Version Date: 1 October 2024
We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share your personal data. It also explains your rights in relation to your personal data and how to contact us or supervisory authorities if you have a complaint.
This privacy policy does not apply to any third party websites that may have links to our own website.
Who are we and what do we do?
Haines Global Pensions Limited provides professional consulting services in pensions and employee benefits to organisations.
We collect, use and are responsible for certain personal data about you. When we do so we are subject to the UK General Data Protection Regulation (UK GDPR). We are also subject to the EU General Data Protection Regulation (EU GDPR) in relation to services we offer to organisations and our wider operations in the European Economic Area (EEA).
Key terms
It would be helpful to start by explaining some key terms used in this policy:
| We, us, our | Haines Global Pensions Limited, a private limited company registered in England & Wales (company registration 15887273) and trading as Haines Global Pensions. |
| Personal data | Any information relating to an identified or identifiable individual |
| Special category personal data | Personal data that needs more protection because it is sensitive and/or private to the data subject (see section on ‘Processing of special category personal data’) |
| Data subject | The individual who the personal data relates to |
Personal data we collect about you
The personal data we collect about you depends on the particular products and services we provide to you and your organisation. We may collect and use the following personal data about you:
- your name and contact information, including email address and telephone number and company details
- your address, for delivery purposes
- information to check and verify your identity, e.g. your date of birth
- your gender, if you choose to give this to us
- location data, if you choose to give this to us
- your job title, role and responsibilities, and career history
- your personal or professional interests
- your contact history, purchase history and saved items
- information from accounts you link to us, e.g. LinkedIn
- information to enable us to undertake credit or other financial checks on you or organisation
- your billing information, transaction and payment card information to enable us to be paid by you or your organisation
- information about how you use our website, IT, communication and other systems
- your responses to marketing invites, surveys and promotions
We collect and use this personal data for the purposes described in the section ‘How and why we use your personal data’ below. If you do not provide personal data we ask for, it may delay or prevent us from providing products and services to you or your organisation.
How your personal data is collected
We collect most of the above information from you. However, we may also collect information:
- from publicly accessible sources, e.g. Companies House or HM Land Registry
- from company websites and social media platforms e.g. LinkedIn
- directly from a third party, e.g. credit reference agencies, marketing databases;
- from a third party with your consent, e.g. your employer, your bank or building society, another financial institution or advisor;
- via our website—we use cookies and similar technologies on our website (for more information on cookies, please see our cookie policy)
- via our information technology (IT) systems eg through automated monitoring of our websites and other technical systems, such as our computer networks and connections, CCTV and access control systems, communications systems, email and instant messaging systems
How and why we use personal data
Under data protection law, we can only use your personal data if we have a proper reason, eg:
- you have given consent—where we need your consent, we will ask for it separately of this privacy policy and you can withdraw consent at any time;
- to comply with our legal and regulatory obligations;
- to fulfil our contract with you or take steps at your request before entering into a contract; or
- for our legitimate interests or those of a third party.
A legitimate interest is when we have a business or commercial reason to use your personal data, as long as this is not overridden by your own rights and interests. You have the right to object to processing based on legitimate interests. We must then stop the processing unless we can demonstrate compelling legitimate grounds which override your interests, rights and freedoms or the processing is required to establish, exercise or defend legal claims.
The table below explains what we use your personal data for and why.
| What we use your personal data for | Our reasons |
|---|---|
| Providing products and services to you | To fulfil our contract with you or to take steps at your request before entering into a contract |
| Preventing and detecting fraud against you or us | For our and/or your legitimate interests, ie to minimise fraud that could be damaging for you and/or us |
|
Conducting checks to identify our customers and verify their identity Screening for financial and other sanctions or embargoes Other activities necessary to comply with legal and regulatory obligations that apply to our business, eg under health and safety law |
Depending on the circumstances: —to comply with our legal and regulatory obligations —for our legitimate interests |
| To enforce legal rights or defend or take legal proceedings |
Depending on the circumstances: —to comply with our legal and regulatory obligations —for our legitimate interests, ie to protect our business, interests and rights |
| Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies |
Depending on the circumstances: —to comply with our legal and regulatory obligations —for our legitimate interests |
| Ensuring internal business policies are complied with, eg policies covering security and internet use | For our legitimate interests, ie to make sure we are following our own internal procedures so we can deliver the best service to you |
| Operational reasons, such as improving efficiency, training and quality control | For our legitimate interests, ie to be as efficient as we can so we can deliver the best service to you at the best price |
| Ensuring the confidentiality of commercially sensitive information |
Depending on the circumstances: —for our legitimate interests, ie to protect trade secrets and other commercially valuable information —to comply with our legal and regulatory obligations |
| Statistical analysis to help us manage our business, e.g. in relation to our financial performance, customer base, services range or other efficiency measures | For our legitimate interests, i.e. to be as efficient as we can so we can deliver the best service to you at the best price |
