Data Privacy Statement and Cookie Information (March 2018)
It is important that you understand how the personal information you give to us will be used. Therefore, please read this Privacy Statement and Cookie Information before proceeding further with your visit to our website or with any business that you may wish us to transact.
This Privacy Statement sets out the obligations of ‘the Companies’ being :
- Pension Management Limited (03582282)
- PML Financial Services Limited (05342018)
- PML Trustees Limited (05726389)
In relation to:
(1) our clients, who’s personal data we use in the conduct and administration of our business with them and
(2) all visitors to this website.
Contact details are:
- The School House, St Michaels Road, Sutton Coldfield, West Midlands B73 5SY
- T: 0121 693 0690
- E: email@example.com
Our Data Protection Officer can be contacted at:
General Data Protection Regulations (GDPR)
To enable us to fulfil our contracted Services with you, we must secure, use and protect the personal information you give us. Furthermore, we must have “proper reason” for securing this personal information. Proper reasons include:
- To fulfil a contract we have with you, or
- When it is our legal duty, or
- When it is in our legitimate interest, or
- When you consent to it
What are your rights?
Your rights under GDPR include:
- The right to be informed of the collection and use of personal data.
- The right to access the personal data we hold on you
- The right to correct and update the personal data we hold on you
- The right to have your personal data erased, unless it must necessarily be retained by ourselves for legal, regulatory or compliance purposes.
- The right to restrict processing of your personal data
- The right to data portability
- The right to object to the processing of personal data to which consent was sought.
To lodge a complaint with the Information Commissioner’s Office you can:
- email them via: https://ico.org.uk/global/contact-us/email/,
- call them on 0303 123 1113,
- or write to them at the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF
We will only collect basic personal data about you, which does not include any ‘special category data’ unless agreed with you otherwise. This basic personal information may include: your name, address, email address and job title.
We may be required to collect and retain ‘special category data’.
This is defined as data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation, data relating to criminal convictions and offences.
Where this applies, all special category data provided by you is subject to your explicit consent. The data is retained exclusively within the Companies protected internal database, accessible only to appointed staff of the Company and subject to codes and passwords known only to those staff members. There is no access to the internal database of the Companies through our website.
If at any point you believe the information we process on you is incorrect you can request to see this information and have it corrected or in appropriate circumstances, deleted.
If you wish to raise a complaint on how we have handled your personal data, you can contact our Data Protection Officer, at firstname.lastname@example.org, who will investigate the matter and respond to you accordingly. If you are not satisfied with our response or believe we are not processing your personal data in accordance with the requirements of GDPR, then you are within your rights to lodge a complaint with the Information Commissioner’s Office (ICO).
Our Data Collection
We need to know basic personal data, including: your name, address, email address and job title, before we can consider contracting to work for you or your company under our standard Terms of Business. The nature of the services we provide will regularly require us to request detailed personal information and ‘sensitive personal data’ from you. The information required to enable us to provide contracted services to you may include:
- Full I.D., including Passport, Driving Licence, Birth Certificate, Marriage Certificate and documents confirming current place of residence, together with full contact details, telephone numbers and email addresses.
- Your financial position, status and history, including taxable income, pension details or entitlements, your tax code and N.I. number.
- Details of your employment or profession and full information of any ownership or control in any partnership or corporate entity with which you may be associated.
- Details of your family and other relationships.
- Details about you that is openly available in public records, such as Electoral Register, Companies House and on the Internet.
- ‘Special category data’ as defined above.
If you do not provide the information we ask for, then it is most likely that we will be unable to provide the services you have requested. We will not collect any personal data from you that we do not need in order to provide and oversee the services we have agreed to provide to you.
Use of Data
All the personal data we hold about you will be processed by our staff. No third parties will have access to your personal data unless there is a legal obligation for us to provide them with this. We have set out below the legal bases for the Companies to process your data. Our authorised marketing agency has access to the data, for the sole purpose of approved and compliant marketing activities, as instructed by the Companies, including the sending of marketing e-mails. They too are covered by the requirements of GDPR and will not use or share this data with any other party.
