Data Protection Policy

Privacy Notice

Atkin Trustees Ltd, trading as Atkin Pensions or Atkin Trustees, provides actuarial, trustee, investment, consultancy and administration services to pension schemes.   For the purposes of data protection legislation, we are data controllers where we act as Trustee or Scheme Actuary, and data processors where we act as administrators.  Where we act as processor, refer to the Privacy Notice of the relevant controller for more information about how your personal data is being processed, and exercising your rights.

Who this policy applies to

  • Members of pension schemes to which we provide services
  • Customers and potential customers
  • Our personnel
  • Our suppliers, contractors and other parties with whom we engage to provide business services
  • Visitors to our website

This policy is set out in the following sections:

  1. How we obtain your personal information
  2. Categories of information we collect
  • Sharing personal information
  • Transfers of personal information
  • Third-party websites
  • Marketing
  • Your rights
  • Automated decision making and profiling
  • Queries and complaints

By accessing or browsing our website, using the services we provide, or providing your information to us, you confirm that you have read and understood this Privacy Notice.

A:    How we obtain your personal information

If you are a customer, an employee of one of our customers or a scheme member, you, your employer or your scheme trustee/administrator may give us personal information about you by using the online forms provided on our website, completing order forms, setting up an account with us, or by contacting us by phone, email or other means. If you are a customer or a potential customer, we may also obtain information about you from your company’s website.

If you are a member of a scheme to which we provide services, we may acquire personal information from third parties such as family members, your employer, insurance companies and medical professionals.

You may provide us with your personal information voluntarily. We may also receive information about you from third parties such as marketing agencies, market research companies, our suppliers, contractors and consultants, group companies, public websites and public agencies, which we refer to as “third-party sources” or “suppliers” throughout this policy.

If you are a contractor or supplier (or a potential contractor or supplier) or other third- party with whom we engage on a business-to-business basis, you or your employer may give us personal information about you when you are, or it is offering or providing services, to us. We may also obtain information about you from your company’s website.

If you contact us on social media, we will collect certain information about you from your social media page and through your interactions with us or with information about our services.

We may acquire personal information from third-party providers in order to promote and market our services. Any such marketing will be carried out in accordance with the provisions of this Privacy Notice.

B: Categories of information we collect

  • Customers and potential customers; personnel who work for our customers, and members of schemes to which we provide services
  • Your name, address and post code
    • Gender
    • Date of birth
    • Email address
    • Telephone number
    • Company name and address
    • Job title
    • Account details
    • Salary and pension details
    • Marital status
    • Health information
    • Information provided in correspondence
    • Information needed to provide services to you

Some of the personal information that we collect about you or which you or your employer provides to us about you may be special categories of data. Special categories of data include information about racial or ethnic origin, political opinions, religious or similar beliefs, trade union membership, your physical and mental health or sexual life.

Please note that we need certain types of personal information so that we can provide services to you. If you do not provide us with such personal information, or ask us to delete it, you may no longer be able to access our services.

We, or third parties on our behalf, may collect and use any of the following information about you:

  • Your name
    • Work contact information
    • Your job title
    • Company name and details
    • Information provided in correspondence

Some of the personal information that we collect about you or which you or your employer provides to us about you may be special categories of data. Special categories of data include information about racial or ethnic origin, political opinions, religious or similar beliefs, trade union membership, your physical and mental health or sexual life.

Please note that we need certain types of personal information so that we can provide services to you or so you, or your employer, can provide services to us. If you do not provide us with such personal information, or ask us to delete it, you may no longer be able to access our services or provide goods and services to us.

  • Visitors to our website, people who contact us with enquiries and people who engage with us via social media
  • Your name
    • Address and post code
    • Email address
    • Telephone number
    • Information provided in correspondence
    • Social media name, or other username
    • IP address used to connect your computer to the internet.
    • Information about your visit to our website

Some of the personal information that we collect about you or which you provide to us about you may be special categories of data. Special categories of data include information about racial or ethnic origin, political opinions, religious or similar beliefs, trade union membership, your physical and mental health or sexual life.

Please note that we need certain types of personal information so that we can provide services to you or so you, or your employer, can provide services to us. If you do not provide us with such personal information, or ask us to delete it, you may no longer be able to access our services or provide goods and services to us

C.    How we use the information and the legal basis for processing

Information on Scheme members is held to allow us to pay pension and death benefits in line with Scheme rules and overriding pension legislation. Each individual is a ‘data subject’ who has rights in relation to the data held by the Trustee or Scheme Actuary data controller and the data processors. Writing, calling or sending e-mails to members with information concerning their benefits or the pension scheme.