| Protecting the security of systems and data used to provide services, prevent unauthorised access and changes to our systems |
Depending on the circumstances: —for our legitimate interests, i.e. to prevent and detect criminal activity that could be damaging for you and/or us —to comply with our legal and regulatory obligations |
| Updating and enhancing customer records |
Depending on the circumstances: —to fulfil our contract with you or to take steps at your request before entering into a contract —to comply with our legal and regulatory obligations —for our legitimate interests, eg making sure we can keep in touch with our customers about existing and new services |
| Statutory returns | To comply with our legal and regulatory obligations |
| Ensuring safe working practices, staff administration and assessments |
Depending on the circumstances: —to comply with our legal and regulatory obligations —for our legitimate interests, eg to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you |
| Marketing our services and those of selected third parties to existing and former customers and third parties |
Depending on the circumstances: —for our legitimate interests, ie to promote our business —consent (which we will ask for separately) |
| Credit reference checks via external credit reference agencies | For our legitimate interests, ie to ensure our customers are likely to be able to pay for our services |
| External audits and quality checks, e.g. for external accreditation and the audit of our accounts to the extent not covered by ‘activities necessary to comply with legal and regulatory obligations’ above |
Depending on the circumstances: —for our legitimate interests, i.e. to maintain our accreditations so we can demonstrate we operate at the highest standards —to comply with our legal and regulatory obligations |
|
To share your personal data with members of our group and third parties that will or may take control or ownership of some or all of our business (and professional advisors acting on our or their behalf) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale or in the event of our insolvency In such cases information will be anonymised where possible and only shared where necessary |
Depending on the circumstances: —to comply with our legal and regulatory obligations —in other cases, for our legitimate interests, i.e. to protect, realise or grow the value in our business and assets |
| To share your personal data with sub-contractors and associated third parties in order to provide contractual services to you or your organisation |
Depending on the circumstances: —to fulfil our contract with you or to take steps at your request before entering into a contract —to comply with our legal and regulatory obligations —consent (which we will ask for separately) |
Processing of special category personal data
Special category personal data includes
- Personal data revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership
- Genetic data
- Biometric data (where used for identification purposes)
- Data concerning health or sexual orientation
Where we process special category personal data, we will also ensure we are permitted to do so under data protection laws e.g.:
- we have your explicit consent;
- the processing is necessary to protect your (or someone else’s) vital interests where you are physically or legally incapable of giving consent;
- the processing is necessary to establish, exercise or defend legal claims; or
- the processing is necessary for reasons of substantial public interest.
Marketing
We may use your personal data to send you updates (eg by email, text message, telephone, post or social media channels) about our services, including exclusive offers, promotions or new services.
We have a legitimate interest in using your personal data for marketing purposes (see above ‘How and why we use your personal data’). This means we do not usually need your consent to send you marketing information. Where this is not the case, we will always ask for your consent.
In all cases, you have the right to opt out of receiving marketing communications at any time by:
- contacting us (see ‘How to contact us’ below)
- using ‘unsubscribe’ links in generic marketing emails
We may ask you to confirm or update your marketing preferences if you ask us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.
We will always treat your personal data with the utmost respect and never sell it to or share it with other organisations or marketing purposes.
Who we share your personal data with
We routinely share personal data with:
- companies within the Haines Global Pensions group;
- third parties we use to help deliver our services to you, e.g. providers of our finance systems, IT service providers including cloud service providers such as data storage platforms, shared service centres and financial institutions in connection with invoicing and payments;
- companies providing services for money laundering checks and other crime prevention purposes and companies providing similar services, including financial institutions and credit reference agencies;
- other third parties we use to help promote our business, e.g. marketing agencies;
- third parties approved by you, eg social media sites you choose to link your account to or third party payment providers;
- our banks in order to make and receive payments;
- companies and individuals helping us to provide services in accordance with contracts agreed with you or your organisation
We only allow those organisations to handle your personal data if we are satisfied, they take appropriate measures to protect your personal data. We ensure all outsourcing providers operate under service agreements that are consistent with our legal obligations.
We or the third parties mentioned above may occasionally also share personal data with:
- our and their external auditors, e.g. in relation to the audit of our or their accounts, in which case the recipient of the information will be bound by confidentiality obligations
- our and their professional advisors (such as lawyers and other advisors), in which case the recipient of the information will be bound by confidentiality obligations
- law enforcement agencies, courts, tribunals and regulatory bodies to comply with our legal and regulatory obligations
- other parties that have or may acquire control or ownership of our business (and our or their professional advisers) in connection with a significant corporate transaction or restructuring, including a merger, acquisition or asset sale or in the event of our insolvency—usually, information will be anonymised but this may not always be possible and the recipient of any of your personal data will be bound by confidentiality obligations
If you would like more information about who we share our data with and why, please contact us (see ‘How to contact us’ below).
