We are committed to safeguarding the privacy and security of all personal information we handle. This policy explains how we collect your personal information, what we do with it and your rights in respect of it.
When we say ‘we’, ‘our’, ‘us’ or ‘Independent Governance Group’ in this policy, we are referring to all or any of the following entities: Ross Trustees Services Limited (07904277), Independent Trustee Services Limited (02567540), Independent Trustee Limited (02473669), Clarity Trustees Limited (12470917), Clark Benefit Consulting Limited (08235483), Leadenhall Independent Trustees Limited (02303944) all registered in England and Wales.
2. Who we are
We are the data controller of the personal information that we process. This means that we determine (sometimes jointly with another party) how your personal information is processed and for what purposes. We are legally responsible for ensuring our systems, processes, suppliers and people comply with data protection laws in relation to the personal information that we handle.
All of our IT systems are located in the UK. We also use a number of suppliers and service providers in connection with the operation of our business who may have access to the personal information that we process, e.g. an IT supplier may see your personal information when providing us with software support, or a company which we use for a marketing campaign may process your contact information on our behalf. In all cases, your personal information is handled and protected in accordance with data protection law.
Where we transfer your personal data to third parties, in certain circumstances those third parties may also be data controllers (see section 4).
3. Whose personal information do we process?
We collect and process the personal information of business contacts who are not our clients, such as those who use our website and online services, attend our events, and subscribe to our newsletters, email services and other promotional services.
We collect and process personal information obtained or created in relation to the services we provide, including the personal information of:
- our clients, our client contacts, their people and third parties engaged by our clients
- other third parties connected to the matters on which we are working for our clients (for example services providers engaged on the pension schemes to which we are appointed)
- professional advisers, experts and consultants involved in the work that we carry out for our clients or engaged by us
We collect and process the personal information of those who apply for a job or work placement with us.
We collect and process the personal information of our staff.
We collect and process the personal information of contractors, suppliers and other third parties connected to the operation of our business.
4. Information we may collect from you
We may collect, keep a record of and process the following personal information about you:
4.1 ID & Contact Details
In almost all cases we will collect and use information which allows us to identify and contact you such as title, name, the company you work for, your job title or position, your address, email address, phone number, and marketing preferences.
This information is usually collected directly from you either by email, in person, by phone or by completing an enquiry form on our website. It can also be collected through a person acting on your behalf such as a business colleague.
As well as using this data to enable us to contact you about our work, mutual clients, opportunities and your role with is; we also use your contact details to promote our services and to contact you with communications about industry news, newsletters and events.
4.2 IT information
Where you use our website or any other software or platform which we employ, we will very often collect technical information, e.g. IP address, details of visits made to our online services such as the volume of traffic, online registration details and login credentials. This is statistical data about our users’ browsing actions and patterns, and does not identify any individual.
We will also collect details of your visits to our website including, but not limited to, traffic data, location data, weblogs and other communication data and the resources that you access.
We use Google Analytics to learn about our website visitors, and possibly target future marketing material. All data is anonymised. You can opt-out of Google Analytics tracking by installing the Google Analytics opt-out browser add-on.
This information is collected automatically by our website or other online platform or software. We collect this information to improve your experience of our website, newsletters and other services, e.g. by monitoring and recording information relating to your browsing behaviour to make personalised content available to you more efficient and relevant.
4.3 Special category personal information
Occasionally we will collect sensitive personal information, usually only in relation to our staff, such as diversity, health, religious beliefs, ethnicity or other special category personal information. We will also collect next-of-kin and dependant’s contact details.
We may also collect information about criminal convictions in relation to our staff or potential new recruits and other pre-employment vetting information such as employment references or ‘right to work’ status. This information will almost always be provided directly by you or, in the case of recruits, through your appointed agency or a vetting agency employed by us.
We collect this information to facilitate our internal business operations, such as internal record keeping, procurement and accounting practices.
We may also collect CCTV footage or images of persons visiting our offices. This is used only for security purposes.
5. How do we process your personal information?
We will only process your personal information where we are permitted to do so by law, meaning when we have one or more legal basis to do so. Section 4 explains how we process your personal information depending on the context of how personal information typically comes into our care, and include further information about the legal basis or bases that we rely on in those circumstances.
In certain circumstances, we rely on the legal basis known as ‘legitimate interests’ to process your personal information. This is where the processing of your personal information is necessary to pursue our legitimate interests in a way which is reasonably expected as part of running our business, but which is not detrimental to you and would have minimal impact on your privacy. We undertake an assessment of any potential impact on your privacy before we process your personal information for our legitimate interests.
If you would like more details about the specific legal basis we are relying on to process your personal information, please email us at firstname.lastname@example.org.
6. How we store and share your personal information
Your personal information will be stored in our information systems and third party software applications and services which have been procured to support the management of personal information held by us. Our IT systems are located in the UK and controlled by us.
In certain circumstances we will share your personal information with:
- service providers who support the operation of our business
- law enforcement, judicial, governmental and regulatory agencies, or professional bodies or similar where we are compelled to do so by law, regulation or professional obligations
- other third parties in limited circumstances, e.g. where we run a joint seminar with a third party that you wish to attend
- other third parties connected to, involved in or engaged by us to support our work for our client, e.g. professional advisers
- other third parties in appropriate circumstances, e.g. to our clients during the course of our work with them or other external contractors and professional advisers from time to time which may include parties involved in restructuring or business changes
Some of these recipients may be acting as data controllers. In all cases, the personal information of yours that we share will be limited to the minimum required for the relevant purpose and subject to appropriate protections.
7. Security and retention of information
We will retain your personal information for as long as is permitted in light of the purposes for which it was collected. Where we no longer require your information we will retain it for a period of time which reasonably allows us to comply with our legal and regulatory obligations or if retention is advisable in light of our legal position. Aggregated or anonymised data may be retained for longer.
8. Your rights
You have the right:
- to be informed about the collection and use of your personal information;
- to ask whether we process your personal information and request a copy of it if so;
- to object to decisions that we may make based solely on the automated processing of your personal information;
- in certain circumstances, to object to processing of your personal information where we do so for the purposes of our legitimate interests;
- to request that any inaccurate or incomplete personal information of yours in our care is rectified or competed;
- in certain circumstances, to restrict our processing of your personal information;
- in certain circumstances, to receive your personal information or have your personal information transmitted to another organisation in a structured, commonly used and machine readable format;
- in certain circumstances, to request that we delete your personal information; and
- to object to our processing of your personal information for direct marketing purposes.
Not all of these rights are absolute, which means that they may only apply in certain situations. To exercise your rights, please email us at email@example.com. You may also write to us at Westgate House, 9 Holborn, London, EC1N 2LL.
You may change your marketing preferences or let us know that you no longer wish to receive any marketing communications from us by contacting us by email on firstname.lastname@example.org. You may also write to us on the above address.
9. How to make a complaint
Please direct any complaint relating to how we have processed your personal information to email@example.com. You may also write to us at 4th Floor Cannon Place, 78 Cannon Street, London EC4N 6HL. We hope that we can resolve any query or concern you raise about our processing of your personal information.
If you believe that we have not been able to assist with your complaint or concern, you have the right to make a complaint to the Information Commissioner’s Officer, at www.ico.org.uk/concerns/.
10. Links to other websites
We sometimes provide you with links to other websites, but these websites are not under our control. We are not liable to you for any issues arising in connection with their use of your information, the website content or the services offered to you by those websites.
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If you have any questions about privacy, please contact us.