ePA Privacy Notice
THIS PRIVACY NOTICE
Towers Watson Limited (“we” or “us”) is part of the Willis Towers Watson group which operates worldwide through its subsidiary and affiliate companies (collectively, “Willis Towers Watson”).
We are the administrators of your occupational pension scheme (“Scheme”) and in accordance with the instructions of our client (the trustees of your Scheme). We provide ePA (the “Site”) as part of those administration services. The Site enables you to view and make decisions relating to your Scheme including your Scheme benefits. To do this, the Site uses some of your Personal Information. To understand how your Personal Information is used in the operation of the Scheme, please check your Scheme's privacy notice.
This privacy notice only describes how Willis Towers Watson handles the Personal Information we collect when you use the Site, acting as a data controller.
PERSONAL INFORMATION PROCESSING
“Personal Information” is information that identifies you as an individual or relates to an identifiable individual. When you use ePA, we collect and use your Personal Information:
- When you log in to the Site (user id and password); and
- through placing cookies and similar technologies on your device.
This Personal Information is your Site Usage Data.
You can find out more about the cookies and similar technologies we use and why by viewing our Cookie Notice. Our Cookie Notice should be read together with this Privacy Notice.
PURPOSES AND LEGAL BASES FOR PROCESSING INFORMATION
We process Site Usage Data for our legitimate interests, which include:
- enabling you to log in to the Site;
- analysing use of the Site;
- improving Site content; and
- monitoring and improving Site security and performance.
DISCLOSURE OF YOUR PERSONAL INFORMATION
We may disclose Site Usage Data to other Willis Towers Watson group entities and/or third-party services providers that help us to operate or improve the Site.
AGGREGATED AND ANONYMISED DATA
We may aggregate and/or anonymise information about you. Aggregated and anonymised data is not capable of being used to identify individuals and is not treated as Personal Information under this privacy notice.
We maintain appropriate technical and organisational security measures to protect your data against loss, misuse, unauthorised access, disclosure or alteration. Despite this, the security of the transmission of information via the Internet cannot always be guaranteed and you acknowledge this in your access and use of the Site. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of your account has been compromised), please immediately notify us in accordance with the “Contact & Comments” section below.
CROSS BORDER TRANSFER
The Site is hosted in the United Kingdom; however, because of the global nature of our business, your Personal Information may be processed in other jurisdictions where we have facilities or in which we engage service providers. We have established safeguards to protect Personal Information that is transferred to other countries, including appropriate contractual protections.
For more information on the appropriate safeguards in place, please contact us using one of the methods listed in the “Contact & Comments” section below.
You have the following rights in relation to your Personal Information. When making a request, please make clear what Personal Information your request relates to and make the request using “Contact & Comments” section below.
- Right of access: You have the right to obtain from us confirmation as to whether or not Personal Information concerning you is being processed, and where that is the case, to request access to the Personal Information. The accessed information includes – among others - the purposes of the processing, the categories of Personal Information concerned, and the recipients or categories of recipient to whom the Personal Information have been or will be disclosed. You have the right to obtain a copy of the Personal Information undergoing processing. For further copies requested by you, we may charge a reasonable fee based on administrative costs.
- Right to rectify and complete Personal Information: You can request the rectification of inaccurate data and the completion of incomplete data. We will inform relevant third parties to whom we have transferred your data about the rectification and completion if we are legally obliged to do so.
- Right to erasure (right to be forgotten): You have the right to obtain from us the erasure of Personal Information concerning you in limited circumstances where:
- it is no longer needed for the purposes for which it was collected; or
- you have withdrawn your consent (where the data processing was based on consent); or
- following a successful right to object; or
- it has been processed unlawfully; or
- the data has to be erased in order to comply with a legal obligation to which Willis Towers Watson is subject.
- compliance with a legal obligation; or
- the establishment, exercise or defense of legal claims.
- Right to restriction of processing: You have the right to obtain from us restriction of processing your Personal Information. In this case, the respective data will be marked and only be processed by us for certain purposes. This right can only be exercised where:
- the accuracy of your Personal Information is contested, to allow us to verify its accuracy; or
- the processing is unlawful, but you do not want the Personal Information erased; or
- it is no longer needed for the purposes for which it was collected, but you still need it to establish, exercise or defend legal claims; or
- you have exercised the right to object, and verification of overriding grounds is pending.
- we have your consent; or
- to establish, exercise or defend legal claims; or
- to protect the rights of another natural or legal person.
- Right to data portability: You have the right to receive the Personal Information concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and you have the right to transmit those data to another entity without hindrance from us, but in each case only where the processing is (a) based on your consent or on the performance of a contract with you, and (b) also carried out by automated means.
- Right to object: You have the right to object at any time to any processing of your Personal Information which has our legitimate interests as its legal basis. You may exercise this right without incurring any costs. If you raise an objection, we have an opportunity to demonstrate that we have compelling legitimate interests which override your rights and freedoms. The right to object does not exist, in particular, if the processing of your Personal Information is necessary to take steps prior to entering into a contract or to perform a contract already concluded.
- Right to object to our use of your Personal Information for direct marketing purposes: You can request that we change the manner in which we contact you for marketing purposes. You can request that we do not transfer your Personal Information to unaffiliated third parties for the purposes of direct marketing or any other purposes.
- Right to withdraw consent: If you have given us your consent for the processing of your Personal Information, you have the right to withdraw your consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.
- Right to obtain a copy of safeguards: You can ask to obtain a copy of, or reference to, the safeguards under which your Personal Information is transferred outside the EU/EEA. We may redact data transfer agreements to protect commercial terms.
- Right to lodge a complaint with your local data protection supervisory authority: You have a right to lodge a complaint with your local supervisory authority if you have concerns about how we are processing your Personal Information. The Information Commissioner's Office, can be contacted at www.ico.org.uk/concerns/.
We are not required to comply with your request to erase Personal Information if the processing of your Personal Information is necessary for:
We can continue to use your Personal Information following a request for restriction, where:
We ask that you please attempt to resolve any issue with us first, although you have a right to contact your supervisory authority at any time.
Please note that we may need to retain certain information for record keeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion. There may also be residual information that will remain within our databases and other records, which will not be removed, but where that is the case we will take steps to prevent such data from being accessed or used.
We retain your Site Usage Data for as long as we provide the Site to you. We may retain aggregated or anonymised data (which is not treated as Personal Information under this privacy notice) for longer.
CHANGES TO OUR PRIVACY NOTICE
We review our Privacy Notice regularly. Where the Privacy Notice has been updated, it will be clearly identified by reference to the date of this Privacy Notice above. We recommend that you review our Privacy Notice regularly to ensure you are fully informed.
CONTACTS & COMMENTS
If you have any questions or comments regarding this privacy notice, please contact us at the following e-mail address: TAS.Customer.Services@willistowerswatson.com or in writing to:
Customer Services, Willis Towers Watson, PO Box 729, Redhill, Surrey RH1 9FG.