing within the European Economic Area (EEA). Data subjects residing outside of the EEA will receive the same levels of protection of their personal data wherever practical to do so.
Who We Are
This Privacy Notice is issued by Carey Pensions UK LLP and Carey Corporate Pensions UK Ltd (collectively referred to as “we”, “us”, and “our” in this Privacy Notice), and relates to one or more of its affiliated firms that may process your personal information.
We gather and process your personal information in accordance with this Privacy Notice and in compliance with the relevant data protection Regulation and Laws. This Notice provides you with the necessary information regarding your rights and our obligations, and explains how, why and when we process your personal data.
Information That We Collect
We process your personal information to meet our legal, statutory and contractual obligations and to provide you with our products and services. We will never collect any unnecessary personal data from you and do not process your information in any way, other than as specified in this Notice.
We may collect and use some or all of the following types of personal data about you and, in some circumstances, your spouse, civil partner, partner or dependents:
- Your full name, address and contact details;
- Your date of birth;
- Your gender;
- Your National Insurance Number;
- Details of your bank account; and
- Information about your health.
You may also need to provide us with personal data relating to other people. When you do so, you will need to check with them that they are comfortable for you to share their personal data with us, and for us to use it in accordance with this Privacy Notice.
If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you, or we may be prevented from complying with our legal obligations.
We may collect information in the below ways:
- You may provide information directly to us;
- Third Parties may provide personal information to us; and
- We may also capture certain personal data to meet our legal, statutory and contractual obligations.
How We Use Your Personal Data
We take your privacy very seriously and will never disclose, share or sell your data without your consent; unless required to do so by Law. We only retain your data for as long as is necessary and for the purpose(s) specified in this Notice. Most commonly, we will use your personal data in the following circumstances, and on the following legal basis:
- In the performance of the contract we have entered into with you; data is processed in order to service and administer your self-invested personal pension or workplace pension
- It is in our legitimate interest to process your personal data; we will, on occasions, process the data beyond the needs for performance of a contract or for compliance with a legal obligation. This will be completed on the understanding that it is our legitimate interest to process the data in this way. For example, using your data for risk based analysis
- When we collect and use certain special categories of personal data with your express consent; where this lawful basis is relied upon, you may withdraw your consent to us processing this data at any point
- Where we need to comply with a legal obligation; we are subject to various statutory requirements, such as the Money Laundering Regulations, the Financial Services and Markets Act 2000, MiFID, and many various tax laws, as well as being regulated by the Financial Conduct Authority and The Pensions Regulator. We therefore have a number of obligations, including identity and age checks, fraud and money laundering prevention, and fulfilling control and reporting obligations.
We may less often also need to use your information to establish, exercise or defend our legal rights.
You have the right to access any personal information that we process about you, and to request information about:
- What personal data we hold about you (commonly known a “data subject access request”);
- The purposes of the processing;
- The recipients to whom the personal data has/will be disclosed;
- How long we intend to store your personal data for; and
- If we did not collect the data directly from you, information about the source.
If you believe that we hold any incomplete or inaccurate data about you, you have the right to ask us to correct and/or complete the information and we will strive to do so as quickly as possible; unless there is a valid reason for not doing so, at which point you will be notified.
You also have the right to request erasure of your personal data or to restrict processing (where applicable) in accordance with the data protection laws; as well as to object to the processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object on those grounds. In addition, you have the right to data portability of your information and the right to be informed about any automated decision-making we may use.
If we receive a request from you to exercise any of the above rights, we may ask you to verify your identity before acting on the request. This is to ensure that your data is protected and kept secure. We will respond using the commonly used electronic form unless you specifically request otherwise, or we are required to use a specific mode of communication. If you are requesting an alternative method, there may be an additional charge for this. When requested, and provided that it is practical and commercially feasible to comply with the request and there is no legal or regulatory need for us to keep the information, we will delete identifying information from current operational systems.
Sharing and Disclosing Your Personal Information
On occasions, we will share your personal information without your consent, in line with the purposes specified in this Notice or where there is a legal requirement. There are three main groups that we are likely to share your personal data with:
- The STM Group – Carey Pensions UK LLP and Carey Corporate Pensions UK Ltd, as a subsidiary of the STM Group, will share your data with other group entities where required. In order to keep administration costs low, a number of specialist resource areas (such as general account administration, legal, sales, and marketing) are shared across the group and will on occasions require data to be shared between entities for the performance of these shared services.
- External Parties – We will transfer data to external parties, such as investment platforms and IFA’s in order to fulfil our contractual obligations. We may also need to share data with the Financial Conduct Authority, and other regulators when required to do so.
- Service Providers – Data may be transferred to service providers appointed by us. We have ensured that all service providers treat your data securely, and in compliance with the GDPR. Service providers will only process a data subject’s information in accordance with instructions from us as the controller.
Transfers Outside the EEA
There may be instances where we are required to transfer data outside of the European Union. This will only happen so long as:
- It is required by law (such as reporting to state bodies overseas)
- You have given us your consent to transfer data.
Should we be required to transfer your data outside of the EEA for any of the above reasons, it is a requirement that an appropriate contract containing the required model clauses is in place between us and the recipient of your data prior to providing them with your personal data, This will ensure that their data protection standards meet, as a minimum, the same level of protection afforded to data subjects by GDPR.
How Long We Keep Your 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. 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. We review retention periods periodically which will be updated on this web-page.
Lodging a Complaint
We only process your personal information in compliance with this Privacy Notice and in accordance with the relevant data protection laws. We hope that you won’t ever need to, but if you wish to raise a complaint regarding the processing of your personal data or are unsatisfied with how we have handled your information, please contact our Data Protection Liaison Officer in the first instance:
STM Group PLC
Data Protection Officer
c/o Carey Pensions, Lakeside House, Shirwell Crescent, Furzton Lake, Milton Keynes, MK4 1GA
You also have the right to lodge a complaint with the relevant local supervisory authority. For further information on your rights and how to complain to the supervisory authority, please refer to their website, which can be; accessed via https://ico.org.uk/global/contact-us/.
Changes to Our Privacy Notice
This statement is subject to regular review and may be updated from time to time. We will inform you if we make any substantial changes to how we use with your personal data.
This policy was last updated on 21 May 2019