Isio Group Ltd and Isio Services Ltd

We are dedicated to protecting the confidentiality and privacy of information
entrusted to us in accordance with the UK General Data Protection Regulation
(GDPR), the UK Data Protection Act 2018 and those laws relating to Data Protection
and privacy in the UK. This Privacy Notice (together with our cookies policy and
terms of use) sets out how we obtain, use, store and dispose of your personal data
as well as explaining your rights.

This Privacy Notice sets out how we will use your personal data when we are acting
as a data controller (someone who determines what data to collect and how to use
it). We may also use your personal data when acting as a data processor (acting on
instructions given by the data controller – our clients (e.g. your employer or pension
scheme)). You should therefore also read the Privacy Notice of your employer
and/or pension scheme as this will also govern the use of your Personal Data.
Any updates to how we use your data will be explained on this page.

1. Who are we?

This Privacy Notice applies to Isio Group Ltd, Premier Pensions Management
Limited and any entity controlled by it and any entity under common control with
Isio Group Ltd as well as any of our employees acting in their individual capacity as
Scheme Actuary (“we” or “us”).
. “You” and “user” means the person about whom we hold the data.

2. How do we collect personal data?
  • Directly - We obtain personal data directly from individuals in a variety of ways,
    including obtaining personal data from individuals who provide us with their
    business card(s), complete our online forms, subscribe to our newsletters, sign
    up for marketing, register for events/meetings, visit our offices or for
    recruitment purposes. We may also obtain personal data directly when, for
    example we are establishing a business relationship, performing professional
    services through a contract, or through hosted software applications. If you are
    a Premier Wealth Planning customer you can find out more about how we use
    your date here.
  • Indirectly - We obtain personal data indirectly about individuals from a variety of
    sources including recruitment services, your employer/former employer and
    pension scheme trustees.
  • Public Sources – Personal data may be obtained from public registers, news
    articles, sanctions lists and internet searches.
  • Social and Professional Networking Sites – If you register or login to our
    websites using social media (e.g. LinkedIn or Twitter) to authenticate your
    identity and connect your social media login information with us, we will collect
    information or content needed for the registration or login that you permitted
    your social media provider to share with us. That information may include your
    name and email address and depending on your privacy settings, additional details about you, so please review the privacy controls on the applicable service to set how much information you want shared with us.
  • Recruitment Services – We may obtain personal data about candidates from an
    employment agency and other parties include former employers and credit
    reference agencies. You can find out more about how we process your data on
    our recruitment website here.
3. What categories of personal data do we collect?

We may obtain the following categories of personal data about you through direct
interactions with us, or from information provided by your employer.

  • Personal data. Here is a list of some of the personal data we commonly collect
    to conduct our business activities.
    • Contact details (e.g., name, company name, job title, work and mobile
      telephone numbers, work and personal email and postal address)
    • Other unique identifiers (e.g., date of birth, national insurance number)
    • Identification information such as driving licence, birth/marriage
      certificates and utility bills
    • Professional details (e.g., job and career history, educational background
      and professional memberships, published articles).
    • Family and beneficiary details (e.g., names and dates of birth).
    • Financial information (e.g., remuneration, pension amounts, taxes, payroll,
      investment interests, assets, bank details).
    • CCTV at our sites may collect images of visitors. Our policy is to
      automatically overwrite CCTV footage within 30 days.
  • Sensitive personal data. We limit collecting sensitive or special categories of
    personal data about individuals other than our own employees. When we do
    need to process sensitive personal data from individuals who are not our
    employees we do so with the express consent of the individuals or as required
    by law. Examples of sensitive personal data we may obtain, or otherwise hold,
    include:
    • Personal identification documents that may reveal race, sexuality, religion
      or ethnic origin, biometric data of private individuals, beneficial owners of
      corporate entities, or applicants.
    • Adverse information about potential or existing clients and applicants that
      may reveal criminal convictions or offences information.
    • Information provided to us by our clients in the course of a professional
      engagement for example ill-health data in order for us to determine
      benefits due to you from a pension scheme which we advise or as part of
      our insurance advisory work.
    • Diversity and equal opportunity information volunteered by participants in
      certain professional programmes and recruitment processes.
  • Child data. Although we do not intentionally collect information from individuals
    under 13 years of age, we may occasionally receive details about children
    attending events we host with their parents or guardians or as beneficiaries of
    pension scheme members or policies.
4. What lawful reasons do we have for processing personal data?

We may rely on the following lawful reasons when we collect and use personal data:

  • Contract – We may process personal data in order to perform our contractual
    obligations owed to (or to enter into a contract with) the relevant individuals.
  • Consent – We may rely on your freely given consent at the time you provided
    personal data to us.
  • Legitimate interests – We may rely on legitimate interests based on our
    evaluation that the processing is fair, reasonable and balanced. These may
    include delivering the professional services our clients have engaged us to
    provide or to deliver timely marketing insights and speciality knowledge we
    believe is welcomed by our business contacts.
  • Legal obligations – We may process personal data in order to meet our legal
    and regulatory obligations or mandates.
  • Substantial public interest – We may process personal data for reasons of
    substantial public interest.

