Our contact details

Name:                              The Data Protection Manager

Website:                           www.intrustedpensions.com

Phone Number:                0116 456 0181

E-mail:                             dataprotection@intrustedpensions.com

 

The type of personal information we collect

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We may collect and process the following information:

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• “Identity Data”, which may comprise your first name, last name, marital status, age, date of birth, work location, job title, national insurance number, and gender.

• “Financial Data”, which may comprise your bank account and billing details. This may also include your salary information or additional information about your financial wealth management or employee benefit requirements where we are setting up Employee Benefit services for you, or for your employer on your behalf (please see below for further details).

• “Contact Data”, which may comprise your address, email address and telephone number.

• “Transaction Data”, which may comprise details about payments to and from you and other details of products and services you have purchased from us.

• “Technical Data”, which may comprise your IP address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the device used to access our website.

• “Usage Data”, which may comprise information about how you use our website.

• “Marketing and Communications Data”, which comprises your preferences in receiving marketing from us and third parties and your communication preferences

 

How we get the personal information and why we have it

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Most of the personal information we process is provided to us directly by you for one of the following reasons:

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1. To provide services to the relevant scheme’s trustees, which will include establishing schemes and maintaining records on our systems.

2. To send information relating to your SSAS to any of the trustees of the scheme.

3. To give essential information about your SSAS to others (for example, investment providers, regulatory authorities or your agents such as your financial adviser or investment manager) if necessary to provide the agreed services and for legal or regulatory purposes.

4. To establish, wind up or administer your pension scheme in line with contractual agreements.

5. Where we need to comply with a legal or regulatory obligation.

We may also receive personal information indirectly, from the following sources in the following scenarios:

• Your previous scheme administrator where the relevant scheme is transferred to our administration.

• Your nominated financial adviser or accountant in the process of administering or establishing the pension scheme.

• Other member trustees.

• Your employer.

• Ceding and receiving Pension Providers in the event of pension transfers.

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We will only process your data where it is lawful to do so and we will only collect the minimum amount of information necessary to meet the purpose for which we intend to use that information, for example in order to provide you with the services we have been engaged for.

We may share this information with third parties. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions. We will ensure that your information is not subsequently shared further by these third parties without our agreement. We shall not share your personal data with any third parties for marketing purposes without your express consent.

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We shall however share your personal data with third parties for the following reasons:-

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• To meet any agreed contractual arrangements we have with you, or your employer on your behalf, we may share your information with other service providers that we use to perform that contractual service.  Examples of service providers include hosting services, suppliers and sub-contractors. We may also need to share your personal data with third party software or IT support providers for the purpose of system administration, data security, data storage, back up, disaster recovery and IT support.

• We may share your personal data with third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Policy.

• We reserve the right to disclose or share your personal data in order to comply with any legal or regulatory requirements, enforce our terms and conditions (or any agreement we enter into with you), or to protect the rights, property, or safety of our business and other website users. We may also share your personal data with our professional advisers including lawyers, bankers, auditors and insurers based who provide consultancy, banking, legal, insurance and accounting services.

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The legal bases on which we will rely for our processing are that the activities are either necessary to provide services to you, necessary for our legitimate interests or are necessary to comply with a legal obligation.

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We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

 

If you fail to provide personal data

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Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to provide services to you. In this case, we may have to terminate our professional relationship but we will notify you if this is the case at the time.

 

Change of purpose

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We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

 

How we store and retain your personal information

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Your information is securely stored on servers in either the UK or the EEA. We will not transfer your personal data outside the UK or the EEA.

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We will retain your personal data for as long as we are providing services to you and the period of 6 years thereafter (as required by our regulatory framework).

 

Your data protection rights

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In certain circumstances, you have rights under data protection laws in relation to your personal data, as set out below.

If you wish to exercise any of the rights set out below, please contact us using the contact details at the start of this privacy notice. We may not have to comply with your request but we would explain why if we believe we are entitled to refuse.

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Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

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Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

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Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

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Object to 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 to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

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Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

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Request the transfer of your personal data to you or to a third party. Where our systems allow, we will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to information which is processed by automated means. We do not currently hold personal data in a form that is readily portable and it is unlikely we would be able (or required) to comply with such a request.

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Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent.

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No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

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What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

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Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

 

How to complain

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.