The following purposes for processing and the legal basis for processing apply to members of the scheme to which we provide services, customers, potential customers and personnel who work for our customers: 

Purpose for processingLegal basis for processing
To provide relevant services and support to you, your employer or scheme trustee/administrator.  Necessary for the performance of a contract.  
To deal with any enquiries or issues you have about our services, including any questions you may have about how we collect, store and use your personal information, or any requests made by you for a copy of the information we hold about you.  Necessary for the performance of a contract Compliance with a legal obligation (i.e. assisting you to give effect to your rights with respect to the processing of your personal data).  
To send you certain communications about our services such as service announcements and administrative messages (for example, setting out changes to our terms and conditions and keeping you informed about our fees and charges).  Necessary for the performance of a contract (i.e. where the communication is necessary for you to receive or continue to receive our service).Our legitimate interest in running, growing and developing our business.  
To allow you to attend our events.  Compliance with a legal obligation. Our legitimate interest in improving our services.  
To carry out statistical analysis and market research.  Our legitimate interest in running, growing and developing our business.  
We may intercept, monitor and/or keep records of email communications entering and  leaving our systems for security and training reasons and in line with our information handling policies.Our legitimate interest in preventing violations of our terms and policies or other harmful or illegal activity, and in improving our customer service.  

The following purposes for processing and the legal basis for processing apply to contractors, potential suppliers and contractors and other parties with whom we engage on a business basis.

Purpose for processingLegal basis for processing
To enable us to receive and manage services from you (including supplier due diligence, payment and expense reporting and Financial audits).  Necessary for the performance of a contract.  
  For health and safety records and management.    Compliance with a legal obligation.  
To assess your working capacity.  Necessary for the performance of a contract.  
To confirm information on CVs and perform reference checks, to assess you or your employer’s suitability to work for us.  Compliance with a legal obligation. Our legitimate interest in managing our workforce, minimising our risks and maintaining effective business operations.  
For equal opportunities monitoringCompliance with a legal obligation. Our legitimate interest in ensuring effective business management and diversity within our business.
We may intercept, monitor and/or keep records of email communications entering and leaving our systems for security and training reasons and in line with our information handling policies.  Our legitimate interest in preventing violations of our terms and policies or other harmful or illegal activity, and in improving our customer service.  

We may also collect, store and use personal information for the following reasons.

Purpose for processingLegal basis for processing
For internal corporate reporting, business administration, ensuring adequate insurance coverage for our business, ensuring the security of company facilities, research and development, and to identify and implement business efficiencies.    Our legitimate business interest in running, growing and developing our business.  
To comply with any procedures, laws and regulations which apply to us – this may include where we reasonably consider it is in our legitimate interests or the legitimate interests of others to comply, as well as where we are legally required to do so.  Compliance with a legal obligation. Our legitimate interest in preventing and addressing frauds, violations of our terms and policies, or other harmful or illegal activity.  
To establish, exercise or defend our legal rights-this may include where we reasonably consider it is in our legitimate interests or the legitimate interests of others, as well as where we are legally required to do so.Our legitimate interest in responding to complaints; preventing and addressing any harmful or illegal activity; seeking legal advice and protecting ourselves, our users or others.  
If you contact us on social media, to monitor your interactions with us and our brand online, where it is in our legitimate interests to do so for market research and for planning future marketing campaigns.  Our legitimate business interest in running, growing and developing our business.If you are a consumer, the lawful basis for this activity will be consent – please see below for more details.  

We may use your special categories of data where you have provided your consent (which you may withdraw at any time after giving it, as described below).

If we rely on your consent for us to use your personal information in a particular way, but you later change your mind, you may withdraw your consent by contacting us and we will stop doing so. However, if you withdraw your consent, this may impact the ability for you to be able to provide services to us or for us to provide services to you.

D.    Sharing personal information

We will share your personal information with the following categories of third parties:

  • Our service providers and sub-contractors, including but not limited to our online software provider, payment processors, suppliers of technical and support services, insurers, auditors, logistic providers, and IT service providers;
  • Companies that assist us in our marketing, advertising, and promotional activities; and
  • Analytics and search engine providers that assist us in the improvement and optimisation of our website.

Any third parties with whom we share your personal information are limited (by law and by contract) in their ability to use your personal information for any purpose other than to provide services for us. We will always ensure that any third parties with whom we share your personal information are subject to privacy and security obligations consistent with this Privacy Notice and applicable laws.

