Privacy Statement
Introduction
The Pensions Authority respects your privacy and is committed to protecting your personal data in accordance with the General Data Protection Regulation (the GDPR) and Data Protection Act 2018 (the DPA). The DPA complements the GDPR and deals extensively with how the GDPR will be enforced in Ireland. Throughout this statement ‘Data Protection Laws’ should be taken as referring to the GDPR, the DPA and any amending legislation. Data Protection Laws confer rights on individuals in relation to the privacy of their personal data. This Privacy Statement informs you what personal data we process, how we receive it, why we use it, and about your privacy rights.
Who we are
The Pensions Authority regulates occupational pension schemes, trust RACs and Personal Retirement Savings Accounts (PRSAs).
The Pensions Authority is the controller and responsible for your personal data (referred to as ‘the Authority’, ‘we’, ‘us’ or ‘our’ in this privacy statement).
We have appointed a Data Protection Officer (DPO) who is responsible for overseeing questions in relation to this privacy statement. If you have any questions including any requests to exercise your legal rights, please contact the DPO using the details set out below.
Data Protection Officer
The Pensions Authority
Verschoyle House
28/30 Lower Mount Street
Dublin 2
D02 KX27
Email: dpo@pensionsauthority.ie
Phone: (01) 613 1900
How we receive personal data
Personal data is received by the methods listed below:
- by phone, email and meetings when conducting regulatory activities or answering enquiries about pensions matters
- submissions to the Pensions Data Register (PDR) system by regulated entities to register pension schemes and provide ongoing information on pension schemes
- submissions of data by PRSA providers
- through FileCloud (a proprietary cloud-based solution for secure file transfer as used by the Office of the Government Chief Information Officer (OGCIO))
- through our website, including the News by Email service
- when conducting consultations and surveys
- when requesting and receiving information from suppliers in response to procurement processes and supplier management
- through management of employees and maintenance of HR records and IT systems
Why we use personal data
We only use personal data for the following purposes:
- regulatory activities as set out under the Pensions Act, 1990, which include:
- registration of occupational pension schemes
- PRSA supervision including collection of PRSA data from PRSA providers
- compliance activities including:
– supervision of Pensions Act, 1990, requirements
– requests for information from regulated entities
– audits of regulated entities
– investigations of regulated entities
– prosecutions of regulated entities
– conducting surveys of regulated entities
- information services to the public which include:
- providing responses to queries on pensions matters
- conducting surveys
- for providing services via our website, PDR and eLearning systems
- policy services including consultations
- management services including:
- procurement processes and supplier management
- employee and HR management
We do not use your personal data for automated decision-making.
The personal data we process
Personal data means any information relating to an identified or identifiable living individual. The categories of personal data defined by Data Protection Laws include identification data (e.g. name, address, emails), marital status, financial data, connection data (e.g. IP addresses) and also includes special categories of personal data for more sensitive information such as PPS numbers and trade union membership.
Cookie Policy
Information on the cookies we collect via our website, PDR and Trustee eLearning systems is available in our Cookie Policy.
A list of the categories of personal data we hold for various types of data subjects and the legal basis for the processing of this data is provided in the table below.
