Your information (Fair Processing Notice)

This notice sets out how we use personal information about members of The College of Law Pension and Assurance Scheme (“Scheme”) and their dependants and nominated beneficiaries (“you”).

We are the Trustees of the Scheme. We are committed to protecting your privacy and operate a strict policy in respect of your personal information. Further details are set out below.

We have contracted Deloitte Total Reward & Benefits Limited to undertake the administration of the Scheme on our behalf. Set out below is its statement regarding your personal information.

What personal information do we collect?

Deloitte may collect personal information relating to you such as:

• name
• contact details
• date of birth
• Government identifiers (such as National Insurance number)
• financial information.

Deloitte may also need to process personal information about you that may be considered sensitive or a special category (for example about your health or ethnic origin) that we require to be able to provide the services to our client or that may become apparent to us based on the personal information that we receive.

How do we use your personal information?

Deloitte collects personal information about you to:

• provide services to our client
• produce aggregate insights that do not identify you.

We may also use your personal information for the purposes of, or in connection with:

• compliance with applicable legal, regulatory or professional requirements
• requests and communications from competent authorities
• protecting our rights and/or property.

To whom will we disclose your personal information?

In connection with one or more of the purposes outlined in the “How do we use your personal information?” section above, we may disclose your personal information to:

• other members of the Deloitte Network
• those with whom you have requested us to share information, such as your spouse or civil partner
• our client (in the context of performing our obligations under the relevant client engagement)
• competent authorities, including courts and authorities regulating us or another member of the Deloitte Network, in each case to comply with legal or regulatory obligations or requests
• service providers handling your information on our behalf; in each case, such service providers will be contractually bound by confidentiality and privacy obligations consistent with the obligations in this Privacy Statement
• third parties to whom we disclose information in the course of providing services to our client.

We transfer your information outside the European Economic Area (EEA) if you are based outside the EEA

If you are based outside the EEA, we will transfer your information outside of the EEA in order to pay you. In this case, we will also transfer your information outside the EEA in order to trace you if we lose contact with you, and to confirm your continuing entitlement to benefits. We will also transfer your information outside the EEA if you ask us to transfer your information to an overseas pensions’ provider. We do this because you have consented to this disclosure to allow us to make such overseas payments or because we have taken other measures to ensure that we continue to protect your information. Please contact us at the address set out below if you want more details.

Transfers of your information outside the EEA

Although we do not do so currently, the use and disclosure of your information by the Scheme’s administrator or actuary may in certain cases involve transferring your information to countries outside of the EEA.

In such cases, except where the relevant country has been determined by the relevant public authority to ensure an adequate level of data protection, we will ensure that the transferred information is protected in compliance with applicable data protection rules, for example by a data transfer agreement in the appropriate standard form approved for this purpose by the European Commission or (where applicable) relevant authority in the United Kingdom. Further details of these transfers including information about any data transfer agreements we use are available from us on request.

Retention of your information

We keep your information for the longer of:

1. the period required in order to meet our legal or regulatory responsibilities, and
2. the period envisaged within our record retentions policy.

We determine the period envisaged within such documentation with regard to the Scheme’s operational and legal requirements, such as facilitating the payment of benefits to you or your nominated beneficiaries, calculating and managing the liabilities of the Scheme, and responding to legal claims or regulatory requests.

In general, we will retain your information for twelve years after all entitlements to your benefits cease. For example, information will be retained for twelve years after the death of a member and their nominated beneficiaries (if any).

Your rights over your information

If you have any concerns about our use of your information, you also have the right to make a complaint to the Information Commissioner’s Office, which regulates and supervises the use of personal data in the UK, via their helpline on 0303 123 1113 Details for the office of the Information Commissioner in the UK are available at www.ico.org.uk.

If you are not based in the UK, you have a right to complain to the EU Data Protection Authority (“DPA”) in your jurisdiction. If you would like to be directed to the appropriate DPA, please contact us.

Other matters

This Fair Processing Notice was updated on 11th June 2020. It is non-contractual. We reserve the right to amend it from time to time and will take appropriate steps to bring any such amendments to your attention.

To contact us about the matters set out above, please contact: