Information about us
Punter Southall Aspire (PS Aspire) (we, us or our) knows that you care how your personal information is used and shared and we appreciate your trust in us to do that carefully and sensibly. Your privacy is important to us and we are committed to protecting and respecting your privacy.

This privacy policy explains how we use your information that we may collect from you; is provided to us about you or you provide to us when you use our website; visit our offices or an event hosted by us; become a recipient of our services; make use of our products; or participate in a PS Aspire research survey.

For an explanation of all the terms in this policy click here.

Who we are
We are Punter Southall Defined Contribution Consulting, trading as Punter Southall Aspire and we are the data controller. We are part of the Punter Southall Group and our business contact details are:  

The contact detail of our Data Protection Officer is:

Personal data we collect

The specific types of personal information we may collect and use about you will depend upon your use of our website facilities, the services or products you have contracted to receive from us, how you use them and the information you choose to provide. We may at times need to collect special category personal data from you (such as health or medical records) to provide the services or products you have contracted to receive from us; we will only request such data with your explicit consent at the time of requesting the data.

The types of information we collect directly from you are:

• Name, phone number, email address;
• Address (current or permanent)
• Job title or position, company name (where applicable);
• Age and/or DOB
• Bank account details
• Education
• Gender
• Health information (mental or physical)
• Condition
• Marital status
• National Insurance number
• Nationality, race or ethnicity
• Salary details
• Tax ID
• Comments, opinions, photos (if attending our events or contributing to our publications only);
• Marketing preferences; and
• Call recordings and voicemails.

The types of information we collect from you automatically are:

• IP address, MAC address, browser types, browser language, operating system, general location data- the country from which you accessed the our website, software and hardware attributes (including device IDs), referring and exit pages and URLs, platform type, the number of clicks, files you download, domain names, landing pages, pages viewed and the order of those pages, the amount of time spent on particular pages, the terms you use in searches on our sites, the date and time you used the website, any form submitted , error logs, and other similar information
• Opening of emails, date and time email opened, links clicked on in email.

We and our website service provider (a data processor that works on our behalf), may use a variety of technologies, including cookies and similar technologies, to assist in collecting this information, as is discussed below.

Aggregate/Anonymous Data
We may aggregate and/or anonymise any personal information collected through the facilities, services or products offered so that such information can no longer be linked to you or your device. We may use this information for any purpose and may share this data with our third parties.

Please note that we need certain types of information so that we can provide the website facilities, services and products to you. If you do not provide us with such information, you may no longer be able to access or use our services or products.

Personal data we obtain from third parties

• We collate publicly available data from third parties such as Dun & Bradstreet and add this into contact and company records in our CRM database. 
• In order to service our clients according to contractual agreements, we may collect data from third parties such as pension providers.  Exact terms can be found in your client contract.

Why we collect and use your personal data

We, or our data processors, use your information for various purposes depending on the types of information we have collected from and about you and the specific facilities, services or products you use. In particular, we collect your information for the following purposes:

• to contact you in response to your enquiry about the products and services we offer;
• to provide you with and /or administer the pensions and workplace savings products and services you request;
• to reply to your questions about your pensions and benefits;
• to provide you with newsletters, information about our forthcoming events and marketing communications;
• to respond to you if you report a problem with our website;
• to enhance and improve your experience on our website, ensure the security of our website facilities and develop the service and products we offer;
• to analyse email marketing campaigns; and
• to monitor and improve our customer service standards.

The legal bases for using your information are as follows:

• Where you make an enquiry, ask a question or request information on a service or product, agree to marketing communications or report a problem we will require your consent or rely on other lawful bases of processing such as legitimate interest, performance of a contract or compliance with a legal obligation, before we use your information;
• Where you have requested a service or product, the use of your information is necessary for the performance of the contract we’ve entered into with you for the provision of those services or products. Where special categories of information is required in the performance of the contract we will ask for your explicit consent prior to its collection;
• Where we provide you with the website facilities, services or products you’ve requested, use of your information is necessary to perform our obligations under the terms of any contract we have with you, including access to our Premium Content subscription service; and
• Where we collect your information automatically or you respond to a survey we use your information for our legitimate business interests.  This is to provide security for our website, operate our business and provide our services and products, ensure safe environments for our staff and visitors to our offices, comply with legal requirements and defend our legal rights, prevent fraud and to know you, our customer to whom we are providing the facilities, services or products.

