- Introduction and General Terms
- This Privacy Notice sets out how Johnson Controls UK Trustees Limited, the trustee of the Tyco Holdings (UK) Limited CARE Pension Scheme, ("Trustee", "we", "us", "our") obtains, uses and protects any personal information that you provide to us, or that is otherwise obtained or generated by us, and which relates to you or to any individual connected with you.
- This Privacy Notice is effective from 24 May 2018.
- This Privacy Notice explains the following:
- Paragraph 2 - what information we may collect about you;
- Paragraph 3 - what we may use your information for;
- Paragraph 4 - how long we retain your records;
- Paragraph 5 - with whom we may share your information;
- Paragraph 6 - your rights regarding the personal information you provide to us;
- Paragraph 7 - keeping your information safe;
- Paragraph 8 - technical information that we may collect about you;
- Paragraph 9 - changes to our Privacy Notice; and
- Paragraph 10 - how to contact us.
- When you, your employer or any other person provides us with your personal information, we will process that information as outlined in this Privacy Notice.
- The data controller of your personal information is Johnson Controls UK Trustees Limited (the Trustee of the Scheme), a company registered in England under number 03343307 whose registered office is at Security House, The Summit, Hanworth Road, Sunbury-on-Thames, Middlesex, TW16 5DB.
- In some circumstances the Scheme actuary and Buck Consultants Limited will also be data controllers in relation to the personal data you provide. The role of the Scheme actuary is to assist the Trustee to determine how much money it needs to fund the Scheme and also to calculate certain member benefits. Information about where to find their data protection information can be obtained by emailing us at Tyco.pensions@conduent.com, or writing to us at Buck HR Services (Manchester), PO Box 324, Mitcheldean GL14 9BJ.
Contact details:
Buck Consultants Limited, a company registered in England with number 1615055, with registered address at 20 Wood Street, London, EC2V 7AF
- What types of personal information may we collect about you?
- Personal information broadly means information that identifies (or which could, with other information that we hold or are likely to hold, identify) a living individual. This would therefore include any information provided to us in relation to your actual, past or potential membership of the Tyco Holdings (UK) Limited CARE Pension Scheme (the "Scheme") or your receipt of benefits from the Scheme.
- We may hold any or all of the following personal information about you:
- personal details such as your name, gender, age, date of birth, email address, postal address, telephone or mobile number and identifiers such as your National Insurance number;
- family, lifestyle and social circumstances such as details about current marriage and partnerships and marital history, details of family and dependants;
- employment details such as pensionable pay, length of service and, in relation to an application for an ill health pension, your job title, job responsibilities and any other information required to determine whether you are able to carry out your job;
- financial details such as income, salary, assets and investments, bank account details to process pension payments, tax code, and benefits; and
- technical information and other information about your visits to any Trustee website - you can find out more information about this in paragraph 8 below.
We may also process other information about you which reveals information about your health status, such as information related to your physical or mental health, including the provision of health care services ("Sensitive Information"). Where we collect these types of information about you, we will take appropriate steps to get your consent to our collection and use of this information.
How do we collect personal information about you?
- We collect your personal information when you, your employer or any other person contacts us by phone, email or post. We also obtain your information where this is provided through any other discussions or correspondence that you, your employer or any other person may have with us. The Trustee may also collect your personal information from other third parties including tracing agencies and from public sources.
- What we may use your information for and why
We will use your personal information for a number of purposes, as set out in the table below. For each purpose we have also set out why we are able to process your information in this way (i.e. our legal basis for processing your personal information). In general, the Trustee's legal basis for processing your personal information is that this information is necessary for the purposes of both our and your legitimate interest to administer the Scheme properly and ensure that you are paid the correct benefits in accordance with the Scheme's governing documentation. There will also be occasions where we are required to process your personal information in a specific way in order to comply with our legal obligations.
