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This is the privacy notice for the B&CE group (excluding The People’s Pension) and it explains how we use any personal information we collect about you.
As required by data protection law, this Privacy notice gives you information from the data controllers who use your personal data regarding a B&CE group product or service.
Several different data controllers in the B&CE group may be using your personal data. A data controller is responsible for the way your data is stored and used – and for how long. We have different data controllers depending on the product or service you have with the B&CE group. Please see ‘Data controller’ at the end of this notice.
In this Privacy notice, ‘we’ means the Data Controller in the B&CE Group.
You may be a member or policyholder of one of our pension or insurance products because you work, or used to work, for one of the many employers who used a B&CE product.
If you work or have worked in construction services, you may be a beneficiary of B&CE’s Charitable Trust or be a member of B&CE’s occupational health scheme.
You may also be an employer, adviser or intermediary who has enrolled employees into one of our products or looks after the account. Or you may be a third party who is acting on behalf of, or providing information in relation to, a B&CE Charitable Trust applicant or member of the occupational health scheme.
We may receive personal information about you when you contact the B&CE group by doing any of the following:
The information you give us about you (and related parties) may include the following:
If your employer offers or offered one of our products or services, we receive personal data about you from them or their business or payroll adviser. This may be to enrol you in a pension or one of our benefit schemes and may include your contact details, date of birth, gender, employment details, National Insurance number, health details and financial information.
We may receive personal data from professional bodies (such as medical professionals), referring bodies (such as advice bureaus), and from people acting on your behalf.
Personal data in beneficiary nominee forms will come from the member. Personal data about members’ dependants, other beneficiary nominees, and death-in-service nominees, will also come from you or your representative. If you give us information about another person, you confirm by doing so that they have given you permission to provide it to us and for us to be able to process their personal data, including any sensitive or special category personal data. You confirm that you’ve told them who we are and what we will use their data for, as set out in this notice.
We also work closely with a number of third parties, including credit checking companies, analytics providers, software providers or payroll providers, and regulatory authorities or government departments, and may receive information about you from them.
In some instances, personal information may also include criminal allegations or convictions, financial and bank account numbers, or unique identifiers such as driver’s licence, and passport numbers, which help to confirm your identity.
If we ask you for other information in the future (for example, about your health), we will explain whether you have a choice about providing it and the consequences for you if you do not do so.
When we need to use information about your health (or other very personal and private information), we may ask for your explicit consent to process this information. Processing may also be necessary for the purposes of preventative or occupational medicine, and to assess your working capacity. However, sometimes there may be reasons of public interest or law that enable B&CE to use this information without consent, and will do so if that is necessary for B&CE to run the scheme in a sensible way. You can withdraw your consent at any time by using the contact details given below. This may affect what we can do for you, unless we have another lawful reason for using your information.
We use your personal data:
B&CE has a legitimate interest in ensuring we give you high-quality service. Given the long-term nature of the products and services we offer and the lifecycle and changing needs our customers will experience, the B&CE group may also send non-statutory communications or marketing campaigns that we have identified are relevant and of benefit to you and your needs.
We may use your information for research or statistical purposes. These include analysing how people use our websites, view our products, respond to our advertising, interact with us via social media such as Twitter and Facebook, use any mobile apps, and improve our understanding of what customers need. Processing personal data for analysis purposes helps us to better understand your interests. It also enables us to tailor our communications to make them relevant and interesting to you. You can change your marketing preferences at any time. For further details see ‘Managing your preferences’.
B&CE will only use your personal data to manage your products or services and to communicate with you about information that may be of interest.
However, sometimes B&CE would like to contact you with details of other products or services it provides. You can choose to receive these types of communications in our Preference Centre – see ‘Managing your preferences’.
B&CE aims to ensure you only receive communications about information that is of interest to you or that enhances our services to you.
You can opt out of marketing or communications that are not required by law or not required to efficiently manage your product and service.
You may also opt out of certain data-processing activities such as research and data analysis.
To do this, call B&CE on 0300 2000 555 (members) or 01293 586666 (employers and business advisers).
B&CE may share or disclose personal data when necessary to provide our services or conduct our business operations. When B&CE shares personal data, we do so in line with data privacy and security requirements. Sharing information enables us to better understand your needs and manage the product or service we provide to you in the most efficient way. If you want any more information from any of the recipients or to use any rights regarding the information they hold, please contact B&CE using the details at the end of this notice.
Below are the parties with whom we may share personal information and why.
Within the B&CE group of companies: Personal data may be shared with other companies in the B&CE group (you’ll find a list of these at the top of this privacy notice). This allows us to efficiently provide administration, customer and technical support, marketing and business and product development. All our employees and contractors must follow our data privacy and security policies when handling personal information.
Our third-party service providers: B&CE provides personal data to these third parties when they need it to fulfil their services to B&CE.
Their services include:
B&CE third-party service providers are not permitted to share or use personal information that B&CE makes available to them for any other purpose than to provide their service. When B&CE outsources any process, we will ensure any supplier or contractor has adequate security measures in place.
Third parties for legal reasons: B&CE will share personal information when we believe it is required, to comply with legal obligations and respond to requests from government agencies, including law-enforcement and other public authorities such as Regulators. Personal information may also be shared with your employer or their adviser to administer your scheme.
