This privacy notice is provided on behalf of Lane Clark & Peacock LLP (“LCP”) of 95 Wigmore Street, London, W1U 1DQ, registered number OC301436.
LCP is listed on the register of data controllers held the Information Commissioner’s Office (“ICO”). Our data protection registration number is Z6661882.
Scope of this privacy notice
The personal data that we collect
We collect personal data about individuals in the course of running our business and providing our services to our clients. We may collect personal data from a variety of sources for example:
- from our clients;
- from prospective clients;
- from recruiters (for the purposes of recruitment);
- from suppliers and service providers;
- directly from an individual (eg Investment Managers); and
- from any other third party with whom we have business dealings.
The personal data 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 personal data that we collect?
On behalf of Clients
In circumstances where we process personal data 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 data, we will usually act as the data processor (eg Pension Administrators) and our client is usually the data controller.
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 data listed above.
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 listed on the register of data controllers held by the ICO.
Our legal basis for processing personal data
Often, our legal basis for processing personal data will be contractual, for example we need to process personal data to meet our obligations under the terms on which we are appointed to advise our clients.
In some cases, we might consider that we have a legitimate interest to process an individual’s personal data.
In other cases we might ask for an individual’s consent to process their personal data, for example we might seek consent to retain contact details for the purpose of providing individuals with information that we believe could be useful and relevant to them. In such cases, we will always provide the individual with a clear way of withdrawing consent.
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
We will only transfer personal data outside of the European Economic Area if:
- the individual has asked us to;
- the European Commission has determined that the country, territory and/or organisation that is receiving the data ensures an adequate level of protection; and/or
- there are appropriate safeguards in place for the data (ie individuals’ rights in respect of that data are still enforceable and effective remedies are still available).
We do not routinely transfer personal data that we process on behalf of clients outside the EEA. Where we are acting on a client’s instructions to do so, the client will usually have put in place appropriate safeguards.
How we manage personal data
The processing of an individual’s personal data will be done in accordance with the General Data Protection Regulation and any other legislation which is relevant to data protection in the United Kingdom. Access to personal data 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 data
To provide our services to clients and for legitimate business purposes we may share personal data:
- 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.
Rights of individuals
Where we are the data controller, individuals have the following rights in relation to their personal data:
- Right of access – the right to request a copy of their personal data that we hold.
- Right to rectification – the right to have their data corrected if it is inaccurate or incomplete.
- Right to erasure – the right to have their data deleted or removed if it is no longer necessary for the purpose for which it was obtained.
- Right to restrict processing – the right to request that the way in which we use their data is restricted to certain uses which they may specify.
- Right to data portability – the right, where applicable, to have their data transferred to another organisation.
- Right to object – the right to object to the processing of their personal data in certain circumstances eg for direct marketing purposes. In the event that an individual has not consented to our use of their personal data and we are not using their data in a way in which they would reasonably expect or they do not consider that we are using their data for their benefit, then an individual may object to us collecting and using their personal data. Individuals may withdraw any consent they have given in respect of their personal data at any time.
To exercise any of these rights please contact us using the contact details below. We will aim to respond to any request received within one month of receipt.
We aim to meet the highest standards when collecting and using your personal information. However, if you believe we are 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.
Changes to this privacy notice
We keep this privacy notice under regular review and place any updates on our website. This privacy notice was last updated on 24 May 2018.
How to contact us?
If you would like further information about this privacy notice or how to request your personal data you can email us at firstname.lastname@example.org or write to:
The Data Protection Officer
Lane Clark & Peacock LLP
95 Wigmore Street