1. This Privacy Notice
Willis Human Capital & Benefits Ireland Limited ("we" or "us") ") is part of the Willis Towers Watson group which operates worldwide through its subsidiary and affiliate companies (collectively, "Willis Towers Watson").
We provide the Pension Portal (the "Site") as the administrators of your occupational pension scheme ("Scheme"). Access to this Site is made available to Scheme members ("you") by the Scheme trustee(s) and/or your employer.
This privacy notice describes how we handle personal information processed through the Site. If you do not agree to this privacy notice, you should cease using the Site.
2. Personal Information Processed Through the Site
“Personal Information” is information that identifies you as an individual or relates to an identifiable individual.
Through the Site, you will be able to access your unique Scheme membership profile which contains information supplied to us by the Scheme trustee(s) and/or your employer ("Member Data”), such as your name and contact information, your staff number, salary details, employment details, contribution amounts, your desired beneficiaries and your investment choices.
You will also be able to review, correct and supply certain new information to the Scheme trustee(s) through the Site, which will also be considered "Member Data".
We process the Member Data outlined above in our capacity as Scheme administrators, acting as processors on behalf of the Scheme trustee(s). We process Member Data solely in connection with the administration of the Scheme, and under the instruction of the Scheme trustee(s). Please refer to the Scheme privacy notice for details on how Member Data is processed by the Scheme trustee(s).
3. Purposes and Legal Bases for Processing Personal Information
We process Member Data as processors acting on behalf of the Scheme trustee(s), except where we are required to process Member Data to comply with our legal obligations (in which case, we process Member Data in accordance with our legal obligations). For more information about the legal bases on which the Trustee(s) process your Member Data, please contact the Scheme trustee(s) in the usual way or contact email@example.com.
We process Site Usage Data for our legitimate interests, which include:
- analysing use of the Site;
- improving Site content; and
- monitoring and improving Site performance.
4. Disclosure of Your Personal Information
We only disclose Member Data to third parties when we are instructed or authorised to do so by the Scheme trustee(s), or where we are required to disclose the data by law (for example, to a court, regulator, government body, law enforcement agency or professional body).
We may disclose Site Usage Data to other Willis Towers Watson group entities and/or third party services providers that help us to operate or improve the Site.
5. Aggregated and Anonymised Data
We may aggregate and/or anonymise information about you. Aggregated and anonymised data is not capable of being used to identify individuals and is not treated as Personal Information under this privacy notice.
We maintain appropriate technical and organisational security measures to protect the security of your data against loss, misuse, unauthorised access, disclosure or alteration. Despite this, the security of the transmission of information via the Internet cannot always be guaranteed and you acknowledge this in your access and use of the Site. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of your account has been compromised), please immediately notify us in accordance with the “Contact & Comments” section below.
7. Cross Border Transfer
The Site is hosted in the Ireland with IT support provided from Serbia. However, because of the global nature of our business your Personal Information may be processed in other jurisdictions where we have facilities or in which we engage service providers. We have established safeguards to protect Personal Information that is transferred to other countries, including appropriate contractual protections. For more information on the appropriate safeguards in place, please contact us using the contact details below.
8. Choices and Access
If you would like to review, correct, update, restrict or object to the processing of your Member Data or request a copy of your Member Data, please contact the Scheme trustee(s) in the usual way or contact firstname.lastname@example.org to handle your request.
If you would like to review, correct, update, restrict or object to the processing of any other Personal Information we hold about you, you may contact us by sending us an email at email@example.com or sending your request by postal mail to the address provided in the “Contact & Comments” section below.
Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion. There may also be residual information that will remain within our databases and other records, which will not be removed, but where that is the case we will take steps to prevent such data from being accessed or used.
9. Retention Period
We retain your Personal Information for as long as we provide services to the Scheme trustee(s), unless otherwise instructed by the Scheme trustee(s). When we have ceased providing the services, we will then retain your Personal Information for a period of time that reasonably allows us to comply with our regulatory obligations and to commence or defend legal claims. We may retain aggregated or anonymised data (which is not treated as Personal Information under this privacy notice) for longer.
For more information about the retention of your Member Data, please contact the Scheme trustee(s).
10. Changes to Our Privacy Notice
We may modify or update this privacy notice from time to time by posting a revised version on the Site. Where changes to this privacy notice will have a fundamental impact on the nature of the processing or otherwise have a substantial impact on you, we will notify you when you next visit the Site, or by another method of communication where appropriate.
11. Contact & Comments
If you have any questions or comments regarding this privacy notice, please contact us by post at the address below or alternatively by email at firstname.lastname@example.org.
Any queries or requests regarding Member Data should be submitted to the Scheme trustee(s), who are the controllers in respect of this data.
Willis Towers Watson
Willis Human Capital & Benefits Ireland Limited
Willis Towers Watson House
Elm Park, Merrion Road
Dublin 4, D04 P231, Ireland