We will also communicate with you information about other services we can offer you and update you about our activities.
Where your information is used other than in accordance with one of these uses, we will first obtain your consent to that use. We take all reasonable steps to ensure that your personal data is processed securely.
How long do we keep data?
Typically, we keep your personal data for a minimum of 7 years, after which time it will be destroyed if it is no longer required for the lawful and compliant purpose for which it was obtained. If you consent to marketing, any information we use for this purpose will be kept with us until you notify us that you no longer wish to receive this information.
Sharing your personal data
Your personal data will only be shared with third parties including other data controllers where it is necessary for the performance of the data controllers’ tasks or where you first give us your prior consent. It is likely that we will need to share your data with:
- Any members of staff of the Companies
- Our suppliers and contractors. For example, we may ask a supplier to send out newsletters on our behalf, or to maintain our database software, or to provide us with IT and other related services
Organisations with which we may share your personal information, subject to your agreement, within the provision of our service to you, include:
- Banks or other deposit-taking institution.
- Your appointed Agent or Independent Financial Advisers.
- Insurance Companies and/or Investment Managers
- Price comparison websites, should you require us to apply for relevant financial products.
- HMRC, the Financial Conduct Authority (FCA) or other regulator.
- Any party linked with you or your business in respect of a service you may ask us to provide.
Any personal data transferred to countries or territories outside the European Union will only be placed on systems complying with measures giving equivalent protection of personal rights either through international agreements or contracts approved by the European Union.
Our Privacy Practices
The Companies use fair information practices that are designed to protect your privacy. If you have questions or you do not feel that your concerns have been addressed in our Privacy Statement, or you just want to talk with us, please feel free to contact us by email at email@example.com
We collect information that is voluntarily provided by visitors to this Site. The data that the Companies receive from visitors to this site includes: name, title, address, email address and telephone number, and any other information provided by visitors in email messages and attachments.
Typically, this data is collected in order to assist visitors to:
- receive information about our Companies and the services we offer
- read our bulletins, technical updates and related business matters
- contact us for further information
It is the policy of the Companies to limit the information collected to the bare minimum required to complete a Site visitor’s request.
It is the intention to not seek any special category data through our website, unless legally required for legal, regulatory or compliance purposes.
Use of User Data
User Data obtained by this website is used for the Companies internal business purposes and in relation to a visitor’s request. This data is not shared with others for unrelated purposes unless stated in this Privacy Statement or otherwise communicated to the visitor to the website.
The Companies’ make every practical effort to avoid excessive or irrelevant collection of data. If a visitor believes the website has collected excessive information, please contact us at firstname.lastname@example.org
Except for instances where visitors explicitly choose to receive specific PML Group marketing or other informational materials, the Companies will not use personal data collected from our website to distribute marketing or informational materials.
It is the policy of the Companies only to disclose User Data to third parties under the following circumstances:
- when explicitly requested by the visitor
- when required to deliver publications or reference materials requested by the visitor
- when required to meet any other request of a visitor
Categories of third parties that the Companies may share personally identifiable information with include National, Regional and local government entities. This Site does not collect or compile personally identifying information for the dissemination of or sale to outside parties for consumer marketing purposes, or host mailings on behalf of third parties.
A cookie is a tiny element of data that a website can send to the computer browser of a visitor, so that this computer will be recognised by the site on their return. Cookies allow our web server to recognise a computer on connection to the Site, which in turn allows the server to make downloading of pages faster than on first viewing. In addition, cookies may also be used by us to establish statistics about the use of the Site by Internet users by gathering and analysing data such as: most visited pages, time spent by users on each page, site performance, etc. By collecting and using such data our aim is to improve the quality of the Site.
The data collected by our servers and/or through cookies that may be placed on your computer will not be kept for longer than is necessary to fulfil the purposes mentioned above. In any event, such information may not be kept for longer than one year.