Where your personal data is held
Personal data may be held at our premises and those of our group companies, third party agencies, service providers, representatives and agents as described above (see ‘Who we share your personal data with’).
Some of these third parties may be based outside the UK. For more information, including on how we safeguard your personal data when this occurs, see below: ‘Transferring your personal data abroad’.
How long your personal data will be kept
We will not keep your personal data for longer than we need it for the purpose for which it was collected or as required by law.
If you no longer have an account with us or we are no longer dealing with you or providing goods or services to you, we will usually delete or anonymise your account data after seven years.
Following the end of the of the relevant retention period, we will delete or anonymise your personal data.
Transferring your personal data abroad
Depending on the work we are doing and the global third parties we work with, it may sometimes be necessary for us to transfer your personal data to countries outside the UK and EEA. This may include countries which do not provide the same level of protection of personal data as the UK or EEA
We will transfer your personal data outside the UK and EEA only where:
- the UK government or European Commission has decided the recipient country ensures an adequate level of protection of personal data (known as an adequacy decision); or
- there are appropriate safeguards in place (eg standard contractual data protection clauses published or approved by the relevant data protection regulator), together with enforceable rights and effective legal remedies for you; or
- a specific exception applies under data protection law.
You can contact us (see ‘How to contact us’ below) if you would like a list of countries benefiting from a UK or European adequacy decision or for any other information about protection of personal data when it is transferred abroad.
Your rights
You have the following rights, which you can exercise free of charge:
| Access | The right to be provided with a copy of your personal data |
| Rectification | The right to require us to correct any mistakes in your personal data |
| Erasure (also known as the right to be forgotten) | The right to require us to delete your personal data—in certain situations |
| Restriction of processing | The right to require us to restrict processing of your personal data—in certain situations, e.g. if you contest the accuracy of the data |
| Data portability | The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations |
| To object |
The right to object: —at any time to your personal data being processed for direct marketing (including profiling); —in certain other situations to our continued processing of your personal data, e.g. processing carried out for our legitimate interests unless we demonstrate compelling legitimate grounds for the processing which override your interests or for establishing, exercising or defending legal claims |
| Not to be subject to automated individual decision making | The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you |
| The right to withdraw consent |
If you have provided us with a consent to use your personal data you have a right to withdraw that consent at any time. Withdrawing consent will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn |
If you would like to exercise any of those rights, please:
- email, call or write to us—see below: ‘How to contact us’; and
- provide enough information to identify yourself g. your full name, address and customer or matter reference number) and any additional identity information we may reasonably request from you;
- let us know what right you want to exercise and the information to which your request relates.
Keeping your personal data secure
We have implemented appropriate technical and organisational measures to keep your personal data confidential and secure from unauthorised access, use and disclosure. We limit access to your personal data to those who have a genuine business need to access it. Those processing your personal data will do so only in an authorised manner and are subject to a duty of confidentiality.
We use industry-standard password-protected Apple computer and phone equipment, Microsoft 365 Business applications (including Outlook for emails) and use Apple and Microsoft’s iCloud solutions for storing data and documents. We use two-factor authentication including Microsoft Authenticator to access Outlook email and other online accounts.
We require our business partners, suppliers and other third parties to implement appropriate security measures to protect personal data from unauthorised access, use and disclosure.
We also have procedures to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are required to do so.
How to complain
Please contact us if you have any queries or concerns about our use of your personal data (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.
You may also have the right to lodge a complaint with the Information Commissioner (the UK data protection regulator) and/or the relevant supervisory authority in your jurisdiction. Changes to this privacy policy
This privacy policy was published on 1 October 2024 and last updated on that date.
We may change this privacy policy from time to time. When we do, we will publish the updated version on our website and ask for your consent to the changes if legally required.
Updating your personal data
We take reasonable steps to ensure your personal data remains accurate and up to date. To help us with this, please let us know if any of the personal data you have provided to us has changed, eg your surname or address—see below ‘How to contact us’.
How to contact us
Individuals in the UK
You can contact us by post, email or telephone if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint.
Our contact details are shown below:
Haines Global Pensions LimitedC/O Xeinadin First Floor
Secure House
Lulworth Close
Chandler’s Ford
SO53 3TL
United Kingdom
Email: sarah.haines@hgpensions.com
Telephone: 02380 251 844 / 07743 346 526
Individuals in the EEA
Individuals within the EEA can contact us direct using the above contact details (see ‘Individuals in the UK’ sub-section).
We do not have a separate data protection representative in the EEA as we consider our data processing activities for individuals in the EEA to be occasional, of low risk to the data protection rights of these individuals and does not involve the large-scale use of special category personal data.
Do you need extra help?
If you would like this policy in another format (for example audio, large print, braille) please contact us (see ‘How to contact us’ above).