Data subjects | Categories of personal data includes | Lawful basis for processing |
Regulated entities(including scheme trustees, Registered Administrators, employers and PRSA providers) | • Identity, CV and contact data* • Trustee training records • Details of investigations or prosecutions | The Authority has a statutory basis to process personal information in order to supervise the operation of the Pensions Act and carry out its regulatory functions. |
Interested parties to occupational pension schemes and PRSAs(including actuaries, accountants, custodians, investment intermediaries, life companies and users of the Pension Data Register (PDR) system) | • Identity and contact data | The Authority has a statutory basis to process personal information in order to supervise the operation of the Pensions Act and carry out its regulatory functions. |
Members of single member occupational pension schemes | • Identity and contact data • Date of birth • PPSN • Salary • Pension contributions and entitlements • Normal retirement date | The Authority has a statutory basis to process personal information in order to supervise the operation of the Pensions Act and carry out its regulatory functions. |
Scheme members**(only relevant to a compliance activity or information service for specific members) | • Identity and contact data • Trade Union membership • Marital status • Payslips • PPSN • Pension contributions and entitlements | The Authority has a statutory basis to process personal information in order to supervise the operation of the Pensions Act and carry out its regulatory functions. |
PRSA contributors | • Name • Date of birth • PPSN • Marital status • Economic status • PRSA contributions | The Authority has a statutory basis to process personal information in order to supervise the operation of the Pensions Act and carry out its regulatory functions. |
Members of the public who contact our information service with pension enquiries | • Identity and contact data • Any data that the public may share with the Authority as part of their enquiries to the Authority (e.g. union membership, pay slips, pension entitlements, marital status etc.) | Members of the public consent to the processing of their personal data by the Authority in order to allow the Authority to communicate with them and deal with their queries. |
Subscribers to the News by Email service on our website | • Identity and contact data | Subscribers have given consent to receive email notifications. We always include an unsubscribe option in our communications so subscribers can opt out of receiving such communications at any time. |
Suppliers of goods and services to the Authority | • Identity and contact data • Banking data | Where any such processing is necessary for the performance of a contract. |
Employees, ex-employees and job applicants*** | • Identity and contact data • HR records (including PPSN, sick leave, health status, marital status, trade union membership) • Banking data • Training and education data • IT records | Where any such processing is necessary for the performance of employment contracts; to comply with legal and regulatory obligations or where it is necessary to comply with our obligations under employment and social security and social protection law. |
eLearning users | • Identity and contact data | eLearning users consent to the processing of their data when they register |
* Identity and contact data includes first name, last name, physical address, email, phone number
**This information is only held for scheme members whose information is processed as part of a compliance activity or information service request. Not all of the categories of personal data listed will be held for all such scheme members. The data processed is dependent on the Authority’s contact with regulated entities through compliance activities (e.g. audits and inspections) or from enquiries from scheme members and members of the public. Scheme member information is not processed as part of scheme registration activities for occupational pension schemes with more than one member.
***A sub-section of the categories of personal data listed will apply to job applicants.
Who we share your personal data with
As part of our regulatory activities we may need to share your personal data with third parties. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not permit our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions. They may only process this data for the purposes of providing us with their services and no other purpose. Below is information on the names and categories of third parties with which we share personal data and the reasons for sharing.
Third party | Reasons for sharing data |
Revenue | To process the registration of occupational pension schemes and approval of PRSA products and where there is a legislative basis to exchange information such as under the Pensions Act. |
Department of Social Protection | To assist and report to our parent department, as required. |
Financial Services and Pensions Ombudsman | To refer investigation cases where there is a legislative basis to do so. |
Central Statistics Office | The purpose of processing administrative data that is collected by Pensions Authority for their own purposes, which is then used by CSO to efficiently accomplish its mandated objectives, is to give effect to the functions of the Central Statistics Office as set out under the Statistics Act 1993 at Section 10, these being to collect, process, analyse and disseminate information relating to economic, social and general activities and conditions of the State. The Memorandum of Understanding between the Pensions Authority and the CSO can be found here. The CSO’s transparency notice can be found at Pensions Authority Data – CSO – Central Statistics Office. |
Other regulators or supervisory authorities | Where there is a legislative basis to exchange information such as under the Pensions Act |
Service providers who provide the Authority with support services (including IT managed service providers, software development contractors, data analysts, document storage and destruction companies, pension administration services, recruitment services, banking services, website management providers, survey companies) | To allow for the performance of a contract. |
Our website uses services provided by Google, including Google Custom Search and Google Analytics. Google may store information on servers outside the European Economic Area (EEA). We have set up the Google Analytics service with enhanced privacy so that Google will not retain your full IP address. Any transfers which take place outside of the EEA are subject to appropriate safeguards including the use of Standard Contractual Clauses.
Our News by Email service is managed using MailChimp. MailChimp’s servers are located in the United States. Any transfers which take place outside of the EEA are subject to appropriate safeguards including the use of Standard Contractual Clauses.
Our surveys are conducted using SurveyMonkey. SurveyMonkey’s servers are located in the United States. Any transfers which take place outside of the EEA are subject to appropriate safeguards including the use of Standard Contractual Clauses.
Our website is hosted on Amazon Web Services (AWS) servers and may transfer data outside the EEA. Any transfers which take place outside of the EEA are subject to appropriate safeguards including the use of Standard Contractual Clauses.
The Pensions Authority uses Microsoft Teams for virtual engagement both internally and externally.
How long we keep your personal data
We will retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.