Scope of this privacy notice

This privacy notice applies where Lane Clark & Peacock Ireland Limited or Lane Clark & Peacock Trustee Services Limited (individually and combined referred to as “LCP”) processes personal data for our clients to fulfil any contractual arrangement with our client and to provide our client with a professional service.

Who is collecting the data?

Lane Clark & Peacock Ireland Limited is an actuarial and investment firm offering a range of professional services to companies and individuals. Lane Clark & Peacock Trustee Services Limited is a firm offering a range of trustee services.

LCP is deemed to be data controller when offering some professional services such as in the provision of actuarial, financial or investment advice to individuals or groups of individuals. All data controllers are required by the European General Data Protection Regulation (GDPR) to notify our clients about the collection, storing, use, disclosure, transfer and disposal (collectively known as “processing”) of personal information (or data) relating to our clients.

What data is being collected?

LCP retain personal data about our clients to fulfil any contractual arrangement with our clients and to provide our clients with a professional service. 

The personal information about our clients can be collected from our clients and other sources such as our client’s employer, representatives, and other advisors. The data which may be collected include: 

• Personal details such as name (including former names), date of birth, sex, contact details (e.g. home address and former addresses, telephone numbers and e-mail address), and identifiers such as PPS number.
• Employment and pension scheme membership details such as dates of joining and leaving employment (including reason for leaving, where relevant to benefit calculations) and employment history (e.g. whether part-time or full-time, periods of absence and job title), periods of pensionable service, earnings and details of other benefits.
• Details of pension contributions and benefits, such as compulsory and voluntary contributions, actual or potential defined benefits and defined contribution account information (e.g. investment allocation and account balance).
• Other financial details such as other pension arrangements, relevant tax and PPS details, bank sort code and account number, tax codes (e.g. PRSI class), tax credits, Personal Financial Threshold and deductions from pension payroll.
• Details of family and social circumstances such as current marriage or civil partnership, any previous relationships and dependents, and death benefit distribution information (including expression of wish forms).
• Copies of identification and similar documents (e.g. birth, marriage, civil partnership and death certificates, passport identity pages, decree absolute, Pension Adjustment Orders).
• Information about health to determine and provide benefits and advice.

LCP respects our client’s right to privacy and will ensure that client personal data is kept securely and is processed in accordance with applicable data protection laws, including the GDPR and LCP‘s data protection policies.

How do we use personal data that we collect?

We use personal data for the purpose for which it has been provided to us, ie for legitimate business purposes, including but not limited to providing and improving our services to our clients, marketing our services (in accordance with our website and marketing privacy policy), managing our relationships with clients, prospects and third parties, the receipt of services, and staff recruitment, as well as identifying clients for anti money laundering and verification of identity purposes.

• On behalf of Clients

In circumstances where we process personal data on behalf of clients (including pension scheme member data and) we will carry out such processing only in accordance with our clients’ instructions. In processing such personal data, we will usually act as the data processor and our client is usually the data controller.

• Scheme Actuary & PRSA Actuary

LCP advises pension scheme trustees on various matters, including, but not limited to, the value of an individual member’s pension, the value of options available to individual members, and the value of the scheme as a whole.

In providing our advice, LCP uses member data, which may include the personal data listed above. 

In circumstances where an LCP partner or staff member acts as scheme actuary for a pension scheme (the “Scheme Actuary”), he or she may be a data controller in carrying out his or her statutory functions as scheme actuary and will carry out those functions in accordance with data protection laws.

• Individual advice and preparation of PRSA Certificates of Comparison

In circumstances where we process personal data on behalf of individual clients (for example in providing financial or investment advice) we will usually act as the data controllers. We will use personal information to provide the services to the client for which we have been appointed – for example to provide financial advice or to prepare a certificate of comparison.

• Trustee Services

In circumstances where we act as Trustee, we will usually act as the data controllers or joint data controllers with the Registered Administrator and the Sponsoring Employer. We will use personal information to provide the Trustee services to the scheme and to meet statutory Trustee duties.

Our legal basis for processing personal data

Often, our legal basis for processing personal data will be contractual, for example we need to process personal data to meet our obligations under the terms on which we are appointed to advise our clients. 

In some cases, we might consider that we have a legitimate interest to process an individual’s personal data.

