L'Oreal (UK) Limited DC Pension Scheme Trustees Privacy Policy

The Trustees of the L’Oréal UK DC Pension Plan of 255 Hammersmith Road, London, W6 8AZ (the Trustees) are the Data Controller of personal information collected by or provided to them about members and their spouses, partners and/or any dependants in connection with and for the purpose of administering the L’Oréal UK DC Pension Plan (the Scheme).

We have appointed Ensors Accountants LLP as our Auditor. Our Auditor will process personal information on our behalf as our Data Processor; however, when processing personal data in accordance with its statutory or professional obligations, our Auditor will also be acting as a joint Data Controller. The Auditor’s privacy policy is accessible at https://www.ensors.co.uk/default/privacy.aspx.

What information do we collect from or about you?

We, the Trustees, will collect and process the following data about you to administer the Scheme and your membership of it:

•                     Information you give us.

This is information about you that you give us by filling in forms, joining the scheme, through our online portal or by corresponding with us by phone, e-mail or otherwise. The information may include your name, address, telephone numbers (fixed line and mobile), email addresses, age, date of birth, gender, employment details (including dates of employment, full or part time employment status, job band, salary, compensation, employee claims, bonuses and benefits), financial information and bank account details, HMRC and tax details, National Insurance Number, details relating to health, lifestyle and social circumstances, education, details of your family, dependents and beneficiaries and any other information that is required to administer your pension.

•                     Information we collect about you.

For each of your visits to our website or online portal we may automatically collect technical information (including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, cookies, operating system and platform) and information about your visit (including the full Uniform Resource Locators (URL).

If you call our contact centre, we may record any phone number used, as well as any phone calls for training and monitoring purposes. 

•                     Information we receive from other sources.

This is information we receive about you from any third parties.  In particular, we may receive personal information about you from L’Oréal (UK) Limited (L’Oréal), your current, previous or prospective employer (if not L’Oréal) or from anyone entitled to benefit under your membership of the Scheme.  We may also during the course of your membership of the Scheme collect information from other sources such as your next of kin (if you are medically unable to provide information to us directly) and, with your consent, registered medical practitioners.

Some of the personal information that we collect may be sensitive information, for example information relating to your physical or mental health.

How will we use this information?

We will use this information to administer the Scheme and your membership of it, including:

•                     for the administration and effective management of the Scheme (as a whole and your membership of it), by us and any third party to whom we have delegated obligations arising in connection with your pension;

•                     to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information and services that you request from us;

•                     to communicate with you by mail, telephone, email, text (SMS) message or other electronic means (including to notify you about any changes to our services);

•                     to manage our relationship with you and to update, consolidate and improve the accuracy of our records;

•                     for analysis purposes by us and, to the extent necessary, any other organisation required (such as our external advisors, including legal advisers, and our insurers);

•                     to prevent and detect crime, carry out regulatory checks and meet regulatory requirements and/or legal obligations;

•                     where you have provided the appropriate permissions, to market and advertise to you products in which you may be interested (although you may notify us at any time to cease use of your personal data for these purposes);

•                     to develop and improve our services to scheme members and beneficiaries and protect our interests; and/or

•                     to comply with our auditing and/or reporting, and any legal and regulatory, requirements.

 

Who may we give your information to?

We may disclose your personal information (and that of your spouse, partner and/or any dependants) to:

•                     the Scheme Administrator. We have appointed Buck Consultants (Administration & Investment) Limited (trading as Conduent) of 160 Queen Victoria Street, London, EC4V 4AN to administer the Scheme to act on our behalf as Scheme Administrator.  The Scheme Administrator will process your personal information on our behalf as our Data Processor;

•                     We have appointed Ensors Accountants LLP as our Auditor. Our Auditor will process personal information on our behalf as our Data Processor; however, when processing personal data in accordance with its statutory or professional obligations, our Auditor will also be acting as a joint Data Controller. The Auditor’s privacy policy is accessible at https://www.ensors.co.uk/default/privacy.aspx;

•                     the provider of our online portal. We have appointed Friends Life and Pensions Limited of Pixham End, Dorking, Surrey RH4 1QA to provide an online portal on our behalf as Portal Provider. The Portal Provider will process personal information on our behalf as our Data Processor. The Portal Provider may also disclose your personal information to third parties who process the information on behalf of the Portal Provider. Such third parties may be outside the EEA, in which case any such transfer will only be made in accordance with the requirements of the Data Protection Act 1998. The Portal Provider’s privacy policy is accessible at www.friendsprivacy.co.uk;

•                     claimants, beneficiaries, assignees and payees;

•                     pension schemes with which the person whose personal information we are processing has an association;

•                     professional advisers;

•                     financial organisations and advisers;

•                     central government;

•                     service providers;

•                     ombudsmen and regulatory authorities;

•                     family, associates or representatives of the person whose personal data we are processing;

•                     current, past or prospective employers;

•                     tracing agencies;

•                     any professional financial adviser(s) that you have appointed in respect of your financial arrangements (including your pension); and

•                     any third party who requires the information in connection with administering your pension (including tracing companies, external advisers (such as lawyers, consultants, actuaries, accountants), insurance companies, regulators and ombudsmen, research and analytics providers).

 

Any data held by L’Oréal, us and any third party will be treated as confidential. We will not sell your information to any third parties nor will any third party to whom we disclose your information.

You consent to us obtaining any pensions or related details, including the information detailed above, which we require for the administration of your benefits.

Some data, for example data in relation to your health or personal life, is regarded as ‘sensitive personal data’, and cannot be used without your specific consent at the time. Therefore, there may be specific situations in which we would require your explicit consent to an application for ill-health retirement will require your consent to use the relevant data when assessing your application.

You consent to us providing your information to the third parties listed above and to any regulatory authorities or other third parties as may be required.

International data transfers

You consent to the transfer of your personal information to a country or territory outside the

European Economic Area, whether by us or by a third party to whom we disclose your personal information in accordance with this Privacy Policy. Any such transfer will only be made in accordance with the requirements

of the Data Protection Act 1998.

Consent

By proceeding to use our services and being a member of the Scheme, you consent to the collection, use, storage, disclosure to third parties and transfer outside of the EEA of your personal information (including any sensitive personal information) by us, anyone administering the Scheme on our behalf and as described in this Privacy Policy.

Your rights: Access to and correction of information

By written request to: lorealdcpension@conduent.com

you may access details of the personal data that we hold about you.

You also have the right (without charge) to require us to correct any inaccuracies in your information and we encourage you to do so to ensure the information we hold about you is up-to-date.

To do this please email: lorealdcpension@conduent.com

Changes to our Privacy Policy

Any changes we make to our Privacy Policy in the future will be posted on this page. Please check back frequently to see any updates or changes to our Privacy Policy.

Contacts and complaints

Should you have further questions regarding the processing of your personal information, or make a complaint, please contact the Scheme Administrator at: lorealdcpension@conduent.com

If you are still employed by L’Oréal and have questions about your payments to the Scheme, your employment or benefits, please contact your HR representative.

If you are not satisfied with our response to your complaint or believe our processing of your information does not comply with data protection law, you can make a complaint to the Information Commissioner’s Office (ICO). 

You can also find general guidance on the law governing the protection and processing of personal data on the ICO website at https://ico.org.uk/

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