- The information that we obtain from you and others and process in order to administer the Scheme(s) of which you are a member;
- The information that we collect from you when you use the www.jaguarlandroverpensions.com website (the “Site“);
- How we use the information we obtain; and
- The third parties to whom we may provide that information.
For the purposes of the Data Protection Act 1998 (“DPA“), the data controller is Jaguar Land Rover Pension Trustees Limited (the “Trustees” or “we”).
Our company details are as follows:
Jaguar Land Rover: Registered Office: Abbey Road, Whitley, Coventry, CV3 4LF
We are committed to safeguarding the privacy of our members, both in relation to the administration of the Schemes generally and the provision of appropriate benefits, and in the provision of this Site.
Please read this policy carefully. By continuing to use the Site and by submitting information to us, whether via the Site or in any other way, you consent to the use of that information as described in this policy. If you do not agree to the terms of this policy insofar as it relates to the Site, please do not use the Site.
We may revise this policy from time to time and will post any changes on this web page. You should check this page from time to time to keep up-to-date with any such changes, as the changes will apply to any data we collect after the change. Reasonable changes will also apply to data collected before the change.
Links to other sites
The Site may contain links to and from other websites, including sites operated by third parties. We have no control over the any third party sites that link to or from the Site. If you follow a link to any third party websites, then please note that they should have their own separate privacy policies. Please check those privacy policies before you use or submit any personal information to third party websites. We do not accept any liability or responsibility for any third party websites, the privacy policies applicable to them or their use of the information that they collect from you.
PERSONAL INFORMATION WE MAY COLLECT FROM YOU
In our operation of the Schemes
In order to become a member of one or more of the Schemes, and in order to enable us to manage and administer the Schemes and provide benefits under them, you have provided and will provide certain personal information about you and about your dependants. This includes, but is not limited to, your name, age, contact details and address, salary and information about your dependants. Sometimes it will include sensitive personal data within the meaning of the DPA, such as physical or mental health, for example in the case of ill-health early retirement. Where you provide information about individuals other than yourself, you need to inform them and, where necessary, obtain their consent. By submitting the information about them, you are confirming to us that you have done so.
Via the Site
In the course of using the Site, you may choose to provide certain personal information. This will generally include, but not be limited to:
- Information you provide by filling in forms on the Site;
- Records of any correspondence between you and us, if you contact us;
- Details of your visits to the Site and the resources that you access.
It is possible to view the Site without providing any personal details.
You must ensure that any personal information you provide is true, accurate and complete. It is also your responsibility to let us know about any changes to your personal information so that we can ensure our records are complete and up-to-date.
Please note that we will never ask you to confirm any personal details, log-in details or payment details by email. If you receive an email asking for any such information which appears to be from us, do not respond to it. It may be an attempt to obtain those details for fraudulent uses.
We never collect information whether via the Site or otherwise from any person that we know to be under the age of 13.
OTHER INFORMATION WE MAY COLLECT
In our operation of the Schemes
In order to manage and administer the Schemes, and provide benefits under them, it may be necessary to obtain information about you and/or your dependants from third parties, such as, for example, your employer or your doctor. We will always look to comply with the DPA and any other relevant legislation in doing this, making sure we have a valid justification under the DPA for the processing.
Via the Site
During your use of the Site, we may automatically collect certain information about your visit and the device that you have used to access the Site.
This is statistical data about our users’ browsing actions and patterns, and does not identify any individual personally. The information that we may collect includes:
- The IP address of the device used to access the Site.
- The internet domain name through which you accessed the Site (which may be, for example, the domain name of your internet service provider or your place of work).
- The length of your session on the Site.
- Details of the pages visited on the Site and resources accessed.
- The web browser used by your device to access the Site.
- Your device’s operating system.
- Details of any website that provided you with a link to the Site (for example, Google, if you found us using a search engine.)
We use the above information for system administration.
HOW WE USE YOUR INFORMATION
We use information held about you and your dependants in the following ways:
- To manage and administer the Scheme(s) of which you are a member, and to provide benefits under them.
- To deal with any queries you raise with us, and otherwise in corresponding with you about the Scheme(s), and keeping records of our dealings with you.
- To protect the Schemes, ourselves and Scheme members.
- To provide you with the Site, and the content made available through it.
- To ensure that the Site and its content are presented in the most effective manner for you and for the device you use to access it.
- To analyse how the Site is used, the effectiveness of the Site and to help us improve the Site and the content made available through it.
- For the purposes of corresponding with you in relation to any queries you raise with us in relation to the Site.
From time to time, we may also ask you whether we can use particular information that you provide to us for other purposes. Where you agree to us doing this, then we may use that information for the purposes that you have agreed.