Your employer and/or pension scheme trustees may rely on other lawful reasons as
laid out in their Privacy Notice.

5. Why do we need personal data?
  • We collect and process your personal data for the following purposes: Providing
    actuarial services to our clients.
  • Providing a quality and professional service. We may process personal data
    when reviewing client files for quality assurance purposes.
  • Promoting our services, products and capabilities to existing and prospective
    business clients.
  • Sending invitations and providing access to guests attending our events and webinars or our sponsored events.
  • Personalising online landing pages and communications we think would be of interest.
  • Administering, maintaining and ensuring the security of our information systems, applications and websites.
  • Authenticating registered users to certain areas of our sites.
  • Seeking qualified candidates and forwarding candidate career enquiries to our human resources team, you can find out more here.
  • Processing online requests, including responding to communications from individuals or requests for proposals and quotations.
  • Contacting journalists regarding company press releases, invitations to annual press parties, highlighting messages that may be of interest on specific industry topics.
  • Complying with legal and regulatory obligations including maintaining appropriate audit trails, anti-money laundering, terrorist financing, fraud and other forms of financial crime.
  • Compiling health and safety data following an incident or accident.
6. Do we share personal data with third parties?

We may occasionally share personal data with trusted third parties to help us deliver
efficient and quality services. These recipients are contractually bound to safeguard
the data we entrust to them. We may engage with several or all of the following
categories of recipients:

  • Parties that support us as we provide our services (e.g., providers of
    telecommunication systems, mailroom support, IT system support, archiving
    services, document production services and cloud-based software services).
  • Our professional advisers (including but not limited to lawyers, auditors and
    insurers) and other advisors appointed by the pension scheme trustees and/or
    your employer.
  • A potential buyer, transferee, merger partner or seller and their advisers in
    connection with an actual or potential transfer or merger of part or all of our
    business or assets, or any associated rights or interests, or to acquire a business
    or enter into a merger with it.
  • Payment services providers.
  • Price comparison websites and similar companies that offer ways to research
    and apply for financial products and services where we are engaged to provide
    this service to our clients
  • Marketing service providers.
  • Law enforcement or other government and regulatory agencies or to other third
    parties as required by, and in accordance with, applicable law or regulation.
  • Recruitment service providers.
7. Do we transfer your personal data outside the UK?

We store most of our data in the UK. We may transfer personal data to reputable
third-party organisations situated inside or outside the UK when we have a
business reason to engage these organisations.

Whenever we transfer your personal data out of the UK, we ensure a similar degree
of protection is afforded to it by ensuring at least one of the following safeguards is
implemented:

  • We will only transfer your personal data to countries that have been deemed to
    provide an adequate level of protection for personal data.
  • Where we use certain service providers, we may use specific contracts
    approved for use in the UK which give personal data the same protection it has
    in the UK.

Further details on this are available on request using the contact details set out in
section 13 below.

8. What about personal data security?

We have put appropriate technical and organisational security policies and
procedures in place to protect personal data (including sensitive personal data)
from loss, misuse, alteration or destruction. We aim to ensure that access to your
personal data is limited only to those who need to access it. Those individuals who
have access to the data are required to maintain the confidentiality of such
information. We may apply pseudonymisation, de-identification and anonymisation
techniques in efforts to further protect personal data.

You remain responsible for keeping your user ID and password confidential. Please
be aware that the transmission of data via the internet is not completely secure.
Whilst we do our best to try to protect the security of your personal data, we cannot
ensure or guarantee the security of your data transmitted to our site; any
transmission is at your own risk.

9. How long do we retain personal data?

We will only retain your personal data for as long as reasonably necessary to fulfil
the purposes we collected it for. Any personal data processed as part of a client
engagement will be retained for as long as instructed by our client. At the end of any
engagement with our clients we will retain one copy for our legal and compliance
purposes including to demonstrate compliance with regulatory rules, to
demonstrate that we have met our contractual and legal obligations and to
establish, exercise or defend legal claims.

We may also retain your data to comply with applicable laws, regulations and
professional obligations that we are subject to.

We retain such personal data for seven years, unless a different time frame applies
as a result of business need or specific legal, regulatory or contractual
requirements. Further details on this are available on request using the contact
details set out in section 13 below.

10. Do we link to other websites?

Our websites may contain links to other sites. Please review the destination
websites’ privacy notices before submitting personal data on those sites. Whilst we
try to link only to sites that share our high standards and respect for privacy, we are
not responsible for the content, security, or privacy practices employed by other
sites.

