This notice does not apply to individuals who participated in a registered pension plan in Canada.

Who is this Privacy Notice Provided For?

You should read this privacy notice if you are a member of a pension scheme whose scheme is being used for ‘test pricing’ purposes by Brookfield Annuity Company UK Limited (BAC UK).

BAC UK is currently not authorized to write business in the UK and therefore cannot and will not use the data provided for any purposes other than the above.

About BAC UK

BAC UK is a limited company currently seeking authorization to enter into the Bulk Purchase Annuity (BPA) market in the UK as an insurer. Our company registration number is: 14130490.

Our address is Level 25, One Canada Square, Canary Wharf, London, E14 5AB

We are a controller under data protection laws. This privacy notice explains how we collect, use and look after your personal data and how we keep to our legal obligations to you when doing so. This privacy notice also tells you about your privacy rights and how the law protects you.

About this document

This privacy notice contains information about:

• The personal data that we process as a controller
• Where the personal data has been obtained
• The reasons why we process your personal data and the lawful basis we use to do so
• The security measures that we have in place to keep your personal data secure
• The length of time we store your personal data for
• The rights you have under data protection laws in relation to our processing of your personal data

1. What personal data do we process

The categories of personal data we process include the following:

Scheme member personal information: Personal data relating to each individual insured under a policy, which may include:

• Postcode
• Date of birth
• Gender
• Marital status
• Retirement age
• Retirement date
• Scheme name

2. Where the personal data has been obtained

Personal data will usually be obtained from Employee Benefit Consultants contracted by the Trustees or Employer of your Scheme.

3. The reasons why and lawful bases to process your personal data

Why do we need it?

We process personal data to determine a theoretical price that the Trustees of your Scheme would need to pay to purchase a bulk annuity for your scheme. This allows the Trustees of your Scheme to obtain competitive prices for the purpose of insuring the Scheme.

Lawful basis for processing

We are required by law to have a “lawful basis” (i.e. a reason or justification) for processing your personal data. We rely on our legitimate interests to process your personal data for the purpose of determining theoretical pricing. Where we process your personal data because it is necessary for our legitimate interests, you can object to our processing at any time. If you object, we will stop processing unless we can show you a compelling reason why the processing is so important for the best interests of the Scheme that it overrides your privacy rights (though this does not mean processing happens without safeguards) or where the processing is for the establishment, exercise or defense of legal claims. For example, if we can demonstrate with the help of the Scheme that not processing your personal data (amongst that of other members) would result in a higher price for insurance, which goes against the best interests of the Scheme, that might be one example of a compelling reason. We’d need to assess this on a case by case basis.

4. How do we keep your personal data secure?

Our commitment to corporate security is demonstrated through the implementation of policies, controls and procedures, which are externally certified and audited. Our security policies, controls and procedures are regularly reviewed and updated so that we maintain good practices across our business to keep your information safe.

5. How long do we store your personal data?

The period we store personal data for the purpose stated above is no longer than 6 months.

6. Who has access to your personal data?

We do not share personal data with other companies. Your data is only accessible by the internal pricing team.

7. Your rights

Under certain circumstances, you have the following rights under data protection law:

• The right to access personal data relating to you (known as Subject Access Requests).
• The right to correct any mistakes in your personal data.
• The right to require us to delete your personal data.
• The right to restrict our processing of your personal data.
• The right to object to us processing your personal data, including for marketing purposes.
• The right to have your personal data provided to another controller.

How to exercise your rights

If you wish to exercise any of your rights, please contact us using the contact details below.

8. Contact Details

You may want to contact us to:

• Ask any questions you have in relation to the information contained in this privacy notice.
• Exercise any of your rights under data protection laws.
• Request a printed copy of this privacy notice.
• Request a version of this privacy notice printed in large print or braille.
• Request an audio version of this privacy notice.
• Make a complaint (see below).

To contact us you can email our Data Protection Officer at jamie.dobbin@brookfield.com or write to him at:

Jamie Dobbin, BAC UK Data Protection Officer,
Level 25, One Canada Square, Canary Wharf, London, E14 5AB

How to make a complaint

If you have a problem or concern relating to the ways we process your personal data or the contents of this privacy notice, please contact us in the first instance. We hope that we will be able to address the problem or concern to your satisfaction. However, you also have the right to make a complaint to the Information Commissioner’s Office. The process for making a complaint to the Information Commissioner’s Office is available here: https://ico.org.uk/make-a-complaint.

Their contact details are as follows:

Address:
Information Commissioner’s Office,
Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

Or phone: 0303 123 1113

Web: ico.org.uk