We use your personal information to |
This means that processing your personal information allows us to |
Do we have to process your personal information in this way? |
Administer the Scheme |
- administer the Scheme including to process data to calculate and pay benefits;
- carry out our obligations arising from any agreement that we have with or concerning you and to provide you with the benefits and services that you request from us;
- process Trustee nominations;
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Yes, it is necessary for us to process your personal information so that we can administer the Scheme and provide you with our services (including the payment of your benefits) and ensure that those benefits are provided in compliance with our legal obligations as Trustee of the Scheme. |
Contact and interact with you and other members of the Scheme |
- use information in relation to any correspondence related to the administration of the Scheme (including queries relating to your membership of the Scheme and communications when we are unable to contact members of the Scheme);
- provide you with information about your benefits or any changes to your benefits or the services we provide;
- provide access to (and analyse and improve the activities, services and information offered by) any Trustee website or online platform;
- use IP addresses to identify the location of users of any Trustee or Scheme website, to block disruptive use and to establish the number of visits;
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Yes, it is necessary for us to process your personal information to provide you with information about the Scheme and respond to any queries that you may have, so that you are aware of your benefits and entitlements and so that we can comply with our legal disclosure obligations. |
Manage our day-to-day operations |
keep internal records about your membership of the Scheme; |
Yes, it is necessary for us to keep internal records so that we can effectively communicate with you, your dependants and relatives and your employer (if applicable) about your membership of the Scheme and your entitlements. This also enables us to pay you the correct benefits at the correct time. |
- carry out risk management activities along with the Principal Employer of the Scheme, the Scheme actuary and our advisers such as assessing employer risk, contingency planning and funding activities;
- use your data for risk management including credit risk analysis, know-your client and anti-money laundering checks;
- use your data in connection with the purchase of Scheme investments, such as "buy-in" agreements with insurance companies;
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Yes, it is in your and our legitimate interests to manage the risks to the Scheme so that risks to the payment of your benefits are minimised. |
- comply with any present or future law, rule, regulation, guidance or directive, industry or professional rules and regulations or any applicable voluntary codes;
- comply with demands or requests made by local and foreign regulators, governments and law enforcement authorities, and comply with any subpoena or court process, or in connection with any litigation;
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Yes, we sometimes need to process your data in order to comply with our legal obligations, for example our obligations to keep up to date and accurate information in relation to our members so that we can pay the benefits that members are entitled to in accordance with the governing documentation of the Scheme.
It is in our legitimate interest to comply with all laws, guidance and codes that apply to us, as well as with data requests from regulators, governments, courts, law enforcement and tax authorities to ensure that the Scheme is well run and compliant.
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Improve our day-to-day operations and manage any changes to the Scheme or its sponsoring employers |
handle information in connection with any sale, merger, acquisition, disposal, recognition or similar change involving the Scheme; |
Yes. It is in your and our legitimate interest to be able to process your personal information in these circumstances so that we can minimise any disruption to the Scheme if there is ever a restructuring of the Scheme or its sponsoring employers and ensure that members' benefits are paid. |
Assist with research |
- use your data for statistical, financial modelling and reference purposes; and
- use your data in research which assists actuaries - for example research into the mortality experience (life expectancy) of pension scheme members in general. This may include the provision of data on a no-names basis to a recognised external authority, for example to the Continuous Mortality Investigation (CMI) which investigates mortality experience on behalf of the Institute and Faculty of Actuaries.
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Yes. It is in your and our legitimate interest to be able to process your personal information in these circumstances so that we properly understand the liabilities under the Scheme and make accurate provision for meeting these liabilities. |
As mentioned in paragraph 2 above, we may also need to process Sensitive Information in order to be able to carry out the activities set out in the table above. To the extent that we use Sensitive Information, we will ask for your permission so that we can use that information for the purposes described in this Privacy Notice. Unless we have another lawful ground for processing this data.
- How long do we retain your records?
We will hold your personal information (and any personal information collected in respect of any individual connected with you) on our systems for as long as is necessary in order to carry out the relevant activities or services listed above. However, in certain circumstances it may be necessary for the Scheme to continue to process your information after you have opted out of the Scheme or stopped receiving any benefits from us, for example the Trustee may need to prove that it no longer holds a liability in relation to you.
- With whom we may share your information
We may share or disclose your information to any of the following recipients:
- the Scheme's administrator, the Scheme's actuary, sponsoring employers and the counterparties to the Scheme's investments;
- our service providers, professional advisers and auditors;
- local or foreign regulators, governments, law enforcement and tax authorities;
- local and foreign courts, tribunals and arbitrators or other judicial committees;
- insurance companies and their reinsurers;
- persons in connection with any sale, merger, acquisition, disposal, reorganisation or similar change to the Scheme or the sponsoring employers (including any potential or actual purchaser of the sponsoring employers or their parent companies and that purchaser's advisors).
Our service providers and professional advisers such as the Scheme's legal adviser and auditors may also be data controllers in relation to your personal information and have to comply with their own legal obligations, industry codes and standards when processing your data. Information about where to find their data protection information can be obtained by emailing us at Tyco.pensions@conduent.com, or writing to us at Buck HR Services (Manchester), PO Box 324, Mitcheldean GL14 9BJ.
