LIFETRACK
Privacy policy
Please read this privacy policy (“Policy”) carefully as it contains important information on how and why the Group Trustees of the RWE Group of the Electricity Supply Pension Scheme (‘Group) (referred to as ‘We’ or “Us’’), c/o Pinsent Masons Pension Services, 30 Crown Place, London, EC2A 4ES will collect, store, use and share your personal data when you visit www.rwepensionsplus.co.uk (the “Site”).
It also explains your rights in relation to your personal data and how to contact Us.
In legal terms, as We are a ‘controller’ of this information, We need to tell you some things about the personal data We have about you, following your access to the Site, and what your rights are in relation to it.
The current data protection laws are set out in the UK General Data Protection Regulation (the ‘UK GDPR’) and the Data Protection Act 2018, together these laws are referred to as the ‘Data Protection Laws’ in this Policy.
The Site is a service operated by Us.
WHAT IS PERSONAL DATA?
Personal data broadly means data that identifies (or which could, with other information that We hold or are likely to hold, identify) a living individual.
This includes any data provided to Us by or on behalf of you.
WHAT TYPES OF PERSONAL DATA MIGHT WE HOLD ABOUT YOU?
As a data controller, We collect and process the personal data about you that you provide by filling in forms (e.g. for registration or subscribing to newsletters) and by corresponding with Us and our service providers by telephone, email or otherwise (e.g when you submit an enquiry or report a problem with the Site). We also collect and process personal data about you that is provided to Us by a third party, such as your employer (as the employer of the Group) or Google analytics.
We may hold and process any or all of the following personal data about you following your visit to the Site, some of which We obtain directly from you for the purposes of using the Site, and in some cases obtained from other sources:
Marketing and Communications data - includes your preferences in receiving marketing from Us and our third parties and your communication preferences; and
Usage data - technical information, including the internet protocol (IP) address used to connect your computer to the internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; and information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our Site (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.
WHERE WE GET YOUR PERSONAL DATA FROM?
Some of the information We get directly from you. We may also get certain information from third-parties such as in relation to some elements of your Usage Data.
If We ask you for other information in the future, We will explain whether you have a choice about providing it and the consequences for you if you do not do so.
WHY WE HOLD THIS PERSONAL DATA?
Data Protection Laws require Us to meet certain conditions before We are allowed to use your personal data in the way described in this Policy.
We hold this personal data because We need it for the running of the Site. More details about how We use your personal data and why, are set out in the table below:
Purpose | Categories of Personal Data | Legal basis for processing | How long We keep it |
Using the Site: We process your personal data when you use the Site. This is done of the following purposes: To measure or understand the effectiveness of advertising We serve to you and others, and to deliver relevant advertising to you; To carry out marketing analysis and make general improvements to the Site and/or our services; To record-keep and track your use of the Site through use of cookies and log files; and To obtain your views or comments on the services We provide. | We process the following type of personal data about you:
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| We store your personal data as long as it is necessary for the purposes mentioned. This will differ depending on the type of information provided and the reason why it was submitted. |
CONSENT
You can withdraw your consent at any time by using our contact details at the end of this Policy. This may affect what We can do for you unless We have another lawful reason for using your information.
If you withdraw consent after our processing, this will not retrospectively affect the processing that has already happened. In limited circumstances, We may need to use your personal data in order to establish, exercise or defend legal claims.
HOW DO WE SHARE PERSONAL DATA?
We may share your information with selected third parties including:
the Group Administrator, Pinsent Masons Pension Services. The Group Administrator uses the information to manage the Site, including the preparation of some of the documents uploaded to the Site;
the Group’s professional advisers, including LikeMinds, the Group’s communications adviser, and Willis Towers Watson, the firm that provides administration and investment advice to Us.
regulators, government departments, law enforcement authorities, tax authorities, any relevant ombudsman, dispute resolution body, or the courts as required to comply with our legal obligations;
any advertisers and advertising networks - that require the data to select and serve relevant adverts to you and others. We do not disclose information about identifiable individuals to our advertisers, but We may provide them with aggregate information about our users (for example, We may inform them that 500 men aged under 30 have clicked on their advertisement on any given day). We may also use such aggregate information to help advertisers reach the kind of audience they want to target (for example, women in a particular postcode). We may make use of the personal data We collect to enable Us to comply with our advertisers' wishes by displaying their advertisement to that target audience; and
any analytics and search engine providers - that assist Us in the improvement and optimisation of our Site.
Except as set out above, We shall not disclose your personal data unless obliged to or allowed to do so by law, or where We need to do so in order to run the Site (e.g. where other people process data for Us). In such circumstances, We will normally put in place confidentiality or non-disclosure undertakings and other arrangements to protect your personal data.
The organisations listed above may also share personal data with their own business suppliers, for example in relation to the operation of IT systems or where they outsource part of their services.
Some of these organisations may also be controllers under the Data Protection Laws. However, in the first instance you should contact Us using the contact details at the end of this Policy if you have any queries about how they use your personal data.
We do not sell, trade or rent your personal data to others.
WHERE DO WE STORE YOUR PERSONAL DATA?
