Purpose of this notice
This notice sets out how we collect and process your data for the purposes of:
· This booking system;
· Money Matters financial education webinars;
· At Retirement 121 sessions;
· New Joiner 121 sessions;
· Annual pension choices webinars; and
· Annual pension choices 121 sessions.
It is important that you read this notice so that you are fully aware of how and why we are using your data.
We may update this privacy notice from time to time. You will be able to see any updates on this booking system.
Additional privacy notices may have been made available to you by First Actuarial (for example, as part of the Money Matters website), the Trustee Directors of Unilever UK Pension Fund Trustees Limited (“the UUKPF Trustees”) and Unilever. You should refer to these notices for information on other topics.
This privacy notice only covers how First Actuarial collect, process and retain your data for the Money Matters webinars, pensions choices webinars, pensions choices 121 sessions, At Retirement 121 sessions and New Joiner 121 sessions. Unilever have also issued a separate privacy notice which covers how they collect, process and retain your data.
For the Money Matters webinars, New Joiner 121 sessions and At Retirement 121 sessions First Actuarial will be the data controller of the personal data provided to us. This means that First Actuarial is responsible for deciding what personal data about you is required, how it is used and how it should be protected.
For the annual pensions choices webinars and pension choices 121 sessions First Actuarial and Unilever will be the joint data controllers of the personal data provided to us. This means that we are both responsible for deciding what personal data about you is required, how it is used and how it should be protected.
How we look after information about you
First Actuarial needs to hold some of your personal information to carry out your 121 session in which we will discuss your pensions arrangements whilst employed by Unilever, and/or after retiring from Uniilever. The 121 sessions may also be used to discuss your potential choices regarding the use of your benefits envelope.
We are committed to protecting the privacy of the people whose data we use. This privacy notice sets out what personal data we hold about you, the legal basis for using it, your rights, how we use it and the safeguards that are in place to protect it. This is all so that you are fully aware of how and why we are using your data.
We realise this notice is quite long, so we’ve tried to help by summarising the main points here, but it would still be really useful for you to read the notice in full:
We collect information in order to enable:
· You to open a profile on this booking system;
· You to to book a place on a webinar and/or a 121 session;
· Us to enable us to provide that webinar and/or 121 session for you;
· Us to provide a summary handout following the completion of the webinar and/or 121 session;
· Us to ask you for feedback after the webinar and/or 121 session; and
· Us to keep a record of the 121 session for our internal compliance requirements.
The infomation held by First Actuarial has been provided by you or by Unilever. Unilever may in turn have been provided with some information by the UUKPF Trustees.
You can contact First Actuarial at any time to request a copy of the data we hold on you for the purpose of your 121 session.
This privacy notice does not require any action from you; it is for information purposes only. However, if you do have any questions please contact us at the address shown at the end of this privacy notice.
What personal data do we hold and use?
Information used by the website when booking a 121 session or webinar
· Personal information including name, date of birth, and contact details;
· Your usual Unilever place of work;
· Any documents that you upload to the booking system in advance of your 121 session; and
· Any questions that you submit to the booking system in advance of your 121 session.
First Actuarial will be the sole data controller for the above information held on the booking system. If you would like further information, please contact us.
When you login to the website we will place a cookie on your device to ensure we know who you are. This cookie will be deleted when you close the browser.
Optional information collected when using the website
When you first access the website, we will ask you if we can place additional cookies on your device and collect information about how you use the website. This additional information allows us to see how the website is used and track any issues. This enables us to improve the website. If you choose to allow us to place additional cookies on your device, we will use the cookies that are outlined in the cookie notice.
Information used for the 121 session for you.
The information we hold on you may include, but is not limited to, some of the following:
· Personal identifiers such as name, gender, contact details (email address), date of birth, National Insurance number, member reference number, usual location of work.
· Personal and family information such as information on dependants, pension sharing orders, earmarking orders and attachment orders.
· Pension scheme membership and employment information such as dates of employment, date joined scheme, date pensionable service commenced, category of membership, your work level at Unilever, details of any transfers of benefits into the pension scheme, details of any periods of absence and/or breaks in pensionable service, full-time or part-time employment, pension debits or pension credits, details of transfers in, normal retirement age and normal retirement date and pension accrual rates. This may include information about other pension schemes.
· Contribution details such as contributions to the pension scheme and any additional voluntary contributions.
· Financial and investment information such as your benefits envelope, pensions contributions paid, basic salary and pensionable salary, total accrued pension, total prospective pension at Normal Retirement Age (including various tranches that make it up), lump sum benefit payable on death in service, spouse’s pension payable on death in service, pension increase amounts.
· Lifetime allowance and annual allowance information, including details of any Fixed, Primary or Enhanced Protections held or applied for.
Why do we hold information about you?
The lawful reason First Actuarial processes your data is because we have a legitimate interest in:
· fulfilling our duty to Unilever to provide you with access to a webinar and a 121 session so that you can better understand your pensions arrangements and the potential options available for your benefits envelope whilst employed by Unilever and/or after retiring from Unilever.
· fulfilling our duty to Unilever to provide you with access to financial education webinars as part of the Money Matters programme.
· fulfilling our duty to manage the 121 sessions by communicating with you in relation to your 121 session before, during and after the 121 session.
· Creating and maintaining a record of your 121 session for internal compliance purposes.
Where did we get your personal data from?
The personal data we hold about you was given to First Actuarial by you and/or Unilever. Unilever will, in turn, have obtained information about your pension benefits from the UUKPF Trustees.
Who do we share information with?
First Actuarial will not give or sell your information to anybody else unless we are legally required to do so. In particular, we will not share your data with any other parties for marketing, market research or commercial purposes.
First Actuarial may share information with Unilever for the purposes of providing feedback about who has attended a 121 session or booked a place on a webinar.
First Actuarial will not transfer your data outside the United Kingdom.
How long do we keep your data?
First Actuarial will need to keep a summary of your 121 meeting for up to seven years in order to be able to demonstrate that we provided unbiased guidance to you in relation to your pensions benefits and the use of your benefits envelope.
The remainder of the data supplied by you and/or by Unilever will be held by First Actuarial for between one and two years from the date that you supplied it to us.
We never forget that your data belongs to you. Legislation gives you several rights so that you can understand and control how we use your data. You can:
· Ask us for a copy of the information we hold on you
· Ask us to fix any information you believe is wrong
· Ask us to stop using your data
· Ask us to delete your data
· Complain to us about how we use your data.
Whenever possible we will comply with your request. If we can’t comply with your request, we will let you know why. If you have any questions on how we use your data or are not happy with our use of your data, please get in touch with us. If you are still not happy with how we use your data, you should contact the Information Commissioner’s Office at: www.ico.org.uk or via their telephone helpline (0303 123 1113).
You may contact us for further details on how we use your personal information, or with any other questions about this Privacy Notice, including any requests to exercise your rights.
First Actuarial LLP
Unilever Pensions Choices