Scope of this privacy notice
This privacy notice applies where LCP processes personal data for you to fulfil any contractual arrangement with you and to provide you with a professional service.
Who is collecting the data?
Lane Clark & Peacock Ireland Limited (“LCP”) is an actuarial and investment firm offering a range of professional services to companies and individuals. LCP are committed to maintaining the privacy of any personal data it receives in its operations.
LCP are deemed to be data controller when offering some professional services such as in the provision of actuarial, financial or investment advice to individuals or groups of individuals. All data controllers are required by the European General Data Protection Regulation (GDPR) to notify you about the collection, storing, use, disclosure, transfer and disposal (collectively known as “processing”) of personal information (or data) relating to you and your employees.
What data is being collected?
LCP retain personal data about you and your employees to fulfil any contractual arrangement with you and to provide you with a professional service.
The personal information about you and your employees can be collected from you and other sources such as your representatives and other advisors. The data which may be collected include:
- Personal details such as name (including former names), date of birth, sex, contact details (e.g. home address and former addresses, telephone numbers and e-mail address), and identifiers such as PPS number.
- Employment and pension scheme membership details such as dates of joining and leaving employment (including reason for leaving, where relevant to benefit calculations) and employment history (e.g. whether part-time or full-time, periods of absence and job title), periods of pensionable service, earnings and details of other benefits.
- Details of pension contributions and benefits, such as compulsory and voluntary contributions, actual or potential defined benefits and defined contribution account information (e.g. investment allocation and account balance).
- Other financial details such as other pension arrangements, relevant tax and PPS details, bank sort code and account number, tax codes (e.g. PRSI class), tax credits, Personal Financial Threshold and deductions from pension payroll.
- Details of family and social circumstances such as current marriage or civil partnership, any previous relationships and dependents, and death benefit distribution information (including expression of wish forms).
- Copies of identification and similar documents (e.g. birth, marriage, civil partnership and death certificates, passport identity pages, decree absolute, Pension Adjustment Orders).
- Information about health to determine and provide benefits and advice.
LCP respects your right to privacy and will ensure that your personal data is kept securely and is processed in accordance with applicable data protection laws, including the GDPR and LCP‘s data protection policies.
How do we use personal data that we collect?
The data will be used to manage and administer your Scheme and to ensure the correct benefits are paid to you or to your dependants.
Our legal basis for processing personal data
Often, our legal basis for processing personal data will be contractual, for example we need to process personal data to meet our obligations under the terms on which we are appointed to advise our clients.
In some cases, we might consider that we have a legitimate interest to process an individual’s personal data.
In other cases we might ask for an individual’s consent to process their personal data, for example we might seek consent to retain contact details for the purpose of providing individuals with information that we believe could be useful and relevant to them. In such cases, we will always provide the individual with a clear way of withdrawing consent.
What is the legal basis for processing the data?
We process your data to comply with the legal obligations under the Scheme's governing documents, pension and trust law requirements, and for the purpose of the legitimate interest in promoting the proper and efficient administration and management of the Schemes in order to provide benefits for you or your dependents.
How we manage personal data
The processing of an individual’s personal data will be done in accordance with the General Data Protection Regulation and any other legislation which is relevant to data protection in the United Kingdom. Access to personal data will be limited to authorised individuals on a strictly need to know basis. We are committed to keeping data safe and secure and will ensure that appropriate technical and organisation measures are in place to protect it from unauthorised or unlawful processing.
Your personal data will be held confidentially but may be disclosed to other third parties, such as:
- Other professional advisors with whom clients have consented we share client information – for example legal advisors or accountants
- Our auditors and other advisors
- Suppliers such as IT providers, shredders, storage companies
- Other parties clients have consented we share client information – for example, your employees' family members
LCP may also be required to disclose information to the Revenue Commissioners, the Financial Services Pension Ombudsman, the Pensions Authority and other regulatory authorities. Where this is required, there must be a legal basis for so doing.
Transfer outside of the EEA
We will only transfer personal data outside of the European Economic Area if:
- the individual has asked us to;
- the European Commission has determined that the country, territory and/or organisation that is receiving the data ensures an adequate level of protection; and/or
- there are appropriate safeguards in place for the data (ie individuals’ rights in respect of that data are still enforceable and effective remedies are still available).
We do not routinely transfer personal data that we process on behalf of clients outside the EEA. Where we are acting on your instructions to do so, you will usually have put in place appropriate safeguards.
How long will the data be stored for?
Usually your personal data will be kept for a maximum of seven years after the termination of your contract with us. However, the duration will be determined by the service offered and the data held.
LCP will retain your and your employees' personal data to allow it to meet its regulatory requirement to retain data and to enable it to defend against any future legal claims and to meet good practice in managing its business.
What rights do you and your employees have?
Where we are the data controller, individuals have the following rights in relation to their personal data
- Right of access – the right to request a copy of their personal data that we hold.
- Right to rectification – the right to have their data corrected if it is inaccurate or incomplete.
- Right to erasure – the right to have their data deleted or removed if it is no longer necessary for the purpose for which it was obtained.
- Right to restrict processing – the right to request that the way in which we use their data is restricted to certain uses which they may specify.
- Right to data portability – the right, where applicable, to have their data transferred to another organisation.
- Right to object – the right to object to the processing of their personal data in certain circumstances eg for direct marketing purposes.
- In the event that an individual has not consented to our use of their personal data and we are not using their data in a way in which they would reasonably expect or they do not consider that we are using their data for their benefit, then an individual may object to us collecting and using their personal data. Individuals may withdraw any consent they have given in respect of their personal data at any time.
To exercise any of these rights please contact us using the contact details below. We will aim to respond to any request received within one month of receipt.
We aim to meet the highest standards when collecting and using your and your employees' personal information. However, if you believe we are not meeting these standards and wish to make a complaint, please send any queries or complaints to the email address below.
In the event that your query has not been resolved to your satisfaction, you have the right to raise the matter with the Data Protection Commissioner, Lo call 1890 252231 or email firstname.lastname@example.org.
Please note that if you fail to provide accurate membership information or object to processing of your data it may result in a delay or an inability to provide professional services.
Further information may be obtained by contacting LCP at the address: email@example.com
How to contact us?
If you would like further information about this privacy notice or how to request your and your employees' personal data you can email us at firstname.lastname@example.org or write to the address provided below.
Lane Clark & Peacock Ireland Ltd
Office 2, Grand Canal Wharf
South Dock Road
Changes to this privacy notice
LCP may revise the privacy notice from time to time and we reserve the right to change the privacy notice at any time. This privacy notice was last updated on 24 January 2019.