This Privacy Policy is supplemental to the Hartlink terms and conditions, and which, by continuing to access the Hartlink website you are deemed to accept and agree to be bound by.
We are committed to ensuring that your privacy is protected. This Privacy Notice explains how we use information about you:
Depending on the services we are providing to your employer or pension scheme trustee you may be able to limit the use of that information, and where that is possible this is explained below.
This notice also explains the procedures that we have in place to safeguard your privacy.
Capita Employee Benefits Limited and Capita Employee Benefits (Consulting) Limited (trading as Capita Employee Solutions) (“we”). We are registered in England and Wales under company numbers 02260524 and 01860772 respectively and have our registered office situated at 65 Gresham Street, London, EC2V 7NQ.
We are authorised and regulated by the Financial Conduct Authority under registration numbers 142484 and 115051 respectively.
We provide pension administration services to your employer and / or pension scheme trustee. As part of these services they provide us with information about you to enable us to administer your pension scheme and to allow you to apply for any additional optional benefits your employer or pension scheme trustees ask us to make available to you.
Your employer and / or the pension scheme trustee are the ‘Controller’ of this information and Capita is a ‘Processor’
This Privacy Notice is therefore supplemental to the Privacy Notice provided by your employer and / or pension scheme trustee and only relates to our administration services.
When you enrol and visit our Site you should check these details are accurate and keep them updated.
We may ask you for further details in the following circumstances:
Depending on the service you may have the option to receive information by SMS e.g. pension investment alerts. Where you choose this service you will have the option of providing your mobile phone number.
We may also ask you for details of your spouse, partner or other immediate family member if they are to be included as the nominated beneficiary of your pension. Where you submit such details, you do so on behalf of the relevant family member and you acknowledge and accept that it is your responsibility for letting them know (i) that you have done so; (ii) what details you have submitted; and (iii) the purpose of submitting the details.
It is your responsibility to keep your personal details and those of any relevant family member updated. If there is any change in your personal details, please let us know the correct details by updating them on our Site (where possible) or inform your employer and/or scheme administrator of the changes.
We gather this information to allow us to process your enrolment, provide you with updated details of your pension scheme, assist you in applying for further benefits or products and processing those applications (where applicable) and generally ensure the smooth running of your pension account.
The information is also used by us to communicate with you on any matter relating to your pension scheme and the provision of the services in general.
Your employer and / or pension trustee may have provided your e-mail address details to Capita for the purpose of providing our services. E-mail messages sent over the internet cannot be guaranteed to be completely secure as they may be subject to possible interception or loss. If you do not want Capita to contact you on your e-mail address, please contact your employer and / or pension scheme administrator.
We may also wish to provide you with information about special features of our Site or other services. This may be by email or by SMS text messaging if you have registered for this service. If you do not want to receive this information, please contact your employer and / or pension scheme administrator.
We never use or share any personally identifiable information provided to us online in ways unrelated to the ones described on our Site, this Privacy Notice or our Cookie Policy.
The controller will have a legal basis for providing us with your information to process and they should provide you with details of this in their privacy notice to you.
As a processor your information is processed by us on the basis of instructions from and a contract with the controller e.g. your employer / pension scheme trustee to provide pension administration services.
Where we provide pension administration services and you apply for any additional products or services offered through our Site, we will pass your personal details as necessary to the provider of those products and services to the extent necessary for you to receive those products or services. Thereafter, the provider may correspond with you directly in order to provide those services.
Once a provider has received your personal information they will usually have a direct relationship with you and use your personal data in accordance with their terms and conditions and privacy policy.
Examples of the types of providers used are:
To provide our services to your employer and / or pension scheme trustee we sometimes use third parties such as IT systems and software providers or print and document management companies.
In addition, your details may be disclosed to your employer / pension scheme in order for Capita to provide the services to you.
In the event that Capita is sold or integrated with another business, your details may be disclosed to our advisers and any prospective purchasers' advisers and will be passed on to the new owners of the business.
Your personal data will not be transferred by us outside of the European Economic Area (EEA) unless specifically agreed with the controller. Where that is the case you will be separately notified.
Our standard policy is to hold your data for a maximum of 7 years after the end our agreement to provide services to your employer / pension scheme trustee after which it will be securely destroyed.
If you do not wish us to process your personal data in order to use our Site, please use the contact details on the Site homepage. However, in certain circumstances the controller e.g. your employer maybe under a legal obligation to process your personal data e.g. for automatic enrolment into a pension scheme and to manage opt-outs in which case we may have to continue to process your personal data.
Where agreed with your employer and / or pension scheme trustee we may anonymise your personal information and use it for data analytical purposes.
We may also use aggregate information and statistics for the purposes of monitoring website usage and to help us develop our Site and our services, and may provide such aggregate information to third parties. These statistics will not include information that can be used to identify any individual.
From time to time we may provide your information that we collect and store during normal use of our Site to our customer service agencies for research and analysis purposes so that we can monitor and improve the services we provide. Such use does not result in any personally identifiable data, other than contact details, being collected, stored or transferred to such agencies. We, or our agents and sub-contractors, may contact you by post, e-mail or telephone to ask you for your feedback and comments on our services.
One way in which we gather this information is by using cookies. Please see our Cookie Policy for more information.
Under Data Protection regulations you have a number of rights. These can be exercised by contacting your employer / pension scheme trustee as the Controller of your information.
The right to be informed This includes an obligation to explain to you how your information is used. This Privacy Notice provides you with this explanation in relation to the information processed by us when providing pension scheme administration services to your employer or pension scheme trustee.
The right of access You have the right to obtain confirmation that your information is being processed and to obtain access to your information (e.g. by receiving a copy of it).
The right to rectification You have the right to have your information corrected if it is inaccurate or incomplete.
The right to erasure (also known as the “right to be forgotten”) You have the right to request the deletion or removal of your information in certain circumstances. Please note that there may be circumstances where you ask for your information to be deleted but both us and your employer / pension scheme trustee are legally entitled to retain it.
The right to restrict processing You have the right to request the processing of your information is restricted in certain circumstances. Again, there may be circumstances where you ask your employer / pension scheme trustee to restrict the processing of your information, but they are legally entitled to refuse that request.
The right to data portability You have the right to receive the information you have provided in a usable electronic format and/or request it is transmitted to a third party where this is technically feasible.
The right to complain to the Supervisory Authority You have the right to make a complaint with the Information Commissioner (www.ico.org.uk) if you think that any of your rights have been infringed.
This Cookie Policy is supplemental to the Hartlink terms and conditions, and which, by continuing to access the Hartlink website you are deemed to accept and agree to be bound by.
We are committed to ensuring that your data is protected. This Cookie Policy explains how we use the information we collect about you by our use of cookies, and the purpose for which we use them.