11. Do we use cookies?

Our websites may use cookies. Where cookies are used, a statement will be sent to
your browser explaining the use of cookies. To learn more, please refer to our
Cookies Notice.

12. What are your data protection rights?
  • Access – You can ask us to verify whether we are processing personal data
    about you, and if so, to provide more specific information.
  • Correction – You can ask us to correct our records if you believe they contain
    incorrect or incomplete information about you.
  • Erasure – You can ask us to erase (delete) your personal data after you
    withdraw your consent to processing or when we no longer need it and no
    longer have the right to hold it.
  • Processing restrictions – You can ask us to temporarily restrict our processing
    of your personal data if you contest the accuracy of your personal data, prefer to
    restrict its use rather than having us erase it, or need us to preserve it for you to
    establish, exercise, or defend a legal claim. A temporary restriction may apply
    while verifying whether we have overriding legitimate grounds to process it. You
    can ask us to inform you before we lift that temporary processing restriction.
  • Data portability – In some circumstances, where you have provided personal
    data to us, you can ask us to transmit that personal data (in a structured,
    commonly used, and machine-readable format) directly to another company if
    is technically feasible.
  • Automated Individual Decision-making – You can ask us to review any
    decisions made about you which we made solely based on automated
    processing, including profiling, that produced legal effects concerning you or
    similarly significantly affected you.
  • Right to Object to Direct Marketing including Profiling – You can object to our
    use of your personal data for direct marketing purposes, including profiling. We
    may need to keep some minimal information to comply with your request to
    cease marketing to you.
  • Right to Withdraw Consent – You can withdraw your consent that you have
    previously given to one or more specified purposes to process your personal
    data. This will not affect the lawfulness of any processing carried out before you
    withdraw your consent. It may mean we are not able to provide certain products
    or services to you and we will advise you if this is the case.
13. Who can you contact for privacy questions or concerns?

If you have questions or comments about this Privacy Notice, how we handle
personal data, please direct your correspondence to: Isio Group Ltd, Data Privacy
Office, c/o SPS, PO Box 721, Salford, M5 0QT or email dataprivacy@isio.com.
We aim to respond within 30 days from the date we receive privacy-related
communications.

We may need to request specific information from you to help us confirm your
identity and ensure your right to access the information or to exercise any of your
other rights. This helps us to ensure that personal data is not disclosed to any
person who has no right to receive it. No fee is required to make a request unless
your request is clearly unfounded or excessive. Depending on the circumstances,
we may be unable to comply with your request based on other lawful grounds.

You may contact the UK Information Commissioner’s Office at
https://ico.org.uk/concerns/handling/ to report any concerns you may have about
our data handling practices. We would, however, appreciate the chance to deal with
your concerns before you approach the ICO so please contact us in the first
instance using the contact details set out in this section.

14. Do we change this Privacy Notice?

We regularly review this Privacy Notice and will post any updates to it on this
website.

Cookies

1.1 Automatic collection of personal information

In some instances, Isio Group Ltd and Isio Services Ltd (“Isio”) and their service providers use cookies, web beacons and other technologies to automatically collect certain types of information when you visit us online, as well as through emails that we may exchange. The collection of this information allows us to customize your online experience, improve the performance, usability and effectiveness of Isio’s online presence, and to measure the effectiveness of our marketing activities.

1.1.1 IP addresses

An IP address is a number assigned to your computer whenever you access the internet. It allows computers and servers to recognise and communicate with one another. IP addresses from which visitors appear to originate may be recorded for IT security and system diagnostic purposes. This information may also be used in aggregate form to conduct web site trend and performance analysis.

1.1.2 Cookies

Cookies may be placed on your computer or internet-enabled device whenever you visit us online. This allows the site to remember your computer or device and serves a number of purposes.
On some of our web sites, a notification banner will appear requiring your consent to collect cookies. If you do not provide consent, your computer or internet-enabled device will not be tracked for marketing-related activities. A secondary type of cookie referred to as "user-input" cookies may still be required for necessary functionality. Such cookies will not be blocked through the use of this notification banner. Your selection will be saved in a cookie and is valid for a period of 90 days. If you wish to revoke your selection, you may do so by clearing your browser's cookies.

