This Notice is issued in accordance with the General Data Protection Regulation 2018 (“GDPR”).
You have received this notice because you are applying to be a member of a pension scheme for which Organon Pension Trustees Limited are the professional or scheme trustee and Organon SIPP Services Limited provide administration services (referred to jointly as “Organon Trustees”).
Our contact details are: Organon Trustees, 8th Floor, Regent House, Heaton Lane, Stockport SK4 1BS
Tel: 0161 480 5157
www.organontrustees.co.uk
As trustees of your pension scheme, we are registered with the Information Commissioner’s Office under reference Z1893318 in accordance with the requirements of GDPR and act as both Data Controller and Data Processors.
Our designated Data Protection Approved Person is Marc Gwynne, who can be contacted at the above address or by e-mail at marc@organontrustees.co.uk.
The purpose of processing your personal data, which was originally collected by means of having you complete our paper application form(s), is to enable Organon Trustees to manage all aspects of your pension in full compliance with the relevant pensions legislation from time to time and to comply where appropriate with the requirements of Her Majesty’s Revenue and Customs and the Financial Conduct Authority. Provision of the requested data is a contractual requirement and whilst you have the right to request the deletion of the data relating to you (see below), this may affect our ability to continue acting as trustees and administrators of your pension benefits.
We undertake to have appropriate processes and procedures in place to safeguard personal data against loss, damage, destruction, theft or unauthorised access, use or disclosure. Where data is used in electronic format it will always be transmitted by secure electronic means.
Your personal data will never be passed to third parties without your explicit consent, except where Organon Trustees use computer software or the services of third party IT support providers to manage clients’ personal data, or where it is required by statutory regulatory bodies, such as H M Revenue & Customs, the Financial Conduct Authority, the Pensions Regulator, or the Financial Ombudsman Service. Third parties to whom we may pass personal data, though only with your explicit consent, include financial advisers, accountants, solicitors and other appointed professional advisers, investment providers and banks, as well as regulatory and statutory authorities.
Your personal data will be stored by us for a minimum period of six years after you cease to be a member of a pension scheme managed by Organon Trustees, but we may retain it for such longer period as may be necessary to ensure that your pension benefits comply with regulatory requirements.
Your rights Under GDPR you have the following rights:
- The right to rectification (of incorrect or incomplete data);
- The right to be forgotten (to have personal data deleted);
- The right to data portability (to receive personal data in a structured, commonly-used and machine-readable format);
- The right of subject access (see below).
- Data Subject Access Request (DSAR)
You have the right to submit to us a DSAR concerning the personal data we hold, free of charge. Under GDPR we have one month to respond with details of:
- The purpose of the processing;
- The categories of personal data concerned;
- Third parties to whom it has been or will be disclosed;
- The data retention period or the criteria used to determine it;
- The right to rectification or erasure of the data or to restrict or object to processing it:
- The right to lodge a complaint with the Information Commissioner’s Office;
- Information as to the data’s source (if it was not provided by you).