Standard Life Assurance Limited Privacy Policy

Your rights, your information and how we use it

The Trustees (“The Trustees”) of the Standard Life Staff Pension Scheme (“the Scheme”) are committed to protecting your personal information.

Our Privacy Policy contains important information about what personal details we collect; what we do with that information; who we may share it with and why; and your choices and rights when it comes to the personal information you have given us.

We may need to make changes to our Privacy Policy; so please check our website for updates from time to time. If there are important changes such as changes to where your personal data will be processed; we will contact you to let you know.

This version of our Privacy Policy was last updated 05/10/2018

Who we are

We are The Trustees of the Standard Life Staff Pension Scheme. Under data protection law, we are a “data controller” of the information we hold about you.

This Privacy Policy applies to The Standard Life Staff Pension Scheme.

How to contact us

If you have any questions about our Privacy Policy or the information we collect or use about you, please contact the Scheme Secretary;

c/o Aon, Atria One, 144 Morrison Street,
Edinburgh EH3 8EX or
standardlifetrusteesecretarialmailbox@aonhewitt.com

Information we collect and use

Information about you that we collect and use includes:

  • Information about who you are e.g. your name, date of birth and contact details
  • Information connected to your membership of the scheme e.g. your service dates, bank account details
  • Information about your contact with us or our representatives e.g. meetings, phone calls, emails / letters
  • Information that is automatically collected when you visit one of the websites hosted on our behalf. Please see the Cookie policy page for more information about cookies
  • Information classified as 'sensitive' personal information e.g. relating to your health or sexual orientation. This information will only be collected and used when it's needed to process a request about your benefits under the Scheme or to comply with our legal obligations
  • Information you may provide us about other people e.g. beneficiaries for any benefits payable under the Scheme
  • Information on children e.g. where a child is named as a beneficiary under the Scheme. In these cases, we will collect and use only the information required to identify the child (such as their name, age, gender).

Where we collect your information

We may collect your personal information directly from you, from a variety of sources, including:

  • an application form to request a quotation and/or payment of a benefit
  • phone conversations with us
  • emails or letters you send to us
  • meetings with one of our advisers e.g. our administrators Mercer
  • participating in research surveys to help us understand you better and improve our products and services
  • our online services such as websites, social media and mobile device applications ('Apps')

We may also collect personal information on you from other sources, including your employer, as well as business directories and other commercially or publicly available sources (to check or improve the information we hold such as contact information)

What we collect and use your information for

We take your privacy seriously and we will only ever collect and use information which is personal to you where it is necessary, fair and lawful to do so. We will collect and use your information only where:

  • you have given us your permission [consent] e.g. to send you information about benefits payable under the Scheme. If you do so you are free to withdraw your permission at any time
  • it's necessary for us to meet our legal or regulatory obligations e.g. to pay your retirement benefits, to send you Annual Benefit Statements, or to keep you updated about any changes and/or developments to the Scheme
  • it's in the legitimate interests of Trustees e.g. to correctly calculate and/or pay your benefits under the Scheme
  • it's in the legitimate interests of a third party e.g. sharing information with your employer for the governance of the Scheme

If you do not wish us to collect and use your personal information in these ways, it may mean that we will be unable to provide you with your benefits under the Scheme.

Who we may share your information with

We may share your information with third parties for the reasons outlined in 'What we collect and use your information for.'

These third parties include:

  • Companies within Standard Life Aberdeen Group
  • Your financial adviser or employer
  • Companies we have chosen to support us in the running of the Schemes such as the Scheme administrator, the Scheme Actuary, Scheme Secretary and our auditor
  • Our regulators and Supervisory Authority e.g. the Pensions Regulator, the Information Commissioner's Office for the UK (the ICO)
  • Law enforcement, credit and identity check agencies for the prevention and detection of crime
  • HM Revenue & Customs (HMRC) e.g. for the processing of tax relief on pension payments or the prevention of tax avoidance

We will never sell your details. Whenever we share your personal information, we will do so in line with our obligations to keep your information safe and secure.

Where your information is processed

The majority of your information is processed in the UK and European Economic Area (EEA).

However, some of your information may be processed by third parties we work with outside of the EEA, including countries such as the United States, New Zealand and India

Where your information is being processed outside of the EEA, we take additional steps to ensure that your information is protected to at least an equivalent level as would be applied by UK / EEA data privacy laws e.g. we will put in place legal agreements with our third party suppliers and do regular checks to ensure they meet these obligations. You can contact us for more information about this.

How we protect your information

We take information and system security very seriously and we strive to comply with our obligations at all times. Any personal information which is collected, recorded or used in any way, whether on paper, online or any other media, will have appropriate safeguards applied in line with our data protection obligations.

Your information is protected by controls designed to minimise loss or damage through accident, negligence or deliberate actions. Our advisors also protect sensitive or confidential information when storing or transmitting information electronically.

Our security controls are aligned to industry standards and good practice; providing a control environment that effectively manages risks to the confidentiality, integrity and availability of your information.

How long we keep your information

We will keep your personal information only where it is necessary to provide you and your potential dependents with benefits under the Scheme.

We may also keep your information after this period but only where required to meet our legal or regulatory obligations. The length of time we keep your information for these purposes will vary depending on the obligations we need to meet.

Your individual rights

You have rights in relation to how we use your information. These rights may include:

Right to be informed

You have a right to receive clear and easy to understand information on what personal information we have, why and who we share it with - we do this in our Privacy Policy and privacy notices.

Right of access

You have the right of access to your personal information. If you wish to receive a copy of the personal information we hold on you, you may make a data subject access request (DSAR). See above for contact details.

Right to request that your personal information be rectified

If your personal information is inaccurate or incomplete, you can request that it is corrected.

Right to request erasure

You can ask for your information to be deleted or removed if there is not a compelling reason for the Trustees to retain it.

Right to restrict processing

You can ask that we block or suppress the processing of your personal information for certain reasons. This means that we are still permitted to keep your information - but only to ensure we don't use it in the future for those reasons you have restricted.

Right to data portability

You can ask for a copy of your personal information for your own purposes to use across different services. In certain circumstances, you may move, copy or transfer the personal information we hold to another company in a safe and secure way. For example, if you were moving your pension to another pension provider.

How to make a complaint

We will always strive to collect, use and safeguard your personal information in line with data protection laws. If you do not believe we have handled your information as set out in our Privacy Policy, please contact the Scheme Secretary (see "How to Contact Us" above) and we will do our utmost to make things right.

If you are still unhappy, you can complain to our Supervisory Authority. Their contact details are on their website http://ico.org.uk