In other cases we might ask for an individual’s consent to process their personal data, for example we might seek consent to retain contact details for the purpose of providing individuals with information that we believe could be useful and relevant to them.  In such cases, we will always provide the individual with a clear way of withdrawing consent.

What is the legal basis for processing the data?

LCP process client data to fulfil contractual obligations with our clients and to provide our clients with a professional service. In addition, LCP will also process client data to: 

• Respond to any information requests from clients or a regulator
• To promote services which we offer including promotion of events and publications
• Comply with its legal and regulatory obligations and risk management
• To defend any legal claims

How we manage personal data

The processing of an individual’s personal data will be done in accordance with the General Data Protection Regulation and any other legislation which is relevant to data protection in the Republic of Ireland.  Access to personal data will be limited to authorised individuals on a strictly need to know basis. We are committed to keeping data safe and secure and will ensure that appropriate technical and organisation measures are in place to protect it from unauthorised or unlawful processing.

Client personal data will be held confidentially but may be disclosed to other third parties, such as:  

• Other professional advisors with whom clients have consented we share client information – for example legal advisors or accountants
• Our auditors and other advisors
• Suppliers such as IT providers, shredders, storage companies
• Other parties clients have consented we share client information – for example, client’s employer or family members

LCP may also be required to disclose information to the Revenue Commissioners, the Financial Services Pension Ombudsman, the Pensions Authority and other regulatory authorities. Where this is required, there must be a legal basis for so doing.

Transfer outside of the EEA

We will only transfer personal data outside of the European Economic Area if:

• the individual has asked us to;
• the European Commission has determined that the country, territory and/or organisation that is receiving the data ensures an adequate level of protection; and/or
• there are appropriate safeguards in place for the data (ie individuals’ rights in respect of that data are still enforceable and effective remedies are still available).

We do not routinely transfer personal data that we process on behalf of clients outside the EEA.  Where we are acting on a client’s instructions to do so, the client will usually have put in place appropriate safeguards.

How long will the data be stored for?

Usually client personal data will be kept for a maximum of seven years after the termination of the client contract with us. However, the duration will be determined by the service offered and the data held.

LCP will retain client personal data to allow it to meet its regulatory requirement to retain data and to enable it to defend against any future legal claims and to meet good practice in managing its business. 

What rights do our clients have?

Where we are the data controller, individuals have the following rights in relation to their personal data:

• Right of access – the right to request a copy of their personal data that we hold.
• Right to rectification – the right to have their data corrected if it is inaccurate or incomplete.
• Right to erasure – the right to have their data deleted or removed if it is no longer necessary for the purpose for which it was obtained.
• Right to restrict processing – the right to request that the way in which we use their data is restricted to certain uses which they may specify.
• Right to data portability – the right, where applicable, to have their data transferred to another organisation.
• Right to object – the right to object to the processing of their personal data in certain circumstances eg for direct marketing purposes. In the event that an individual has not consented to our use of their personal data and we are not using their data in a way in which they would reasonably expect or they do not consider that we are using their data for their benefit, then an individual may object to us collecting and using their personal data. Individuals may withdraw any consent they have given in respect of their personal data at any time.  

To exercise any of these rights please contact us using the contact details below.  We will aim to respond to any request received within one month of receipt. 

Complaints

We aim to meet the highest standards when collecting and using our clients personal information. However, if our clients believe we are not meeting these standards and wish to make a complaint, please send any queries or complaints to the email address below.

In the event that your query has not been resolved to your satisfaction, you have the right to raise the matter with the Data Protection Commissioner, Lo call 1890 252231 or email info@dataprotection.ie.

Please note that if you fail to provide accurate membership information or object to processing of your data it may result in a delay or an inability to provide professional services.

Further information may be obtained by contacting LCP at the address: eoin.mullen@lcpireland.com

How to contact us?

If you would like further information about this privacy notice or how to request your personal data you can email us at eoin.mullen@lcpireland.com or write to the address provided below.

GDPR

Lane Clark & Peacock Ireland Ltd

Office 2, Grand Canal Wharf

South Dock Road

Dublin 4

Changes to this privacy notice

LCP may revise the privacy notice from time to time and we reserve the right to change the privacy notice at any time. This privacy notice was last updated on 4th March 2024.