At CBC Pension Services (CBC), we respect your privacy and we are committed to protecting your personal data. This privacy notice informs you about how we look after your personal data when you visit our website, use our professional secretariat services, or otherwise conduct business with us, or when you are a beneficiary or member of a Pensions Trust for which we are a professional trustee. This notice explains your privacy rights and how the law protects you.
1. Important information and who we are
Purpose of this privacy notice
This privacy notice aims to give you information on how we collect and process your personal data through your use of this website, use of our professional secretariat services or other business you may conduct with us and where you are a Pension Trust beneficiary or member for which we act as a professional trustee.
We are Clark Benefit Consulting Limited, trading also as CBC Pension Services. We control and we are responsible for certain personal data as set out in this policy. Our registered office is at 71-75 Shelton Street Covent Garden London WC2H 9JQ. We are registered with the Information Commissioner’s Office at ZA287835.
If you have any questions about this policy, you can contact us by emailing email@example.com
Changes to the privacy notice and your duty to inform us of changes
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
2. The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We collect only that personal data from you that we need in order to provide you with the services you request and otherwise, in order to operate our business in the way that you would anticipate.
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
|Contact Data||includes first name, last name and email address, telephone number, residential, office address|
|Other Identifier Data||includes passport details, date of birth, job, National Insurance number, employer/company details.|
|Beneficiary Data||includes information about your dependants, salary information.|
|Sensitive Data||includes information about your physical and mental health, and sexual orientation to the extent we have details about your spouse or partner.|
|Payment Data||includes details about payments to and from you, invoices and billing address.|
|Technical Data||includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.|
|Usage Data||includes information about your use of our service, including the full Uniform Resource Locators (URL) clickstream to, through and from our website (including date and time); elements you viewed or words you searched for; page response times; download errors; length of visits; interaction information (such as scrolling, clicks, and mouse-overs).|
|Communications Data||includes emails, notes of conversations, trustee board minutes and records of conversations.|
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
3. How is your personal data collected?
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Identity, Contact, Payment or Communications Data by submitting information on our website or by corresponding with us by phone, post, email or otherwise. This includes personal data you provide when you:
- enquire about our services;
- contract to receive our services;
- discuss with us your particular requirements in connection with our services;
- otherwise use our services.
- Automated technologies or interactions. As you interact with our website, we may automatically collect Technical and Usage Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies.
- Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below:
- Technical Data from analytics providers such as Google based outside the EU who provide server monitoring tools to monitor the status of our APIs and the type and volume of queries being made to them.
- Contact and Other Identifier Data from publically available sources such as Companies House and the Electoral Register, based in the EU.
- In relation to Pension Trust beneficiaries or members only: Beneficiary Data and Sensitive Data from your pension trustee administrator and from other trustees.
4. How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
From time to time, we will send you marketing communications by email about our services to those that we work with (but not to Pension Trust beneficiaries or members). We offer you the chance to opt out of receiving such emails at the point that you register your contact details with us and whenever we send such a communication, we include an option for you to unsubscribe from receiving further such communications.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us at firstname.lastname@example.org if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Note also that for Pension Trust beneficiaries or members, for whom we act as a professional trustee, we may process or control certain Sensitive Data. This will only be collected by the pension trust administrator with the explicit consent of the individual about whom it concerns or otherwise in accordance with the law.
|Purpose/Activity||Type of data||Lawful basis for processing|
|To register you as a new client of our service (not for Pension Trust members and beneficiaries):||(a) Contact
(b) Other Identifier
|Performance of a contract with you|
|To provide our services:
|(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to provide trustee services to Pension Trust beneficiaries or members)
|To manage our relationship with you
(b) Other Identifier
|(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to tailor our services appropriately, to keep our records updated and to study how clients use our services)
|To exercise our duties as Trustee||(a) Contact
(b) Other Identifier
|(a) Necessary for our legitimate interests (to provide trustee services to Pension Trust beneficiaries or members)|
|To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||(a) Contact
(b) Other Identifier
|Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)|
|To deliver relevant website content and marketing messages to you||(a) Contact
(b) Other Identifier
|Necessary for our legitimate interests (to study how clients use our services, to grow our business and to inform our marketing strategy)|
|To use data analytics to improve our website, our services, marketing, customer relationships and experiences||(a) Technical
|Necessary for our legitimate interests (to define types of clients for our services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)|
You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.
Change of purpose
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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at email@example.com
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.
If you don’t provide personal data
Where we need to collect personal data by law or otherwise in line with existing data protection legislation, and you don’t provide that data when requested, we may not be able to carry out our services. We will notify you if this is the case at the time.
5. Disclosures of your personal data
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
- Third parties in order to fulfil our professional secretariat services (including email and document host systems (such as Gmail and Mailchimp), professional advisors, business associates, fellow trustees and marketing consultants working on our behalf).
- 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 notice.
- Only in respect of Pension Trust beneficiaries or members: Third parties in order to fulfil our obligations as trustee of any pension scheme including, for example: actuaries, scheme administrators, your employer, insurance companies, annuity providers and fraud detection agencies, the pensions ombudsman and other regulatory authorities.
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.
6. International transfers
We do not transfer the personal data of any Pension Trust beneficiary or member outside the European Economic Area (EEA).
If we need to transfer personal data in connection with our professional secretariat services out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring that we use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
7. Data security
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 have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8. Data retention
How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances you can ask us to delete your data: see section 9 below.
9. Your legal rights
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 about data protection before you approach the ICO so please contact us in the first instance.
You also have the right in certain circumstances to:
|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.|
|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.|
|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.|
|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.|
|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.|
|Request the transfer of your personal data to you or to a third party.||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 automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.|
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).
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.
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.
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