We only currently store personal data within the UK. If We or one of our subcontractors needs to transfer data outside of the UK, then We will take the necessary steps to make sure there are adequate levels of privacy protection in accordance with Data Protection Laws.
These transfers will be governed by the Data Protection Laws. We may transfer your data outside the UK to a country which the UK government considers ensures an adequate level of protection of personal data. These “adequacy regulations” currently apply to a number of countries, including countries within the EU. If there are no adequacy regulations in place, We may only transfer your data if there are adequate safeguards and if you would have enforceable legal rights and effective legal remedies in respect of your data.
HOW LONG DO WE KEEP YOUR PERSONAL DATA FOR?
We will only hold your data for as long as is necessary for the effective running of the Site, in line with the table above, or where you ask Us to delete any records We may delete it earlier.
However, you should note that the right to have data deleted is not an absolute right, and in many cases We may still need to retain your data for a certain period of time.
The duration for which We retain your personal data will differ depending on the type of information and the reason why it was submitted. However, in some cases personal data may be retained on a long term basis.
For example, personal data that We need to retain for legal purposes will normally be retained for at least six years in accordance with usual commercial practice and regulatory requirements.
YOUR RIGHTS IN RELATIONS TO YOUR PERSONAL DATA
You have certain rights in relation to your personal data and these rights can generally only be exercised against a data controller of your personal data.
The accuracy of the personal data that We hold about you is important to Us. We will aim to keep your personal data up to date, but rely on you telling Us promptly if any of the personal data that we hold about you following your visit to the Site changes.
You have a number of rights under Data Protection Laws in relation to the way We process your personal data. You have the right to:
make a request to have your personal data corrected if it is inaccurate, and completed if it is incomplete;
in certain circumstances, to restrict how We process your personal data;
in certain circumstances, to have data deleted or removed
request access to your personal data and to obtain information about how We process it;
in particular circumstances, move, copy or transfer your personal data;
in particular circumstances, object to Us processing your personal data;
not be subject to automated decision-making including profiling where it produces legal or other significant effects on you.
You also have the right to withdraw your consent to processing where you have given consent.
You can exercise all of these rights free of charge except in some very limited circumstances and We will explain these to you where they are relevant.
Not all of these rights are absolute, which means that they may only apply in certain situations and may be subject to legal exceptions and exemptions.
If you wish to exercise any of the above rights, please contact the Data Protection Representative at: GArwe@trustsolutions.co.uk.
You can also exercise your right to prevent processing for marketing purposes by checking certain boxes on the forms We use to collect your data. You can also exercise this right at any time by contacting Us at GArwe@trusteesolutions.co.uk or following the “unsubscribe” option in the latest marketing communication.
Please note that We may be unable to delete or remove your personal data whilst We still need this to administer the Site – see the section on ‘How long do We keep your personal data for?’.
LINKING WITH THIRD PARTIES
The Site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and they will be a data controller of your personal data. We do not accept any responsibility or liability for these policies and you should check these policies before you submit any personal data to these websites. We recommend that you check the policy of third-party sites and contact its owner or operator if you have any concerns or questions.
SECURITY
We employ a variety of technical and organisational measures to keep your personal data safe and to prevent unauthorised access to, or use or disclosure of it. Unfortunately, no data transmission over the Internet is guaranteed to be 100% secure nor is any storage of data always 100% secure, but We do take a number of appropriate steps to protect the security of your personal data.
COOKIES
If you use the Site, you’ll be informed of the presence of cookies which are used to collect information relating to how you use the website. A cookie is a small data file that certain websites store on your computer's hard-drive when you visit such websites.
For more information, Cookie Policy.
LOG FILES
In common with most websites, our Site logs various information about visitors, including internet protocol (IP) addresses, browser type, internet service provider (ISP) information, referring / exit pages and date / time stamp.
We may use this information to analyse trends, administer the Site, track your movement around the Site and gather broad demographic information.
CHANGES TO POLICY
This Policy is current as at September 2023.
Any changes We may make to this Policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to this Policy and, should you object to any alteration, please contact Us as described below under contract details.
ISSUES AND COMPLAINTS
In the unlikely event that you have any concerns or complaints about how your personal data is being used, please contact Us as described beow.
If We are unable to resolve your complaint, you may make a complaint to the Information Commissioner’s Office. Please see https://ico.org.uk/for-the-public/raising-concerns/ for more information.
FURTHER INFORMATION AND CONTACT DETAILS
The information provided in this Policy is in addition to any other privacy information We may give you on this Site via other means. You may also wish to view the Group Trustees’ general Group privacy policy if you are currently a member of the Group, or your current or previous employer’s privacy policy - these will explain how they collect(ed), processed and controlled your personal data in relation to your membership of the Group or employment with the employer.
Questions, comments and requests regarding this Policy are welcomed and should be addressed to the Data Protection Representative at: GArwe@trustsolutions.co.uk.
Whilst this Policy sets out a general summary of your legal rights in respect of personal data, this is a very complex area of law. More information about your legal rights can be found on the Information Commissioner’s website at https://ico.org.uk/for-the-public/.
September 2023