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Employer Clients Privacy Notice

Privacy Notice 

This privacy notice explains how Premier Benefit Solutions Ltd (‘we/our’) use any personal information we collect about you and your employees. Please read the following carefully to understand our views and practises regarding your personal data and how we will treat it. 

Before providing us with any information you are responsible for ensuring that your employees are aware of the data being held by us on your behalf as Data Controller and the reasons for holding that data. “Data Protection Legislation” the EU General Data Protection Regulation 2016/679; together with all other applicable legislation relating to privacy or data protection and where we use the terms “personal data”, “data subject”, “controller”, “processor” and “process” (and its derivatives), such terms shall have the meanings given to them in the Data Protection Legislation. 

What information do we collect about your employees and how do we do this? 

We could hold both basic and sensitive data about your employees: 

  • name, address, date of birth, telephone number and email address; 
  • National Insurance number; 
  • employment history; 
  • information on children e.g. where a child is named as a beneficiary on the policy taken out by a parent or guardian on their behalf; 
  • salary, details of any period of absence and working hours; 
  • marital status and details of any dependants and/or potential beneficiaries; 
  • bank details; 
  • information relating to health if this has been shared with us; and 
  • any other personal data which may be needed to carry out the services. 

How do we collect this data? 

We collect information about you and your employees when it is provided to us for the employee benefits consultancy services. 

Some of this information is or will have been collected directly from you or your employees (for example, when filling in forms, or when corresponding with us or our representatives by telephone, post, email or otherwise). We may also collect information when you and your employees voluntarily complete client surveys or provide feedback to us. 

Information relating to usage of our website is collected using cookies. These are text files placed on your computer to collect standard internet log information and visitor behaviour information. We’ll use any information collected from the website to personalise repeat visits to the site. 

Lawful grounds for using your information 

We are permitted to process personal information, in compliance with data protection legislation, by relying on one or more of the following lawful grounds: 

  • you or your employees have explicitly agreed to us processing such information for a specific reason; 
  • the processing is necessary to perform the agreement we have with you or them or to take steps to enter into an agreement with you or them. The information that we collect about you and your employees is essential for us to be able to carry out the services that you require from us effectively. Without collecting you and your employees’ personal data we’d also be unable to fulfil our legal and regulatory obligations; 
  • the processing is necessary for compliance with a legal obligation we have; or 
  • the processing is necessary for the purposes of a legitimate interest pursued by us, which might be: 
  • to provide our services; 
  • to prevent fraud; 
  • to protect our business interests; 
  • to ensure that complaints are investigated; 
  • to evaluate, develop or improve our services; or 
  • to keep you informed about relevant products and services, unless you have indicated at any time that you do not wish us to do so. 

In relation to any sensitive data, we will generally rely on obtaining specific consent in order to process such information, although it may be necessary for us to use certain information in order to comply with our legal obligations as a regulated entity (such as in relation to an alleged offence). 

Where you or your employees have consented to our processing of such information (including sensitive categories of personal data) you or they may withdraw such consent at any time. Please note, however, that in certain circumstances it may be still lawful for us to continue processing this information even where consent has been withdrawn, if one of the other legal bases described above is applicable. Please note that not providing or withdrawing consent could mean that we have insufficient information to provide our services. 

How will we use the information about you and your employees? 

We collect information about you and your employees in order to: 

  • assess any billing matters or credit decisions; 
  • provide you and your employees with the services for which you and your employees engage us; 
  • enable us to carry out statistical and other analysis and to meet our legal or regulatory obligations; 
  • for our reasonable commercial purposes (including in connection with our insurance, quality control and administration and assisting us to develop new and improved services); 
  • to confirm your or their identity and carry out background checks, including as part of our checks in relation to anti-money laundering, compliance screening and to prevent fraud and other crimes; 
  • to follow up with you or them after you request information to see if we can provide any further assistance; 
  • to check your or their instructions to us; 
  • to monitor, record and analyse any communications between you or them and us, including phone calls to analyse, assess and improve our services to you, as well as for training and quality purposes; 
  • to share information with relevant third parties in the context of a sale or potential sale of a relevant part of our business, subject always to confidentiality obligations; 
  • if instructed to do so by you or them or where you or they give us your consent to the use and/or processing involved; and 
  • to improve the relevance of marketing messages we may send you or them (which you can opt out of as explained below). 

Who might we share your information with? 

In order to deliver our services to you effectively we may send you and your employees details to third parties such as: 

  • those that we engage for professional compliance, accountancy or legal services, our regulator the Financial Conduct Authority, the Information Commissioners Office for the UK (the ICO), price comparison websites and similar companies that offer ways to research and apply for financial products and services as well as product and platform providers that we use to arrange employee benefits and financial products for you or your employees; 
  • any other service providers who hold or process your data on our behalf; and 
  • to fulfil our legal obligations in respect of prevention of money-laundering and other financial crime we may send you and you employees’ details to third party agencies for identity verification purposes. This will assist us in developing and improving how we deal with financial crime and complying with regulations that apply to us. Whenever we share your or your employees’ personal information, we will do so in line with your obligations to keep the information confidential, safe and secure. 

How long do we keep hold of your and your employees’ information? 