Although most browsers automatically accept cookies, you can choose whether or not to accept cookies via your browser's settings (often found in your browser's Tools or Preferences menu). You may also delete cookies from your device at any time. However, please be aware that if you do not accept cookies, you may not be able to fully experience some of our web sites' features.
Further information about managing cookies can be found in your browser's help file or through sites such as www.allaboutcookies.org.Below is a list of the types of cookies used on our web sites:

Purpose Description ​Type & Expiry​
Performance (i.e. User’s Browser) Our web sites are built using common internet platforms. These have built-in cookies which help compatibility issues (e.g., to identify your browser type) and improve performance (e.g., quicker loading of content). Session Deleted upon closing the browser
Security (e.g. Asp .NET) Cookies If you register for access to a restricted area, our cookies ensure that your device is logged for the duration of your visit. You will need your username and password to access the restricted areas. Session Deleted upon closing the browser
Site Preferences Our cookies may also remember your site preferences (e.g. language) or seek to enhance your experience (e.g. by personalising a greeting or content). This will apply to areas where you have registered specifically for access or create an account. Session Deleted upon
closing the
browser
Analytical We use several third party analytics tools to help us understand how site visitors use our web site. This allows us to improve the quality and content on all our Isio website (mainly isio.com) for our visitors. The aggregated statistical data cover items such as total visits or page views, and referrers to our web sites. For further details on our use of Google Analytics, see below Persistent
Site visitor feedback

We use a third party survey tool to invite a percentage of visitors to provide their feedback. Cookies are used to prevent visitors from being invited multiple times.

The first cookie (1) is set if the visitor is not invited to participate in the survey, and is used to ensure visitors are not invited after their first page view.

The second cookie (2) is set if the visitor is invited to participate in the survey, and is used to ensure the visitor is not invited again to participate for a period of 90 days.

1 Session
Deleted upon closing the browser

2 Persistent Deleted
automatically after 90 days or presenting survey invite.

Social sharing

We use third party social media widgets or buttons to provide you with additional functionality to share content from our web pages to social media websites and email. Use of these widgets or buttons may place a cookie on your device to make their service easier to use, ensure your interaction is displayed on our webpages (e.g. the social share count cache is updated) and log information about your activities across the Internet and on our web sites. We encourage you to review each provider's privacy information before using any such service. For further details on our use of social media widgets and applications, see below.

Persistent, but will be deleted automatically after two years if you no longer visit isio.com

Other third party tools and widgets may be used on our individual web pages to provide additional functionality. Use of these tools or widgets may place a cookie on your device to make their service easier to use, and ensure your interaction is displayed on our webpages properly.

Cookies by themselves do not tell us your email address or otherwise identify you personally. In our analytical reports, we may obtain other identifiers including IP addresses, but this is for the purpose of identifying the number of unique visitors to our web sites and geographic origin of visitor trends, and not to identify individual visitors.

BY NAVIGATING ON OUR WEB SITES OR ENTERING YOUR LOGIN DETAILS TO ACCESS AREAS RESERVED FOR REGISTERED USERS, YOU AGREE THAT WE CAN PLACE THESE COOKIES ON YOUR COMPUTER OR INTERNET ENABLED DEVICE.

1.1.3 Google Analytics

Isio uses Google Analytics. More information about how Google Analytics is used by Isio can be found here.

To provide website visitors with more choice on how their data is collected by Google Analytics, Google have developed the Google Analytics Opt-out Browser Add-on. The add-on communicates with the Google Analytics JavaScript (ga.js) to indicate that information about the website visit should not be sent to Google Analytics. The Google Analytics Opt-out Browser Add-on does not prevent information from being sent to the website itself or to other web analytics services.

1.1.4 Web beacons

A web beacon is a small image file on a web page that can be used to collect certain information from your computer, such as an IP address, the time the content was viewed, a browser type, and the existence of cookies previously set by the same server. Isio only uses web beacons in accordance with applicable laws.

Isio or its service providers may use web beacons to track the effectiveness of third party web sites that provide us with recruiting or marketing services or to gather aggregate visitor statistics and manage cookies.

You have the option to render some web beacons unusable by rejecting their associated cookies. The web beacon may still record an anonymous visit from your IP address but cookie information will not be recorded.

In some of our newsletters and other communications, we may monitor recipient actions such as email open rates through embedded links within the messages. We collect this information to gauge user interest and to enhance future user experiences.

1.1.5 Location-based tools

Isio may collect and use the geographical location of your computer or mobile device. This location data is collected for the purpose of providing you with information regarding services which we believe may be of interest to you based on your geographic location, and to improve our location-based products and services.

1.2 Social media widgets and applications

Isio web sites may include functionality to enable sharing via third party social media applications, such as the Facebook Like button and Twitter widget. These social media applications may collect and use information regarding your use of Isio web sites (see details on 'Social Sharing' cookies above). Any personal information that you provide via such social media applications may be collected and used by other members of that social media application and such interactions are governed by the privacy policies of the companies that provide the application. We do not have control over, or responsibility for, those companies or their use of your information.

In addition, Isio web sites may host blogs, forums, crowd-sourcing and other applications or services (collectively "social media features"). The purpose of social media features is to facilitate the sharing of knowledge and content. Any personal information that you provide on any Isio social media feature may be shared with other users of that social media feature (unless otherwise stated at the point of collection), over whom we may have limited or no control.