Navigation data about site viewers is automatically collected by our servers. If you do not wish to have this navigation data collected, we recommend that you do not use the Site. A visitor can also set their browser to block the recording of cookies on their hard drive to minimise the amount of data that may be collected about your navigating on the Site. The browser on a computer can be set to notify the user when a cookie is being recorded on their computer’s hard drive. Most browsers can also be set to keep cookies from being recorded on their computer. However, for optimal use of the Site, we recommend that visitors do not block the recording of cookies on their computer.
For more information about cookies, please see the Information Commissioner’s website at:
The cookies we use across all of our websites and what we use them for
|_utma_utmb_utmc_utmz||This website uses Google Analytics, a web analytics service provided by Google. These cookies are used to monitor the performance of our site and understand how effective our content is. We use the information to help us improve the site. The cookies collect information in an anonymous form, including the number of visits to our site, where visitors have come from to the site and the pages they visited. To opt out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout.|
|EKtGUID||This identifies the unique ID for each user to increase efficiency of the website functionality. These help to mitigate any compatibility issues e.g. to identify your browser type and improve performance.|
|EKAnalytics||This allows us to understand how users use our website. This allows us to improve the quality and content on our site for our visitors.|
|cookielegislation_uk (+languageid)||This is used to check if users have accepted or denied cookie legislation.|
|ecm-||These cookies can record information about the choices you have made e.g. mailing or language preferences.|
How to manage cookies via your browser settings
Establish the type and version of the web browser you use to access the internet.
- PC– click on ‘Help’ at the top of your browser window and select the ‘About’ option.
- Mac– click on the Apple menu and select the ‘About’ option.
Choose your preferred settings
Microsoft Internet Explorer 7.0 and 8.0
- Click on ‘Tools’ at the top of your browser window and select ‘internet options’.
- Click on the ‘Privacy’ tab.
- Move the slide to choose your preferred setting.
- Click on ‘Tools’ at the top of your browser window and select ‘Options’.
- Then select the Privacy icon in the left-hand panel.
- Click on Cookies and choose your preferred settings.
- Click on ‘Tools’ at the top of your browser window and select ‘Options’.
- Click the ‘Under the Bonnet’ tab, locate the ‘Privacy’ section, and choose the ‘Content settings’ button.
- Click the ‘Cookie settings’ tab and choose your preferred settings.
All other browsers and/or versions
Please consult your browser online help files.
Transfer of User Data outside the User Jurisdiction
The Internet is a global environment. We do not operate outside the UK and have no need to process User Data outside the UK.
Visitors to our website are not required to register to gain access. Personally identifiable information provided to us through our website is provided voluntarily by visitors. Should visitors subsequently choose to unsubscribe from mailing lists or any registrations, we will provide instructions on the appropriate website area or in communications to our visitors; or a visitor may contact us at email@example.com
Each visitor has the right of access to personal data they have submitted through this Site.
User updates of information should be handled by going back through the registration process. Enquiries about the accuracy of identifying information previously submitted, or requests to have information removed, should be directed to firstname.lastname@example.org
All members of staff of the Companies are instructed to follow a firm-wide security policy. Only authorised personnel are provided access to personally-identifiable information and these employees are required to agree to ensure confidentiality of this information.
All documents, programmes, publications, designs, products, processes, software, technology, information, and ideas (Content) provided by or described in this Site are the property of the Companies or its suppliers and are protected by U.K. and international copyright laws and other intellectual property laws, unless stated otherwise.
The Content is provided to users of this Site for informational purposes only. users may not in any other way exploit commercially all or any part of the Site or any document available through it without our prior written permission.
Users may print or save copies of any page of the Site and documents available through it (other than documents provided by third parties) for their own personal use
Pensions Management Limited, The School House, St Michaels Road, Sutton Coldfield, West Midlands B73 5SY
Tel: 0121 693 0690