LCP is registered as a data controller with the Information Commissioner’s Office (“ICO”). Our registration number is Z6661882.
The information we collect
We collect personal information about individuals in the course of running our business and providing our services to our clients. We may collect personal information from a variety of sources for example:
- from our clients;
- from prospect clients;
- from recruiters (for the purposes of recruitment);
- from service providers;
- directly from an individual (eg Investment Managers); and
- from any other third party with whom we have business dealings.
The personal information provided will depend on the source of the information but may include an individual’s:
- contact details (telephone number, email address, address);
- national insurance number;
- date of birth;
- marital status;
- health information;
- salary; and
- pension amounts.
How do we use information that we collect?
- On behalf of Clients
In circumstances where we process personal information on behalf of clients (including pension scheme member data) we will carry out such processing only in accordance with our clients’ instructions. In processing such personal information, we will usually act as the data processor (eg Pension Administrators) and our client is usually the data controller.
- Scheme Actuary
LCP advises pension scheme trustees on various matters, including, but not limited to, the value of an individual member’s pension, the value of options available to individual members, and the value of the scheme as a whole.
In providing our advice, LCP uses member data, which may include the personal information listed above. It is LCP’s policy to use data that cannot directly identify an individual or anonymous data, wherever possible .
In circumstances where an LCP partner or staff member acts as scheme actuary for a pension scheme (the “Scheme Actuary”), he or she will usually be a data controller in carrying out his or her statutory functions as scheme actuary and will carry out those functions in accordance with data protection laws. Each Scheme Actuary at LCP (with a current Scheme Actuary appointment) is registered as a data controller with the ICO.
Data retention periods
We will retain an individual’s personal data for so long as the purpose the individual has provided it for still exists, unless a longer retention period is required or permitted by law.
Transfer outside of the EEA and automated decision making
We do not routinely transfer personal data outside of the EEA nor do we use personal data to make automated decisions about individuals.
How we manage personal information
The processing of an individual’s personal information will be done in accordance with the Data Protection Act 1998. Access to personal information 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.
Sharing personal information
We will keep personal information within LCP, however to provide the services outlined above we may share it:
- where we have permission to do so;
- to third party service providers eg website host, auditors, event organisers an individual has registered for;
- in order to give individuals and/or clients the service they have requested eg to use specialist companies to provide additional services or advice;
- for regulatory or legal purposes or to protect the rights of LCP, our clients or other parties ; and
- to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities.
Access to your information and correction
Where we are the data controller of the personal information, the individual has a right to request access to and/or correction to your personal information from us. If you believe the personal information we hold on you is incorrect, or you wish to see the information we hold on you, please contact our Data Protection Officer (details below).
We aim to meet the highest standards when collecting and using your personal information. However, if you believe we not meeting these standards and wish to make a complaint, please contact our Data Protection Officer.
If you are not satisfied with our response you have the right to complain to the Information Commissioner’s Office.
How to contact us?
The Data Protection Officer
95 Wigmore Street