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Institute of chartered accountants staff pensions fund privacy notice

The trustee, FCA Ltd, collects and processes personal data relating to members of the Institute of Chartered Accountants staff pensions fund (the scheme) in order to pay the pensions and associated benefits from the scheme.

What personal data does FCA Ltd collect?

FCA Ltd is committed to being transparent about how it collects and uses personal data and to meet our data protection obligations. ICAEW administers the scheme on the trustee’s behalf. Your data is stored in a range of systems and formats. These include in your electronic personal file, in the pensions administration and management systems and in other IT systems, including the organisation’s email system. For the purposes of operating the pension scheme the following items of data may be held and processed:

  • Your name,
  • Address
  • Email address
  • Telephone numbers.
  • Your gender and date of birth.
  • The dates you were employed by ICAEW or another participating employer.
  • Information about your marital status, dependent and beneficiaries.
  • Details of your standard working hours.
  • Details of periods of leave taken by you, sickness absence, family leave, unpaid leave and the reasons for leave.
  • Copies of your passport, birth and marriage certificates.

Children’s data

  • FCA Ltd may obtain and hold information about dependent children including copies of birth certificates, or health information.

High risk personal data

  • Details of your bank account and national insurance number.
  • Information about your remuneration, including entitlement to benefits such as pensions or life assurance cover.
  • Information from other employers or providers relating to other pension benefits to which you may be entitled.

Special category and criminal offence data

  • Information about medical or health conditions.
  • Where permitted by law, information related to health or sexual orientation.

FCA Ltd may collect this personal data in a number of ways. For example, identity information might be collected through information provided by your employer when you were contributing to the scheme, application forms; from your passport or other documents such as your birth and/or marriage certificates; from correspondence (including email) with you; or through meetings and phone calls.

Personal data provided by third parties

The organisation may collect personal data about you from third parties, such as information from your employer when you were contributing to the scheme, government bodies such as HMRC, or from the administrators of other schemes of which you may be a member and you request us to contact them.

Why does FCA Ltd process your personal data?

In order to comply with data protection laws, FCA Ltd needs a lawful basis to process your personal data. We use the following lawful reasons to obtain and use your personal data.

Consent

FCA Ltd will ask for your express consent if we need to process sensitive personal data, for example, if you apply to retire on the grounds of ill health you will need to provide ICAEW and the trustee with health information supporting your application. If your application is successful the trustee will continue to monitor your eligibility until normal retirement age. To do this the trustee may ask for further health information. 

Legitimate interest

FCA Ltd has a legitimate interest in processing personal data in order to administer the Institute of Chartered Accountants Staff Pensions Fund and provide benefits to members and or their dependents. We process data to:

  • maintain accurate and up-to-date membership records and contact details;
  • calculate benefits due to members;
  • pay benefits to members of the scheme and their dependents
  • calculate the liabilities of the scheme;
  • comply with our obligations under the scheme, with statutory obligations; and
  • respond to and defend against legal claims.

FCA Ltd monitors personal data for the security of staff, and to protect the assets and integrity of the scheme.

Who will have access to your personal data?

FCA Ltd shares your personal data with their professional advisers and ICAEW in connection with their responsibilities towards the scheme. We use external suppliers, consultants and advisers to help us administer the scheme.

We will not share your information, other than for purposes related to the operation of the pension scheme and the interests of the members, without obtaining your consent. If we are unable to obtain your consent, we may share your information where we believe it is in your legitimate interest to do so.

We will seek at all times to ensure your information is shared in a secure manner. While we will make best efforts to protect your information, we cannot guarantee the security of data transmitted  by website, email, post or phone.

Processors

The trustee shares your personal data with third-party processors who provide services to the scheme. These services include: 

  • ICAEW (scheme administrators)
  • Northgate (payroll)
  • Profund (pensions administration system)
  • Pension Tracing Service (DWP)

Joint controllers 

FCA Ltd will share personal data with:

  • Hymans Robertson LLP (actuarial advisers)
  • AON (insurance broker)

Separate controllers

The trustee may share your personal data with organisations where we have a legal obligation, contract or other legitimate interest to do so, including: 
HMRC

  • Eversheds LLP (legal advisers)
  • Just Group plc (insurance)
  • AVIVA (insurance)

Third countries

Your personal data may be transferred to countries outside of the European Economic Area (EEA) for the purpose of payroll. Where data is transferred outside of the EEA, it is done on the basis of appropriate safeguards, for example binding corporate rules, EU model clauses or a declaration of adequacy.

What if you do not supply your personal data?

The information we collect from you is required to provide you with the benefits you and/or your beneficiaries are entitled to receive from the scheme. If you do not provide your personal data, this will hinder the trustee’s ability to maintain accurate records and pay you or your beneficiaries the benefits to which you are entitled.

How long will we hold your personal data? 

FCA Ltd will hold your personal data for the duration of your scheme membership. Following the end of your membership, FCA will dispose of the majority  of your personal data 10 years after you are no longer eligible for benefits from the scheme. FCA Ltd will however, retain limited personal data for the purposes of validating your scheme membership indefinitely.

Where FCA Ltd has a legal obligation to retain your personal data, we will do so for the duration of the legal obligation.