This is Censeo Actuaries & Consultants Limited’s general privacy notice. To view the Scheme Actuary privacy notice, please click here.
Censeo Actuaries & Consultants Limited (“referred to as “Censeo”, “we”, “us” or “our” in this privacy notice”) respects your privacy and is committed to protecting your personal data.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
This version was last updated on 25 May 2018 and previous versions may be obtained by contacting us using the details shown in paragraph 10 below.
1 Data subjects
Censeo collects personal information and will act as the data controller of this information for the following data subject types:
- clients and their representatives (where authority has been given),
- our business partners,
- individuals on our mailing list and
- visitors to our website. This website is not intended for children and we do not knowingly collect data relating to children.
2 The data we collect about you
Personal data, or personal information, means any information about a living individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes first name, last name, username or similar identifier, title and gender.
- Contact Data includes your postal address, email address and telephone numbers.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
- Usage Data includes information about how you use our website.
- Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Neither do we collect any information about criminal convictions and offences.
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
3 How is your personal data collected?
We use different methods to collect data from and about you, including through:
- Direct interactions. You may give us your information by corresponding with us by post, telephone or email. This includes personal data you provide when you:
- enter into a contract with us or during the performance of that contract,
- provide information through us for compliance with regulations and statutory information requests (for example, anti-money laundering forms and the Pensions Regulator’s Scheme Return),
- subscribe to our publications,
- request marketing to be sent to you or
- give us some feedback.
- Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
- Technical Data from analytics providers and search engines (such as Google based outside the EU),
- Identity and Contact Data from publicly availably sources (such as Companies House based inside the EU).
Your duty to inform us of changes
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
4 How we use your personal data and the legal basis we rely on
We will use your personal information for one or more of the following reasons:
a) to provide the services you have engaged us to provide,
b) to take steps to enter into a contract with you,
d) to send you information you have consented to us sending you, or which we believe might be of interest to you,
e) to improve our services and
f) to make our website more relevant.
The legal bases we rely on to process your data are as follows:
- to fulfil a contract with you (a),
- in our legitimate interest as a commercial organisation to provide services to our clients or for the purpose of business development, provided that our use is proportionate and respects your privacy rights (b), (d), (e), (f),
- to comply with a legal or regulatory obligation (c),
5 Disclosure of your personal data
We may have to share your personal data with the parties set out below for the purposes set out in paragraph 4 above:
- our selected business partners, acting as data processors based in the UK, who assist us in providing services to you,
- professional advisers acting as data processors or joint data controllers, including lawyers and auditors based in the UK,
- HM Revenue & Customs, regulators and other authorities based in the UK, who require reporting of processing activities in certain circumstances,
- third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and we permit them to process your personal data only for specified purposes and in accordance with our instructions.
6 International transfers
We will not transfer your personal data outside the European Economic Area (EEA).
7 Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will process your personal data only on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8 Data retention
How long will you use my personal data for?
We will retain your personal data only for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements.
By law we have to keep basic information about our clients (including Contact and Identity Data) for six years after they cease being clients.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
9 Your legal rights and opting out
Under certain circumstances, you have the following rights under data protection laws in relation to your personal data:
- 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 processing it lawfully.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- 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 to continue to process it. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data where we are relying on a legitimate interest and your particular situation makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You have also the right to object where we are processing your personal data for direct marketing purposes (see below for how to opt out). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data.
- Request the transfer of your personal data to you or to a third party.
- Withdraw consent at any time where we are relying on consent to process your personal data.
If you wish to exercise any of the rights set out above, please contact us. Usually you will not have to pay a fee to access your personal data (or to exercise any of the other rights).
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to help us protect your personal data.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
You also 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 (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.
You can ask us to stop sending you marketing messages at any time by sending an email to firstname.lastname@example.org, with “Unsubscribe” in the subject line.
10 Our contact details
If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.
Matthew Hill, Data Protection Manager
Censeo Actuaries & Consultants Limited
The Portway Centre, Old Sarum Park, Salisbury SP4 6EB