DISCLOSURE AND SHARING OF YOUR INFORMATION
We will only share or disclose your personal information with third parties in connection with the purposes described in the “How We Use Your Information” section above in the following circumstances:
- To your employer, or, if you no longer work for Jaguar Land Rover, your former employer.
It may receive the data as a data controller or, if they are undertaking work on our behalf, as our data processor.
- To enable third parties to provide products or services to us or on our behalf.
This includes, but is not limited to, third parties we have appointed to assist us in managing and administering the Schemes, and in providing benefits under them, and in developing, hosting, maintaining and operating the Site.
Some of these companies, for example third party benefit providers like Scottish Equitable/Aegon, Legal & General, and some specialist service providers like the actuary to the Schemes, Jonathan Gainsford, and our lawyers, Squire Patton Boggs are also data controllers. This means that they have direct obligations under the DPA in relation to your personal information.
Other contractors and service providers, such as, for example, the administrators of the Schemes, JLT Benefit Solutions Limited and consultancy providers like Aon Hewitt, process personal information on our behalf as data processors. We make enquiries into the security measures that they will take to keep your information safe, and enter into written contracts with them, requiring them to process your information only on our behalf and in accordance with our instructions, and to keep your data secure.
Sometimes, your information will be processed outside the European Economic Area by staff of our service providers. As these countries may have less stringent data security requirements, this is only permitted if we agree in advance both to the extent of the processing to be undertaken and the security measures to be applied, and subject to strict contractual protections.
- With your consent.
We may share personal information with people or organisations where we have your consent to do so.
- If it is proposed to sell your employer or any part of the business of your employer
We may share personal information with potential purchasers of your employer or any part of the business of your employer, but only for use in connection with that sale (or its evaluation) and subject to appropriate confidentiality and security obligations.
- For legal reasons
We may share personal information with other people or organisations where we consider in good faith that one or more of the following circumstances apply:
(i) It is reasonably necessary to comply with any applicable law, regulation, legal process or enforceable government request;
(ii) Any applicable laws permit us to make the disclosure. For example, the DPA permits us to disclose personal information where necessary in connection with any legal proceedings or prospective legal proceedings, or for the prevention or detection of crime;
(iii) It is necessary to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention).
- For marketing purposes
We may from time to time provide information to you about products or services that may be available to you as a member of the Scheme(s). You have the right, however, to ask us not to contact you for this purpose by contacting us at the contact details set out at the end of this policy.
- Aggregated, Anonymised and Pseudonymised data
In order to take the benefit of industry-wide initiatives, for example relating to longevity modelling, locating lost pensioners etc, we may provide information to relevant third parties. Wherever aggregated or anonymised data will suffice for the purpose, we provide aggregated or anonymised information, and where that is insufficient, the information is pseudonymised to the extent compatible with obtaining meaningful results. In such cases, we seek appropriate protections from the recipients for the information provided.
We may also share information about Site usage and visitor patterns to third parties for the purposes of Site administration.
Except as set out above, we will not share your personal information with any third party without your consent.
We take the security of your personal information very seriously, and take appropriate technical and organisational measures to seek to prevent the loss, misuse or alteration of your personal information. Whenever we appoint contractors, we undertake investigations into their security measures, and build appropriate protections into our contracts with them.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will take reasonable steps to protect your information submitted to the Site or otherwise communicated to us electronically, we cannot guarantee the security of your information. We will not be liable for any loss of or interception of your information, unless this results from our failure to use reasonable steps to keep it secure.
All information you provide to us is stored on our secure servers or those of our service providers or contractors.
ACCESSING & CORRECTING INFORMATION AND YOUR OTHER RIGHTS
You have a number of legal rights under English law (and in particular the DPA) in relation to how your personal information is used, and some of these are set out below. You can obtain further information about your rights from the Information Commissioner’s Office at www.ico.org.uk.
You have the right to access the information that we hold about you. Your right of access can be exercised in accordance with the DPA, which also sets out circumstances when we must or may not provide personal information to you. Any access request will be subject to the statutory fee, towards our costs in providing you with details of the information we hold about you (currently £10). Under the DPA, we may need to verify your identity before providing your personal information to you.
You have the right to have information about you corrected. If you need to amend any of your personal details provided via the Site, you can do so [by logging into your account or] by contacting us using the details below. To change other details, contact us using the details below.
You have the right to have any information that we hold about you corrected. If you need to amend any of your personal details, you can do so by contacting us using the details below. Please ensure that you provide us with accurate contact details and update them as necessary.
Jaguar Land Rover Pension Department – 0121 347 2451 and JLR Pensions Department, Block 17, Lode Lane, Solihull, B92 8NW firstname.lastname@example.org