PUBLICIS PRIVACY NOTICE

PRIVACY NOTICE FOR MEMBERS OF: D’Arcy Masius Benton & Bowles Pension and Death Benefit Scheme Publicis Limited Pension and Assurance Scheme and the Saatchi & Saatchi Group Pension Scheme and the Leo Burnett Pension Scheme

Introduction

This Privacy Notice applies to information that the Trustee holds about you.

The information we hold about you is known as ‘personal data’ and is subject to certain legal safeguards.

Whilst this Privacy Notice is important, you do not need to take any action in respect of it.

Data Controllers

Capital Cranfield Pension Trustees Limited (“Capital Cranfield”) are the trustee of the pension schemes listed above and are a “data controller” of the personal data collected and used by the schemes.

In addition, the Scheme Actuary (currently Adam Bracken FIA) and our Actuarial Advisers (Buck) act as a joint data controller in respect of the personal data that they use. This Privacy Notice also covers these joint data controllers.

What personal data do we hold?

We hold personal data about you to enable us to calculate and pay benefits to you or your dependants. The information will also be used, where necessary, for the financial management of the scheme.

The information we hold about you may include:

details of your employment history, including salary information and length of service

personal information including name, date of birth, National Insurance number, marital status and contact details

records of any benefits you have transferred into the scheme from other pension arrangements

information on benefits you will receive from the scheme

your bank account details (but only from the time we need to start paying benefits to you).

How is data collected?

The personal data we hold about you is given to us by:

The employer, who provided us with data such as your salary information and information on when you joined and left employment.

You, for example, through the forms which you completed when you joined the scheme or information provided subsequently when you contacted the administrators of the scheme,

Previous pension schemes, where you transferred your benefits into the scheme. This will include information such as your dates of service, contracted-out benefits (if applicable) and contributions.

Your doctor, where we have needed to obtain medical information if you have applied for ill-health early retirement.

Government agencies, for example tax codes, national insurance history, contracted-out benefits etc.

Why do we hold this information?

We hold this information as we have a legitimate interest in ensuring that the correct benefits are paid to scheme members and their beneficiaries.

We also need the data to (i) fulfil our legal obligations to keep and maintain records about you, (ii) to fulfil our obligations to HMRC and (iii) to calculate whether the Scheme has enough money to pay future benefits.

We may also hold ‘sensitive’ data (also known as “special categories of data”), such as health information, which would be collected when considering whether to pay any ill-health benefits.

If we have to collect sensitive data it will be in accordance with data protection requirements and/or because you consent, at the time, to us holding and using this information.  You may withdraw that consent at any time, in which case we will erase that sensitive data. However, if we consider that doing this will prevent us from paying the correct benefits to you or your dependants, we will let you know before proceeding.

The Scheme Actuary and Buck also hold and use some of your personal data. The lawful reason they hold this data is because they have a legitimate interest in providing actuarial advice and valuations to us. For example, the Scheme Actuary carries out calculations to advise us if the scheme has enough money to pay the future benefits promised to its members.

Do you share data with any other parties?

In order to run the scheme, your personal data  will be used by the Scheme Administrator (currently Buck) and our advisers, as necessary including the Scheme Actuary (currently Adam Bracken FIA), actuarial advisers (currently Buck), auditor (currently Ernst & Young and BDO) and legal advisers (currently Mills & Reeve).

From time to time we may also need to share your personal data  with external consultants and service providers who perform tasks on our behalf to assist with the running of the scheme or to other parties where we believe it is in the legitimate interests of the scheme (this may include annuity providers and tracing agencies; for example, if you move to a new house and don’t tell us your new address). Where we do share information with these parties we remain in control of the data and we will ensure that suitable data protection agreements are in place.

We may transfer your data to separate third parties. These parties may include:

official organisations who we have a legal obligation to provide information to. This includes HMRC and the Pensions Regulator

insurance companies, for example, if we buy an annuity on your behalf

other pension schemes, if you ask us to transfer your benefits to a new scheme

the Employer, or their advisers, to enable them to manage their financial commitment to the Scheme, to produce pension related accounting disclosures and to allow them to answer questions you may have about your benefits or to give you guidance on pension related matters.

Where possible we will anonymise your data before it is shared with third parties. We only share information about you where it is necessary for the running of the scheme.

How long do we keep your data?

Given the long term nature of pensions we keep information about you for the lifetime of the scheme. Should we change administrators or advisers we will ensure that the previous providers pass on your personal data to the new providers and destroy any additional copies of personal data that they hold after a suitable period of time.

Your rights
Data protection legislation gives you a number of rights:

You can ask for a copy of the information we hold about you.

If, at any point, you believe the information we hold about you is wrong, you can ask us to correct it.

In some circumstances, you may also have a right to ask us to restrict the processing of your personal data, to object to processing or to transfer or erase your personal data.

You can obtain further information about these rights from the Information Commissioner’s Office at: www.ico.org.uk or via their telephone helpline (0303 123 1113.).

Complaints

If you have any complaints about how we process your personal data, please let us know and we will do our best to resolve the issue. You also have the right to complain directly to the Information Commissioner’s Office.

Contact Details

If you would like any more information about the matters covered in this Privacy Notice, wish to exercise any of your rights in relation to the personal data we hold, or have a complaint about how we process your personal data, please write to the Secretary to the Trustee at Buck (Ipswich), PO Box 323, Mitcheldean, Gloucestershire, GL14 9BL or e-mail publicis@buck.com

Changes to this Privacy Notice

We keep our Privacy Notice under regular review and will notify you of any changes. This Privacy Notice was last reviewed and updated in January 2022, following a change in Trustee.