Why should you read this document?
During the course of dealing with us we will ask you to provide detailed personal information relating to your Employees existing circumstances, their financial situation and, in some cases, their health and family history (your employees personal data). Therefore, this document is important as it explains what we will need to do with your employees personal data, and the various rights your business and your staff have in relation to your company and your employees personal data.
It is your businesses responsibility to obtain approval from your employees, by way of Contract of Employment, Terms of Employment or other means deemed appropriate by you before you pass employee data to us. We will not be contacting directly with staff relating your businesses disclosure of their personal data.
What do we mean by “your employees personal data”?
Your employees personal data means any information that describes or relates to their personal circumstances. Your employees personal data may identify them directly, for example their name, address, date of birth or National Insurance number. Your employees personal data may also identify them indirectly, for example, their employment situation, their physical and mental health history, or any other information that could be associated with their cultural or social identity.
In the context of providing you with assistance in relation to your Businesses Investment, Pensions, Insurance and Employee Benefits, your employees personal data may include: –
- Title, names, date of birth, gender, nationality, civil/marital status, contact details, addresses and documents that are necessary to verify their identity.
- Employment and remuneration information, (including salary/bonus schemes/overtime/sick pay/other benefits), employment history.
- Sources of income and expenditure, family circumstances and details of dependents.
- Health status and history, details of treatment and prognosis, medical reports (further details are provided below specifically regarding the processing we may undertake in relation to this type of information).
- Any pre-existing Pension, Investments or Insurance products and the terms and conditions relating to these.
The basis upon which our Company will deal with your employees personal data
When we speak with you about your Businesses Investment, Pensions, Insurance and Employee Benefits requirements we do so on that basis that both parties are entering a contract for the supply of services. To perform that contract, and to arrange the products your business may require, we have the right to use your employees personal data for this purpose.
Alternatively, either in the course of initial discussions with you or when the contract between us has come to an end for whatever reason, we have the right to use your employees personal data provided it is in our legitimate business interest to do so and your business and your Employees rights are not affected. For example. We may need to respond to requests from pension or insurance providers and our Compliance Service Provider relating to the advice we have given you, or to make contact with you to seek feedback on the service you received.
On occasion, we will use your employees personal data for contractual responsibilities we may owe our Regulator; The Financial Conduct Authority, or for wider compliance with any legal or regulatory obligation to which we might be subject. In such circumstances, we would be processing your employees personal data to meet a legal, compliance or other regulatory obligation to which we are subject.
The basis upon which we will process certain parts of your employees personal data
Where you ask us to assist you with for example your Employees insurance needs, in particular life insurance and insurance that may assist staff in the event of an accident or illness, we may ask you for information about their health and medical history (Special Data). We will record and use the Special Data in order to make enquiries of insurance providers in relation to insurance products that may meet your business needs and to provide you with advice regarding the suitability of any product that may be available to the business or employees.
How do we collect your employees personal data?
We will collect and record your employees personal data from your business or directly from staff. You will usually provide information during our initial meetings or conversations with you to establish your circumstances and needs and preferences in relation to Investment, Pensions, Insurance and Employee Benefits. You will provide information to us verbally and in writing including email.
What happens to your employees personal data when it is disclosed to us?
While handling Your Employees Personal Data, we will:
- Record and store your employees personal data in our paper files, mobile devices and on our computer systems, websites, email hard drives and cloud facilities. This information can only be accessed by employees and staff within our Company and only when it is necessary to provide our service to you and to perform any administration tasks associated with or incidental to that service.
- Submit your employees personal data to Product Providers, both in paper form, email and on-line via a secure portal. The provision of this information to a third party is essential in allowing us to progress any enquiry or application made on your behalf and to deal with any additional questions or administrative issues that lenders and providers may raise.
- Use your employees personal data for the purposes of responding to any queries you may have in relation to any Investment, Pension, Insurance or Employee Benefits the Business may take purchase, or to inform you of any developments in relation to those products and/or policies of which we might become aware.
Sharing your employees personal data
From time to time your employees personal data will be shared with:
- Investment, Pension, Insurance and Employee Benefit providers.
- Third parties who we believe will be able to assist us with your enquiry or application, or who are able to support your needs as identified. These third parties will include but may not be limited to, our Compliance Advisers and Product Specialists.
In each case, your employees personal data will only be shared for the purposes set out in this customer privacy notice, i.e. to progress your Investment, Pension, Insurance and Employee Benefit enquiry and to provide you with our professional services.
Please note that this sharing of your employees personal data does not entitle such third parties to send you or them marketing or promotional messages: it is shared to ensure we can adequately fulfil our responsibilities to you, and as otherwise set out on this Privacy Notice.
Security and retention of your employees personal data
Your Employees privacy is important to us and we will keep your employees personal data secure in accordance with our legal responsibilities. We will take reasonable steps to safeguard your employees personal data against it being accessed unlawfully or maliciously by a third party.
We also expect you to take reasonable steps to safeguard your Employees own privacy when transferring information to us, such as not sending confidential information over unprotected email, ensuring email attachments are password protected or encrypted and only using secure methods of postage when original documentation is being sent to us.
Your employees personal data will be retained by us either electronically or in paper format for a minimum of six years, or in instances whereby we have legal right to such information we will retain records indefinitely.
Your rights in relation to your employees personal data
- request copies of your employees personal data that is under our control and originally provided by you. We will not provide data passed to us directly by staff without their written approval.
- ask us to further explain how we use your employees personal data.
- ask us to correct, delete or require us to restrict or stop using your employees personal data (details as to the extent to which we can do this will be provided at the time of any such request).
- ask us to send an electronic copy of your employees personal data to another organisation should you wish.
How to make contact with us in relation to the use of your employees personal data
If you have any question or comments about this document, or wish to make contact to exercise any of your businesses or your Employee rights set out within it please contact:
Shailesh Patel (Director) at firstname.lastname@example.org
If we believe we have a legal right not to deal with your request, or to action it in a different way to how you have requested, we will inform you of this at the time.
You should also contact us as soon as possible if you become aware of any unauthorised disclosure of your employees personal data , so that we may investigate and fulfil our own regulatory obligations.
If you or your Employees have any concerns or complaints as to how we have handled your employees personal data, employees may lodge a complaint with the UK’s data protection regulator, the Information Commissioner’s Office (ICO), who can be contacted through their website at https://ico.org.uk/global/contact-us/ or by writing to the ICO, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.
The use of “you” or “your” within this text shall be deemed as referring to the corporate entity, our client.