Who we share your personal data with

In providing our facilities, services and products to you we may share your personal information with other organisations or entities. Listed below are the organisations / entities, the reason for sharing and the type of the information shared.

Where we process your personal data outside the EEA
It is not intended that your information be transferred outside the European Economic Area (EEA), but if it is, Model Clauses or other mechanisms approved by the European Commission or the Information Commissioner's Office (ICO) will be put in place prior to us processing your information.  Where required we will also obtain your consent.

You can obtain further information regarding the mechanisms used to safeguard your data by contacting our Customer Care team or Data Protection Officer at the contact details listed above.

How long we will keep your personal data
We will only keep your personal data for as long as we need to in order to fulfil the purposes for which it was collected, as set out in this privacy policy, and for as long as we are required to keep it by law. In order to ensure we meet our obligations, we have produced a retention schedule that indicates when personal information should be disposed of. You can view our schedule here. If you have opted out of receiving all email marketing communications, we will suppress your data so that we do not unknowingly send you marketing emails.

Cookies and similar technologies
For more information on the cookies we use, the purposes for which we use them and how you can control them please refer to our Cookie Policy.

Marketing and research
You have choices when it comes to receiving marketing communications and taking part in market research. We will send you relevant news about our products and services in a number of ways including by email, but only if you have previously agreed to receive these marketing communications or if we believe the services to be of genuine legitimate interest to you. When you make an enquiry via our website we will ask if you would like to receive marketing communications. You can change your marketing choices at any time online, over the phone or in writing.

We would also like to hear your views to help us to improve our services and products so we may contact you for market research purposes. You always have the choice about whether to take part in our market research.

Applications for employment
Our website contains a “Working for us” section that links to a website where you can apply for employment at PS Aspire. This recruitment website is administered by Jobtrain, a Punter Southall Group (PSG) service provider. The Jobtrain website collects personal information such as your personal details, contact information and work history and qualifications. It also uses cookies and other means of collecting information, which is only used to enable you to complete your application and for analytics purposes.

Jobtrain is permitted to collect, use and share your information only as necessary to perform the functions that PSG directs it to perform. Any information that PS Aspire collect from Jobtrain in connection with the recruitment website is handled consistent with this Privacy Policy. PS Aspire will use and share your information only for employment purposes, such as communicating with you about or evaluating you for a job opportunity or where sharing is required by law.

How to access and control your personal data - Your rights
You have certain rights with respect to your information which are summarised below. Some of the rights are complex therefore, not all details are included in the summary:

• Right to be informed: at the time your information is collected, you should be given, or can ask for information about how your information is collected and used. A copy of this privacy policy can be obtained by clicking the printer icon at the top of this page;
• Right of access: you can ask for copies of all the information that we process about you;
• Right to rectification: you can ask to have inaccurate information held about you corrected;
• Right to erasure: you can ask for the information held about you to be erased (subject to certain criteria);
• Right to restriction of processing: you can ask us to stop processing your information (under certain circumstances);
• Right to data portability: you can, under certain circumstances, request that we transmit your personal information to another provider of services;
• Right to object: you can object to your information being processed if our legal basis for processing your information is based on a “legitimate interests”. To check whether we use your information for “legitimate interests” see the section “Why we collect and use your personal data"

You also have the right to object to direct marketing and if you make such an objection, we will cease to process your personal information for this purpose.

• Our use of automated decision making (including profiling): We use pre-defined Marketing ‘personas’ (amalgamated character profiles of our target audiences) to assist us in tailoring your web experience. You can ask to be removed from our persona groups at any time.

If you would like to exercise any of your rights mentioned above, you can do so by writing or emailing our Data Protection Officer or Customer Care team at the address detailed above.

Your right to withdraw consent
Where you have provided consent for us to process your information you can withdraw your consent at any time. Please note: Withdrawal will not affect the lawfulness of processing prior to you withdrawing your consent.

You can withdraw your consent in the following ways:

• In writing, to our Customer Care team or Data Protection Officer;
• By unsubscribing from our marketing emails.

Your right to make a complaint
If you have a complaint about the way we process your personal information or think that we have not complied with your rights, you can make a complaint to:

The Information Commissioners Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Telephone: 0303 123 1113 or 01625 545745
Fax: 01625 524510
Website: www.ico.org.uk 

Changes to this policy
You will be informed of changes to this policy by dedicated service emails, when you log-in to your account or by notification on our website.

General
If you have questions regarding our Privacy Statement, please contact us at sayhello@psaspire.com. For other general questions, please go to our Contacts page.