Personal Data – what is it?
Personal data means data which relates to a living person who may be identified directly or indirectly from that data. The processing of Personal Data is governed by the General Data Protection Regulation 2016/679 (“GDPR”). The trustees of the Scheme (“the Trustees”) are the data controllers. This means that the Trustees determine how your data is processed. Invesco Limited (“Invesco”), as registered administrator of the Scheme, is the data processor and acts on the instructions of the Trustees.
What categories of Personal Data are processed?
Invesco will process the following categories of personal data:
  • The personal data disclosed to us in the Application Form and any other documentation you are requested to provide to us from time to time in order for the Trustees to provide you with benefits under the Scheme. This personal data includes but is not limited to name, date of birth, gender, nationality, address, contact details, telephone number, email address, employer name, employee number, date of joining service, dates of absence, employment category, job title, employee benefit details, underwriting status, date of leaving service, PPSN, salary and remuneration, details of current and historic pension arrangements, pension contributions, insurance cover/underwriting details, health information, marital status, beneficiary details, bank details, passport number, driving licence, utility bills, details of power of attorney.
  • The personal data disclosed to us by Insurance Companies or your Employer or other relevant parties as part of the provision of benefits to you.
  • From time to time sensitive or “special categories” of personal data may be processed i.e. data relating to your physical or mental health e.g. in circumstances where you retire early on grounds of disability or ill health or for the purpose of obtaining insurance cover.
Purposes for which your Personal Data shall be processed
We process your data for the following purposes:
  • to provide registered administration services to the trustees in relation to your membership of the Scheme
  • to communicate with a product provider such as an Insurance Company;
  • to communicate with you by post, telephone, email or SMS, for the above purposes, (unless you instruct us not to do so in writing);
  • to initiate a product application if requested by you.
Legal basis for processing your Personal Data
The above purposes are necessary for the Trustees to comply with their obligations as trustee under the Pensions Act 1990 (as amended) and to comply with other legal obligations such as reporting to and liaising with the Revenue Commissioners for tax purposes or in response to a request or when dealing with the Pensions Authority or the Financial Services and Pensions Ombudsman in the event of an enquiry or complaint and to comply with Data Protection Acts 1988 to 2003 (as amended) or any other legislation or regulations implementing Directive 95/46/EC, the General Data Protection Regulation (GDPR) and any consequential national data protection legislation and including any guidelines, codes of practice or similar circulars issued by the Office of the Data Protection Commissioner, in each case as may be replaced, re-enacted, consolidated, extended, revised or amended from time to time.
We may also process your personal data for the purpose of our legitimate interests or those of a third party such as:
  • keeping you up to date with information about other products and services we offer, except where your consent is required by law in order to communicate with you;
  • any analytics or data sharing with other service providers which are not for the purpose of managing the Scheme or performing the service, for example, EuroStat returns must be made to the Pensions Authority on an annual basis and member statistics are used for this purpose. The output of such analytics will not identify particular clients or individuals.
  • Sensitive or “special categories” of personal data when you retire early on grounds of disability or ill health or for the purpose of obtaining insurance cover shall be processed on one or more of the following grounds:
  • With your explicit consent;
  • Where necessary to protect your vital interests where you are physically or legally incapable of giving consent;
  • where necessary for the establishment, exercise or defence of a legal claim by us;
  • where necessary for the purpose of carrying out our obligations and exercising our rights in the field of employment and social security and social protection law.
Security of processing
Invesco implements appropriate technical and organisational measures to protect the Data from unlawful or unauthorised processing and accidental loss, destruction or damage having due regard for the nature of the Personal Data concerned, the level of access to it, the nature, scope, context and purposes of the Processing provided that such measures ensure a level of security appropriate to the risks to the rights and freedoms of Data Subjects that might result from unauthorised or unlawful processing or accidental loss, destruction or damage to the Data.
Data Retention
Your personal data shall be processed and retained for the duration of your membership of the Scheme for such time as the Scheme is administered by Invesco, or for the duration of your Employer's relationship with Invesco plus an additional 7 years.
Sharing of your Personal Data
Your personal data will be treated as strictly confidential but may be disclosed to the Pensions Authority, Revenue Commissioners, the Financial Services & Pensions Ombudsman auditors, professional advisors, insurance companies and other service providers in connection with the administration of the Scheme.
Your PPS number is your Personal Public Service Number. It is a unique identifier for use in transactions with public bodies such as the Revenue Commissioners and the Pensions Authority and is used by Invesco for this purpose.
Transfers outside the EEA
The vast majority of your personal data is stored securely and backed up within the European Economic Area (“EEA”), however in some instances your data may be transferred to, processed and stored at, a destination outside the EEA subject to the provisions of GDPR being complied with by that processor. Details of the provisions applicable to such processors are available from the Head of Risk and Compliance.
Your Rights
You have the right to raise objections in relation to the processing of your personal data, which may include a right to restrict such processing in certain instances. You also have a right to request a copy of your personal data and, in limited circumstances, to request its rectification or erasure. Any such queries, objections or requests should be directed to the Head of Risk and Compliance and will be processed in accordance with applicable data protection legislation. If you are not satisfied with how your query or complaint has been resolved, you have the right to raise the matter with the Office of the Data Protection Commissioner.
Contact Us
If you have any queries please contact the Head of Risk and Compliance, Invesco Limited, 2 Sandyford Business Centre, Burtonhall Road, Sandyford, Dublin 18. Email: dataprotection@invesco.ie