- Your rights regarding the personal information you provide to us
- We will take appropriate legal, organisational and technical measures to protect your information consistent with applicable privacy and data security laws.
- You have the right:
- to withdraw your consent to the processing of your Sensitive Information, to the extent it is processed on the basis of your consent (as set out above);
- to request information regarding the processing of your personal information, including to be provided with a copy of your personal information;
- to request the correction and/or deletion of your personal information, or restrict or object to the processing of your personal information;
- to request to obtain and reuse your personal information for your own purposes across different services; and
- to complain to your local data protection authority, or to a court of law, if your data protection rights are violated. You may be entitled to claim compensation for damages or distress incurred or suffered in consequence of unlawful processing of your personal information.
- We will process your Sensitive Information (where applicable) unless we receive a written revocation of your consent from you.
- If you would like access to the information that we hold about you, if any of the information we hold about you is inaccurate or out of date, or if you object to us processing it, please let us know by emailing us at Tyco.pensions@conduent.com, or writing to us at Buck HR Services (Manchester), PO Box 324, Mitcheldean GL14 9BJ.
What if you do not provide us with your personal information?
We may not be able to perform the actions necessary to pay your benefits and achieve the other purposes set out in the table in paragraph 3 above and you may not be able to make use of the services offered by us if:
- you do not provide us with any personal information that we may need to comply with our statutory or contractual obligations, as set out in the table in paragraph 3, above; or
- you refuse, or subsequently withdraw, your consent to your Sensitive Information being processed, transferred or disclosed in accordance with the above.
- Keeping your information safe
Transfers of your information
- We may transfer, store, or process your personal information outside the European Economic Area (EEA). Where the countries to which your personal information is transferred may not offer an equivalent level of protection for personal information to the laws of the UK, we will take reasonable steps to ensure that your information is treated securely and in accordance with this Privacy Notice. This may include our entering into data transfer agreements based on the model clauses approved by the European Commission, to ensure that third parties to whom we transfer personal information in those countries nevertheless commit to ensuring an adequate level of protection for your personal information (further information on the model clauses can be found on the following website: https://ec.europa/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en).
- Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the safety of your personal information transmitted via email or any Trustee website which may be available in the future; any transmission is at your own risk. Once we have received your information, we will use reasonable procedures and security features to try to prevent unauthorised access.
- Where we give you (or you choose) a password which enables you to access any Scheme website or portal, you will be responsible for keeping that password confidential. We ask you not to share such passwords with anyone. HM Government's National Cyber Security Programme recommends making your password stronger by using three random words, and numbers/symbols if needed. Please avoid using the same password for multiple online accounts. If you are using a computer or terminal in a public location, we recommend that you always log out and close the website browser when you complete an online session for your security.
- Technical information that we may collect about you
The Scheme Portal Privacy Notice which can be found within the Terms & Conditions page of www.conduenthr.co.uk/jctycocare explains how we collect, use and store:
- any personal information you provide to us for the purpose of opening and maintaining your user account on the Portal. This includes information provided at the time of registering to use this Portal and when updating your user ID, name or contact details. You are required to provide us with this information to gain access to the Portal and to comply with the Portal Terms of Use www.conduenthr.co.uk/jctycocare; and
- information about your visits to the Portal and about your computer, tablet, mobile or other device through which you access the Portal. This may include the Internet protocol (IP) address used to connect your computer to the Internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, and geographical location, the full Uniform Resource Locators (URL), clickstream to, through and from our Portal (including date and time), pages you viewed and searched for, page response times, download errors, and length of visits to certain pages, referral source/exit pages, page interaction information (such as scrolling, clicks and mouse-overs), and website navigation and search terms used.
- Changes to our Privacy Notice
Any changes we make to this Privacy Notice in the future will be posted on this page. Please check back frequently to see any updates or changes to our Privacy Notice. Any changes to this Privacy Notice will become effective when we post the revised Privacy Notice on our website. The date of the most recent revisions will appear on this page.
- Contact
If you have any questions, comments or requests regarding any aspect of this Privacy Notice, please do not hesitate to contact us at:
Bob Purves, Secretary to the Trustee
c/o Buck HR Services
Level 5 Exchange Crescent
7 Conference Square
Edinburgh EH3 8AN
Email: Bob.purves@conduent.com