We will only keep the information we collect about you and your employees for as long as required for the purposes set out above or as required to comply with any legal obligations to which we are subject. This will involve us regularly reviewing our files to check that information is accurate and up-to-date and still required. 

Sharing your personal data outside of the EEA 

Information about you or your employees in our possession is usually stored inside of the EEA. However, there may be occasions where it may be transferred to other countries (which may include countries outside the European Economic Area) for any of the purposes described in this notice, including our transmission of such information to agents outside the European Economic Area. 

If any such information (including special categories of personal data) belongs to relevant individuals other than you, by providing us with such information you confirm that you have obtained any necessary permissions from such persons to the reasonable use of their information for such purposes in accordance with the following provisions, or are otherwise permitted to give us this information on their behalf. 

You and they understand and accept that these countries may have differing (and potentially less stringent) laws relating to the degree of confidentiality afforded to the information it holds and that such information can become subject to the laws and disclosure requirements of such countries, including disclosure to governmental bodies, regulatory agencies and private persons, as a result of applicable governmental or regulatory inquiry, court order or other similar process. In addition, a number of countries have agreements with other countries providing for exchange of information for law enforcement, tax and other purposes. 

If we, or our permitted third parties, transfer information outside the European Economic Area, we or they will impose contractual obligations on the recipients of that data to protect such information to the standard required in the European Economic Area. We or they may require the recipient to subscribe to international frameworks intended to enable secure data sharing. In the case of transfers by us, we may also transfer your information where: 

  • the transfer is to a country deemed to provide adequate protection of your information by the European Commission; or 
  • you and other relevant individuals have consented to the transfer. 

If we transfer your information outside the European Economic Area in other circumstances (for example because we have to provide such information by law), we will use best endeavours to put in place appropriate safeguards to ensure that your information remains adequately protected. 

General Rights 

You and your employees have a number of rights concerning the way that we use your information. You are responsible for ensuring that other relevant individuals are aware of these rights. At any time, such individuals shall have the right: 

  • to be informed about the processing of their personal data (i.e. for what purposes, what types, to what recipients it is disclosed, storage periods, any third party sources from which it was obtained, confirmation of whether we undertake automated decision-making, including profiling, and the logic, significance and envisaged consequences); 
  • to request access to, or a copy of, any personal data we hold about them; 
  • to request the rectification of their personal data, if they consider that it is inaccurate; 
  • to request the erasure of their personal data, if they consider that we do not have the right to hold it; 
  • to object to their personal data being processed for a particular purpose or to request that we stop using their information; 
  • to request not to be subject to a decision based on automated processing and to have safeguards put in place if they are being profiled based on their personal data; 
  • to ask us to transfer a copy of their personal data to themselves or to another service provider or third party where technically feasible and otherwise required by applicable regulations; 
  • to withdraw, at any time, any consent that they have previously given to us for our use of their personal data, although if you withdraw your consent this may impact on our ability to provide services to you; or 
  • to ask us to stop or start sending them marketing messages at any time. 

As stated above, you and other relevant individuals may have a right of access to some, or all, of the information we hold about you or them, or to have any inaccurate information corrected, under the data protection legislation. Any request for access to or a copy of your personal data must be in writing and we will endeavour to respond within a reasonable period and in any event within one month in compliance with data protection legislation. We will comply with our legal obligations as regards any individual’s rights as a data subject. 

We aim to ensure that the information we hold about you or other relevant individuals is accurate at all times. To assist us in ensuring that such information is up to date, please let us know if the personal details of you or other relevant individuals change. We will correct any incorrect or incomplete information and will stop processing personal data, or erase it, where there is no legal reason for us to continue to hold or use that information. 

Marketing 

We’d like to send you information about our products and services which may be of interest to you. If you have agreed to receive marketing information, you may opt out at a later date. If you no longer wish to be contacted for marketing purposes, please contact us by email or post. We won’t share you and/or your employees’ information for marketing purposes with companies outside our group of companies or other companies. 

Cookies 

We use cookies to track visitor use of our website www.premiercompanies.co.uk and to compile statistical reports on website activity. Our website privacy policy can be viewed when you access the website. 

For further information visit http://www.allaboutcookies.org/ 

You can set your browser not to accept cookies and the above website tells you how to remove cookies from your browser. However in a few cases some of our website features may not function as a result. Further details are contained within our privacy policy on the website. 

What can you and your employees do if you/they are unhappy with how your/their personal data is processed? 

You and your employees also have a right to lodge a complaint with the supervisory authority for data protection. In the UK this is: 

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

0303 123 1113 (local rate) 

Changes to our privacy policy 

We keep our privacy policy under regular review and we’ll place any updates on our web page and provide you with an updated copy at your next review meeting. This privacy policy was last updated on 26th April 2018. 

How to contact us 

Please contact us if you have any questions about our privacy policy or the information we collect or hold about you; 

In writing: To the Compliance Officer at Premier Benefits Solutions Ltd, AMP House, Dingwall Road, Croydon, Surrey, CR0 2LX 

By phone: +44 (0) 203 727 9800 

By e-mail: howard.barnes@premiercompanies.co.uk 

We are committed to protecting your personal data. 

Further information

Questions, comments and request regarding this privacy policy are welcomed and should be addressed to info@premiercompanies.co.uk.