We will also disclose your personal information to third parties:

  1. Where it is in our legitimate interests to do so to run, grow and develop our business:
    1. If we sell or buy any business or assets, we may disclose your personal information to the prospective seller or buyer of such business or assets;
    1. If substantially all of Atkin is acquired by a third-party, in which case personal information held by Atkin will be one of the transferred assets;
  • If we are under a duty to disclose or share your personal information in order to comply with any legal obligation, any lawful request from government or law enforcement officials and as may be required to meet national security or law enforcement requirements or prevent illegal activity;
  • In order to enforce or apply our terms and conditions or any other agreement or to respond to any claims, to protect our rights or the rights of a third-party, to protect the safety of any person or to prevent any illegal activity; or
  • To protect the rights, property, or safety of Atkin, our staff, our customers or other persons. This may include exchanging personal information with other organisations for the purposes of fraud protection and credit risk reduction.
  • Save as expressly detailed above, we will never share, sell or rent any of your personal information to any third-party without notifying you and, where necessary, obtaining your consent. If you have given your consent for us to use your personal information in a particular way, but later change your mind, you should contact us and we will stop doing so.

E.    Transfer of personal information

Personal  information may be used, stored and/or accessed by third-party data processors. This may be for the purposes listed in section  above

Lf we provide any personal information about you to any non-UK third-party data processors, we. will take appropriate measures to ensure that the recipient protects your personal information adequately in accordance with this Privacy Notice. These measures include:

  • In the case of data passed from the UK to an EEA country, the UK government has recognised these countries as providing adequate protection;
  • In the case of entities based in countries outside the UK and the EEA (including US based entities), entering into approved standard contractual arrangements with them.

F.    Third party websites

Our website (including newsletters and updates) may, from time to time, contain links to websites operated by third parties. Please note that this Privacy Notice only applies to the personal information that we collect, and we cannot be responsible for personal information collected and stored by third parties. Third-party websites have their own terms and conditions and privacy policies, and you should read these carefully before you submit any personal information to these websites. We do not endorse or otherwise accept any responsibility or liability for the content of such third-party, websites or third–party terms and conditions or policies.

G.    Marketing

We may collect and use your personal information for undertaking marketing by email, or phone.

We may send you certain marketing communications (including electronic marketing communications to existing customers} if it is in our legitimate interests to do so for marketing and business development purposes.

However, we will always obtain your consent to direct marketing communications where we are required to do so by law and ifwe intend to disclose your personal information to any third-party for such marketing.

If you wish to stop receiving marketing communications, you can contact us at any time, by calling 0121 506 8200 during business hours or by clicking on the unsubscribe link which will be located in all our marketing communications.

H.    Your rights

You have the right to request that we:

  1. Provide access to any personal information we hold about you. You can ask us for a copy of your personal information; confirmation as to whether your personal information is being used by us; details about how and why it is being used; and details of the safeguards which are in place if your information is transferred outside of the United Kingdom;
  2. Update any of your personal information which is out of date or incorrect;
  3. Delete any personal information which we hold about you in certain specific circumstances. Restrict the way that we process your personal information in certain specific circumstances. You can ask us for further information on these specific circumstances using the details given above;
  4. Prevent the processing of your personal information for direct-marketing purposes;
  5. Provide your personal information to a third-party provider of services. This right only applies where we use your personal information on the basis of your consent or performance of a contract; and where our use of your information is carried out by automated means; or
  6. Consider any valid objections which you have to our use of your personal information where we process your personal information on the basis of our, or another person’s legitimate interest. We will consider all such requests and provide our response within a reasonable period. Please note, however, that certain personal information may be exempt from such requests in certain circumstances. If an exception applies, we will tell you this when responding to your request. We may request you provide us with information necessary to confirm your identity before responding to any request you make.

I. Automated decision making and profiling

Atkin Trustees Limited does not make significant decisions about individuals by wholly automated means.  Staff work on all individual cases.   Atkin Trustees Limited does not carry out ‘profiling’ which is automated processing intended to evaluate certain personal aspects of an individual (for example, health, location or economic situation).

J. Queries and Complaints

If any member has concerns about the data that is held on them by Atkin Trustees Limited or the way that it has been stored or transferred they should contact Atkin Trustees Limited directly using the contact details given below.  Atkin Trustees Limited are registered as data processors with the Information Commissioner’s Office (ICO) Any member that has concerns about the way in which Atkin Trustees Limited has handled your personal information may contact the ICO directly.  The ICO’s website can be found at https://ico.org.uk/   Their telephone number is 0303 123 1113.

Contact Details

Atkin

Cornwall House

Blythe Gate

Blythe Valley Park

Solihull

B90 8AF