Lawful bases and data protection rights

Under UK data protection law, we must have a “lawful basis” for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases on the ICO’s website.

Which lawful basis we rely on may affect your data protection rights which are in brief set out below. You can find out more about your data protection rights and the exemptions which may apply on the ICO’s website:

• Your right of access – You have the right to ask us for copies of your personal information. You can request other information such as details about where we get personal information from and who we share personal informationwith. There are some exemptions which means you may not receive all the information you ask for. You can read more about this right here.

• Your right to rectification – You have the right to ask us to correct or delete personal information you think isinaccurate or incomplete. You can read more about this right here.

• Your right to erasure – You have the right to ask us to delete your personal information. You can read more about this right here.

• Your right to restriction of processing – You have the right to ask us to limit how we can use your personal information. You can read more about this right here.

• Your right to object to processing – You have the right to object to the processing of your personal data. You can read more about this right here.

• Your right to data portability – You have the right to ask that we transfer the personal information you gave us toanother organisation, or to you. You can read more about this right here.

• Your right to withdraw consent – When we use consent as our lawful basis you have the right to withdraw your consent at any time. You can read more about this right here.

If you make a request, we must respond to you without undue delay and in any event within one month.

To make a data protection rights request, please contact us using the contact details at the top of this privacy notice.

Our lawful bases for the collection and use of your data

Our lawful bases for collecting or using personal information to provide and improve products and services for clients are:

• Consent – we have permission from you after we have given you all the relevant information. All your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.

• Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All your data protection rights may apply except the right to object.

• Legal obligation – we have to collect or use your information so we can comply with the law. All your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.

• Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All your data protection rights may apply, except the right to portability. Our legitimate interests include:

  • The primary basis for which we use your data (and data about your family’s circumstances where relevant) is to assist in the running of pension schemes by providing actuarial advice and relatedservices. The information we collect about you is essential for us to be able to carry out theservices that the pension scheme requires from us effectively. Without collecting your personal data wewould not be able to help the pension scheme fulfil its legal and regulatory obligations.

  • A certain amount of personal information is used to help us provide a first-class service to our clients and prospective clients. This includes but is not limited to:

    • Alerting those we think might be interested about forthcoming events or recent industry developments;

    • Noting the preferences of those we interact with, including preferred methods of communication, working patterns, etc.

• Public task – we have to collect or use your information to carry out a task laid down in law, which the law intends to be performed by an organisation such as ours. All your data protection rights may apply, except the right toerasure and the right to portability.

Our lawful bases for collecting or using personal information for the operation of client or customer accounts are:

• Consent – we have permission from you after we have given you all the relevant information. All your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.

• Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All your data protection rights may apply except the right to object.

• Legal obligation – we have to collect or use your information so we can comply with the law. All your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.

• Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All your data protection rights may apply, except the right to portability. Our legitimate interests include:

  • To engage with our clients in the most appropriate way, ensuring we deal with the relevant person at the relevant time to maximise efficiency all round.

  • We also have obligations to know the people we are working with, whether they are clients, suppliers or employees, and we require a certain amount of personal information to fulfil our obligations (both legal and moral) in this area.

• Public task – we have to collect or use your information to carry out a task laid down in law, which the law intends to be performed by an organisation such as ours. All your data protection rights may apply, except the right toerasure and the right to portability.

Our lawful bases for collecting or using personal information for the prevention, detection, investigation or prosecution of crimes are:

• Consent – we have permission from you after we have given you all the relevant information. All your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.

• Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All your data protection rights may apply except the right to object.

• Legal obligation – we have to collect or use your information so we can comply with the law. All your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.

• Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All your data protection rights may apply, except the right to portability. Our legitimate interests include:

  • Ensuring we know the people we are working with, whether they be clients, suppliers or employees, to appropriately identify all relevant parties. 

  • Using personal data in the running of pension schemes to help identify early any activity that could be fraudulent.

• Public task – we have to collect or use your information to carry out a task laid down in law, which the law intends to be performed by an organisation such as ours. All your data protection rights may apply, except the right toerasure and the right to portability.

Our lawful bases for collecting or using personal information for information updates or marketing purposes are:

• Consent – we have permission from you after we have given you all the relevant information. All your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.

• Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All your data protection rights may apply except the right to object.

• Legal obligation – we have to collect or use your information so we can comply with the law. All your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.

• Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All your data protection rights may apply, except the right to portability. Our legitimate interests include:

  • Alerting those we think might be interested about forthcoming events or recent industry developments;

  • Noting the preferences of those we interact with, including preferred methods of communication, working patterns, holidays/festivals of particular importance to contacts, etc.

• Public task – we have to collect or use your information to carry out a task laid down in law, which the law intends to be performed by an organisation such as ours. All your data protection rights may apply, except the right toerasure and the right to portability.

Our lawful bases for collecting or using personal information to comply with legal requirements:

• Consent – we have permission from you after we have given you all the relevant information. All your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.

• Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All your data protection rights may apply except the right to object.

• Legal obligation – we have to collect or use your information so we can comply with the law. All your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.

• Legitimate interests – we’re collecting or using your information because it benefits you, our organisation orsomeone else, without causing an undue risk of harm to anyone. All your data protection rights may apply, except the right to portability. Our legitimate interests include:

  • Helping pension schemes meet their legal requirements regarding the running and operation of the scheme.

  • Assisting us to perform our legal and professional duties, including whistleblowing in any relevant cases.

• Public task – we have to collect or use your information to carry out a task laid down in law, which the law intends to be performed by an organisation such as ours. All your data protection rights may apply, except the right toerasure and the right to portability.

Our lawful bases for collecting or using personal information to protect client welfare are:

• Consent – we have permission from you after we gave you all the relevant information. All your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.

• Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All your data protection rights may apply except the right to object.

• Legal obligation – we have to collect or use your information so we can comply with the law. All your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.

• Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All your data protection rights may apply, except the right to portability. Our legitimate interests include:

  • Ensuring we are dealing with the appropriate people, both from the client and from associated adviser companies.

  • Noting the preferences of those we interact with, including preferred methods of communication, working patterns, holidays/festivals of particular importance to contacts, etc.

• Public task – we have to collect or use your information to carry out a task laid down in law, which the lawintends to be performed by an organisation such as ours. All your data protection rights may apply, except the right to erasure and the right to portability.

Our lawful bases for collecting or using personal information for recruitment purposes are:

• Consent – we have permission from you after we have given you all the relevant information. All your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.

• Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All your data protection rights may apply except the right to object.

• Legal obligation – we have to collect or use your information so we can comply with the law. All your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.

• Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests include:

  • Identifying appropriate candidates and finding out about their skills and abilities.

  • Assessing an appropriate benefit package for relevant candidates.

  • Retaining information on interesting candidates if there is not currently a role for them but there may be in future.

  • Keeping feedback to improve our offering and the experience of those we interview.

• Public task – we have to collect or use your information to carry out a task laid down in law, which the law intends to be performed by an organisation such as ours. All your data protection rights may apply, except the right toerasure and the right to portability.

Our lawful bases for collecting or using personal information for dealing with queries, complaints or claims are:

• Consent – we have permission from you after we have given you all the relevant information. All your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.

• Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All your data protection rights may apply except the right to object.

• Legal obligation – we have to collect or use your information so we can comply with the law. All your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.

• Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All your data protection rights may apply, except the right to portability. Our legitimate interests include:

  • Communicating with all relevant parties involved in the situation.

  • Collating, analysing and retaining relevant evidence and information regarding the case.

  • Considering how a case relates to other similar cases.

• Public task – we have to collect or use your information to carry out a task laid down in law, which the law intends to be performed by an organisation such as ours. All your data protection rights may apply, except the right toerasure and the right to portability.

Our lawful bases for collecting or using personal information to provide advisory services are:

• Consent – we have permission from you after we have given you all the relevant information. All your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.

• Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All your data protection rights may apply except the right to object.

• Legal obligation – we have to collect or use your information so we can comply with the law. All your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.

• Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All your data protection rights may apply, except the right to portability. Our legitimate interests include:

  • The primary basis for which we use your data (and data about your family’s circumstances where relevant) is for providing advisory services. The information we collect about you is essential for us to be able to carry out the services that the pension scheme or the sponsoring employer requires from us effectively. Also, without collecting your personal data we would not be able to fulfil our legal and regulatory obligations.

• Public task – we have to collect or use your information to carry out a task laid down in law, which the law intends to be performed by an organisation such as ours. All your data protection rights may apply, except the right to erasure and the right to portability.