Punter Southall Defined Contribution Consulting Limited (trading as Punter Southall Aspire, Punter Southall Coleman and Punter Southall JDP) (“we”, “us” or “our”) is committed to protecting and respecting your privacy. This Policy is:

• meant for employees of employers and members of pension schemes that are clients of ours and;

• sets out the basis on which any personal data we collect from you, from third parties, such as your employer or insurance companies, about you or that you provide to us will be processed by us.

 We provide products and services to employers and to trustees for the management and administration of workplace pension schemes and non-investment insurance products. The products we may advise on include but may not be limited to: 

  When providing these products or services, we may act as the Data Processor of your personal data. This means that we process your data in accordance with the requirements of the Data Controller, usually your employer or pension scheme. In some instances, we will act as Data Controller, detailed below. Where we act as Data Controller, we are responsible for deciding how we hold and use personal data about you and that we are required to notify you of the information contained in this Privacy Policy (“Policy”). It is important that you read this Policy so that you are aware of how and why we are using your personal data and how we will treat it. 

1. THE TYPE OF DATA WE COLLECT ABOUT YOU, THE BASIS FOR COLLECTING IT, AND HOW WE WILL USE IT

   • We will collect various types of personal data about you when providing the products and services, depending on our agreement with your employer or your pension scheme. Further details of how we use your personal data are set out below.

 At times, and depending upon the products and services that we may be providing, we may also collect special category personal data, which may include details about your health; for example, when discussing setting up a life assurance policy, details of your health may be relevant.   

2. DISCLOSURE OF YOUR INFORMATION

We will share your data with the Recipients set out below, depending on the services or products we are providing: 

• The company which provides your workplace pension scheme or non-investment insurance product, such as Aviva or Legal & General. This is to support the administration of the pension scheme or non-investment product for your employer or the trustee;

• Intelligent Office, IRESS and Watermark: provide back office systems which help us provide the products and services we are contracted for.

 We enter into agreements with such third parties part of which is to ensure that they respect the security of your data and use it only in accordance with data protection laws. We will also disclose your personal data to third parties: 

• if we are under a duty to disclose or share your personal data in order to comply with any legal obligation.

3. INTERNATIONAL TRANSFER OF YOUR PERSONAL DATA

 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.  

4. STORAGE OF YOUR PERSONAL DATA

 We will only keep your personal data for as long as we need to in order to fulfil the relevant purpose(s) it was collected for, as set out above in this Policy, and thereafter for as long as we need to keep it for legal purposes. Generally we will delete your records six years after our relationship with your employer or pension scheme ends. However, we are obliged to retain some data longer for regulatory purposes. For more information about how long we will keep your personal data, please contact us at the details shown above. We take the security and confidentiality of your personal data very seriously. We will use strict procedures and security features to aim at preventing unauthorised access, disclosure, alteration or deletion of your data. This includes restrictions on who can access data, using encryption to protect data when it is being transferred or stored, and maintaining corporate firewalls to safeguard against unauthorised access. For full details of the security measures we have in place, please contact us using the details shown above. 

5. YOUR RIGHTS

 Data protection laws provide you with the following rights 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;

• 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 information we hold about you corrected in certain circumstances;

• 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. Where we have a legal obligation to retain your data, such as where you are also a member of the Aspire Savings Trust, we will be unable to comply with your request. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing (see below);

• request the restriction of processing of your personal data, for example if you want to establish its accuracy or the reason for processing it; and

• request the transfer of your personal data to another party.

You also have the right 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 to processing on this ground.You will not have to pay a fee to access your personal data (or to exercise any of the other rights above). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive, for example if you keep requesting copies of the same data. Alternatively, we may refuse to comply with the request in such circumstances. We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal data is not disclosed to any person who has no right to receive it.  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. They can be contacted at:

The Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Telephone: 0303 123 1113 or 01625 545745
Fax: 01625 524510
Website: www.ico.org.uk  

6. CHANGES TO OUR PRIVACY POLICY

 Any changes we make to our Policy in the future will be posted on this page and, where appropriate, notified to you by your employer or Pension Scheme Trustee. Alternatively please check back frequently to see any updates or changes to our Policy. 

7. CONTACTING US

 If you have any queries, comments or requests regarding this Policy or you would like to exercise any of your rights set out above, you can contact us in the following ways: 

• by email at sayhello@psaspire.com

• by telephone on 0203 327 5470; or

• by post at Punter Southall Aspire, 80 Leadenhall Street, London, EC3A 3DH.