Intelligent Pensions Ltd may need to collect and use personal data on this web site in order to transact customer's requests effectively. Intelligent Pensions Ltd acknowledges that the proper treatment of personal data is very important to successful transactions as well as ensuring customer satisfaction.
Why should you read this privacy notice?
During the course of dealing with us, we will ask you to provide us with detailed personal information relating to your existing circumstances, your financial situation and, in some cases, your health and family health history (Your Personal Data). This document is important as it allows us to explain to you what we will need to do with Your Personal Data, and the various rights you have in relation to Your Personal Data.
What do we mean by “Your Personal Data”?
Your Personal Data means any information that describes or relates to your personal circumstances. Your Personal Data may identify you directly, for example your name, address, date or birth, National Insurance number. Your Personal Data may also identify you indirectly, for example, your employment situation, your physical and mental health history, or any other information that could be associated with your cultural or social identity.
In the context of providing you with assistance in relation to your pension and retirement planning requirements Your Personal Data may include:
- Title, names, date of birth, gender, nationality, civil/marital status, contact details, addresses and documents that are necessary to verify your identity
- Employment and remuneration information, (including salary/bonus schemes/overtime/sick pay/other benefits), employment history
- Bank account details, tax information, loans and credit commitments, personal credit 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 with regard to the processing we may undertake in relation to this type of information)
- Any pre-existing pension, investment, mortgage, loans or other outstanding credit and insurance products and the terms and conditions relating to these
The basis upon which our Firm will deal with Your Personal Data
When we speak with you about your pension and retirement planning requirements, we do so on the basis that both parties are entering a contract for the supply of services.
In order to perform that contract, and to arrange the products you require, we have the right to use Your Personal Data for the purposes detailed in the sections that follow.
Should our initial discussions with you not result in a contract being entered into, or when a contract between us has come to an end for whatever reason, we retain the right to use Your Personal Data provided it is in our legitimate business interest to do so and your rights are not affected. For example, we may need to respond to requests from providers or our Compliance Service Provider relating to the advice we have given to you, or to make contact with you to seek feedback on the service you received.
On occasion, we will use Your 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 Personal Data in order 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 Personal Data
Where you ask us to assist you with your pension and retirement planning requirements, we will ask you information about your health and medical history (Your Special Data). We will record and use Your Special Data in consideration of advice in relation to pension and retirement planning.
If you have parental responsibility for children under the age of 13, it is also very likely that we will record information on our systems that relates to those children and potentially, to their Special Data.
Information on Your Special Data must be capable of being exchanged freely between intermediaries such as Intelligent Pensions Limited and annuity providers, to enable customers to secure the products that their needs require.
How do we collect Your Personal Data?
We will collect and record Your Personal Data from a variety of sources, but mainly directly from you. You will usually provide information during the course of our meetings or conversations with you to establish your circumstances and needs and preferences in relation to your pension and retirement planning. You may provide information to us verbally and in writing, including email or online submissions.
We may also obtain some information from third parties, for example, existing providers, your employer or your other professional advisers. With regards to electronic ID checks we do not require your consent but will inform you of how such software operates and the purpose for which it is used.
What happens to Your Personal Data when it is disclosed to us?
In the course of handling Your Personal Data, we:
- Will record and store Your Personal Data in our paper files, mobile devices and on our computer systems, for example websites, email, hard drives, and cloud facilities. This information can only be accessed by employees and consultants within our Firm 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
- May submit Your Personal Data to Product Providers or your other professional advisers, either in paper form or on-line via a secure portal or both. This information will only be provided to a third party where it 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 may be raised.
- Will use Your Personal Data for the purposes of responding to any queries you may have in relation to the services we provide you with or the productsyou may take out, or to inform you of any developments in relation to those services or products of which we might become aware.
Sharing Your Personal Data
From time to time Your Personal Data may be shared with:
- Product providers
- Your other professional advisers
- 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 include but are not be limited to, our Compliance Advisers, Product specialists and providers of legal services such as estate planners. Your data will only be shared with such third parties where we believe this to be necessary.
In each case, your Personal Data will only be shared for the purposes set out in this customer privacy notice, i.e. to provide you with assistance relating to your pension and retirement planning requirements and to provide you with our professional services.
Please note that this sharing of Your Personal Data does not entitle such third parties to send you marketing or promotional messages: it is shared to ensure we can adequately fulfil our responsibilities to you, and as otherwise set out in this Customer Privacy Notice.
We do not envisage that the performance by us of our service will involve Your Personal Data being transferred outside of the European Economic Area.
Security and retention of Your Personal Data
Your privacy is important to us and we will keep Your Personal Data secure in accordance with our legal responsibilities. We will take reasonable steps to safeguard Your Personal Data against it being accessed unlawfully or maliciously by a third party.
We also expect you to take reasonable steps to safeguard your 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 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 Personal Data
- request copies of Your Personal Data that is under our control
- ask us to further explain how we use Your Personal Data
- ask us to correct, delete or require us to restrict or stop using Your 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 Personal Data to another organisation
- change the basis of any consent you may have provided to enable us to market to you in the future (including withdrawing any consent in its entirety)
How to make contact with our Firm in relation to the use of Your Personal Data
If you have any questions or comments about this document, or wish to make contact in order to exercise any of your rights set out within it please contact:
Jennifer Bolling, Compliance Officer at Intelligent Pensions Ltd, Cadell House, 27 Waterloo Street, Glasgow G2 6BZ or by telephone at 0141 226 1710.
If we feel we have a legal right not to deal with your request, or to action it in different way to how you have requested, we will inform you of this at the time.
You should also make contact with us as soon as possible if you become aware of any unauthorised disclosure of Your Personal Data, so that we may investigate and fulfil our own regulatory obligations.
If you have any concerns or complaints as to how we have handled Your Personal Data you may lodge a complaint with the UK's data protection regulator, the ICO, who can be contacted through their website at https://ico.org.uk/global/contact-us/ or by writing to Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.
Please also refer to our Terms & Conditions for the website.