Third parties with your consent: We may also share your personal data with someone else where you have given your consent – for example, to discuss your details or refer you to another organisation for specialist advice.
Some of the people mentioned just use your personal data in the way the B&CE data controller tells them. However, others may make their own decisions about the way they use this information to perform their services or functions, or to comply with regulatory responsibilities as controllers in their own right. In this case, they are subject to the same legal obligations regarding this information. The rights you have regarding your information apply to them too.
If you want any more information from any of these recipients or to exercise any rights regarding the information they hold, please contact B&CE and you will be put in touch with them.
Customer data held directly by B&CE is stored on secure servers in the UK. We do not transfer customer data outside the European Economic Area. B&CE holds data in various forms, including electronic databases and paper files. We take all reasonable steps necessary to ensure your data is adequately protected and processed in line with this privacy notice.
B&CE works with third-party suppliers during their business activities. Sometimes these suppliers need to receive and store data on B&CE’s behalf. B&CE does detailed checks (due diligence) on these suppliers, which includes detailed questionnaires about their information security, data protection and encryption policies and procedures. Some of the people (this includes organisations) that B&CE shares your information with may process it overseas. This means your personal data may sometimes be transferred outside the UK and the European Economic Area. Some countries already provide adequate legal protection for your personal data. In other countries, additional steps will be needed to protect it.
We take data security seriously. Our information security policies and procedures are closely aligned with widely accepted international standards. They are reviewed regularly and updated as necessary to meet our business needs, changes in technology and regulatory requirements.
We will retain and process your personal information to comply with our legal obligations, pay any benefits due to you or concerning you, resolve disputes, evidence claims and relationships and to enforce our agreements. We will keep your information for long enough to ensure that, if a query arises in the future about your benefits, we have enough information to deal with it. If data is kept as evidence of the payment of a claim or transfer, it will be archived and reduced to the minimum information needed to allow identification and confirmation of the claim payment.
When we no longer need personal information, data will be disposed of or minimised. This will happen in line with approved company processes to ensure all reasonable efforts and precautions are taken to protect the confidentiality of the data. The B&CE group keeps a data retention policy which details the required timescales for the documents and data it processes.
You have the right to lodge a complaint directly with the supervisory authority, the Information Commissioner who can be contacted on 0303 123 113. You may be asked to provide proof of identity when making these requests. You have other rights under data protection law that you can exercise against B&CE, but please note that these will not apply in all circumstances. You can exercise those rights free of charge except in some very limited circumstances, which will be explained to you where relevant. For more information about all these rights and how to exercise them, please contact B&CE who will be able to tell you more. Short descriptions of your rights are as follows:
Right of access – you have a right to request access to your personal data, to obtain confirmation that it is being processed, and to obtain certain prescribed information about how it is processed.
Right of rectification (correction) – in certain circumstances you have a right to ask for your personal data to be corrected if it is inaccurate, and completed if it is incomplete. Where your personal data in question has been disclosed to organisations, they must be informed of the rectification if possible.
Right to be forgotten – in certain circumstances you can ask to have your personal data erased. It may not always be possible to accept your request where, for example, B&CE has a legal duty to retain or process your information.
Right to restriction of processing – where certain conditions apply, you have a right to restrict the processing of your information.
Right of portability – in certain circumstances, you have the right to move, copy or transfer your personal data to another organisation or to yourself. This right is only relevant if personal data is being processed based on a consent (or to perform a contract) and is done automatically. This right is different from the right of access, and the types of information you can get under the two separate rights may be different. Using the data portability right, you cannot get all the personal data you can get using the right of access.
Right to object – you have the right in certain circumstances to object to certain types of processing of your personal data where it is based on legitimate interests, where it is processed for direct marketing (including profiling relevant to direct marketing), or where it is processed for the purposes of statistics.
Automated decision making – B&CE may profile your data for marketing and communication purposes, which you can opt out of. We do not do any automated decision-making that would produce legal or other significant effects on you. You can also withdraw consent if you have provided it and if this is being relied on as the legal basis for using your personal data.
|Product or service||Data controller|
|B&CE EasyBuild Stakeholder Pension, Employee Accident and Life cover,
Rapidcash injury insurance
|B&CE Insurance Limited|
|B&CE Lump Sum Retirement Benefit Scheme (LSRB),
B&CE Additional Voluntary Contributions (AVC)
|The Building & Civil Engineering Benefits Scheme Trustee Limited|
|Occupational Health||Constructing Better Health|
|Charitable Trust applicants||The Building and Civil Engineering
|Tutman B&CE Contracted-out pension||B&CE Financial Services Limited|
If you wish to make a complaint, find out more information about how your personal data is being processed by or on the behalf of the data controller(s), or exercise your rights, you can contact B&CE.
B&CE’s Data Protection Officer, who is the Group Director of Business Assurance, will act as a point of contact for data protection queries about the controllers by liaising with them on your behalf.
You can write to the Data Protection Officer, Risk and Regulatory Compliance Department, Manor Royal, Crawley, West Sussex, RH10 9QP.
For members of EasyBuild Pension, Employee Accident and Life Cover, Lump Sum Retirement Benefit, and RapidCash Injury Insurance, please email firstname.lastname@example.org or call 0300 2000 555.
For employers or advisers offering a B&CE product or service to your employees, please email email@example.com or call 01293 586 666.