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Privacy Notice

IMI Retirement Savings Plan (the "Plan")

This notice is for members and beneficiaries of the Plan. It has been prepared by IMI Pensions Trust Limited ("Trustee", or "we") in its capacity as Trustee of the Plan.

This notice will also be made available online on the Plan's website www.imipensions.com.

Why we are providing this notice to you

As the Trustee of the Plan we hold certain information about you ("personal data"). We are required by law to give you specified information about the personal data we hold about you, how we use it, and the safeguards that are in place to protect it. This notice is designed to give you that information.

Why we hold your personal data

The Trustee processes personal data about you, in its role as controller, for the proper handling of all matters relating to the Plan, including its administration and management, calculating, securing and paying benefits and managing liabilities in relation to it. Further information about how we process this data is provided under the heading "How we will use your personal data" below.

The legal basis for our use of your personal data will generally be one or more of the following:

  1. We need to process your personal data to satisfy our legal obligations as Trustee of the Plan
  2. We need to process your personal data for the legitimate interests of: administering and managing the Plan and liabilities under it; calculating, securing and paying benefits; and performing our obligations and exercising any rights, duties and discretions the Trustee has in relation to the Plan
  3. The processing is necessary for the performance of a contract to which you are party, or in order to take steps at your request prior to entering into a contract

We obtain some of this personal data directly from you. We may also obtain data from the Plan's sponsoring employer(s) that currently employs or previously employed you (for example salary information), from a member of the Plan (where you are or could be a beneficiary of the Plan as a consequence of that person's membership), and from a variety of other sources including public databases, our advisers, and government or regulatory bodies.

If your benefits under the Plan have been transferred in from one of the other pension schemes sponsored by IMI, including the FCX Retirement Benefits Scheme or the IMI 2014 Deferred Fund, we also obtain personal data from the trustees, administrators and/or sponsoring employers of that pension scheme in relation to your benefits that have been transferred into the Plan from that other pension scheme.

Where we obtain information concerning certain "special categories" of particularly sensitive data, such as health information, extra protections apply under the data protection legislation. We will only process your personal data falling within one of the special categories with your consent, unless we can lawfully process this data for another reason permitted by that legislation. You have the right to withdraw your consent to the processing at any time by notifying the Trustee in writing. However, if you do not give consent, or subsequently withdraw it, the Trustee may not be able to process the relevant information to make decisions based on it, including decisions regarding the payment of your benefits.

Where you have provided us with personal data about other individuals, such as family members, dependants or potential beneficiaries under the Plan, please ensure that those individuals are aware of the information contained within this notice.

What personal data we hold and how we obtain it

The types of personal data we hold and process about you can include:

How we will use your personal data

We may use this data to deal with all matters relating to the Plan, including its administration and management. This can include the processing of your personal data for all or any of the following purposes:

Organisations that we may share your personal data with

From time to time we will share your personal data with our advisers and service providers so that they can help us carry out our duties, rights and discretions in relation to the Plan. These include the following:

In some instances advisers and service providers will be controllers in their own right and will be directly responsible to you for their use of your personal data. They may be obliged under the data protection legislation to provide you with additional information regarding the personal data that they hold about you and how and why they process that data. Further information may be provided to you in a separate notice or may be obtained from the advisers and service providers directly, for example, via their websites.

Whenever one of our advisers or service providers acts as a joint controller with us in respect of your personal data, because we jointly determine the purposes and means of processing it, we will agree with them how we are each going to meet our respective and collective obligations under the data protection legislation. If you would like more information about how such an arrangement works please contact us using the contact details below.

We may also provide some of your data to the Plan's sponsoring employers and group companies of those employers, their advisers and potential purchasers of their businesses.

In addition, where we make Plan investments or seek to provide benefits for Plan members in other ways, such as through the use of insurance or pension scheme mergers, then we may need to share personal data with providers of investments, insurers and other pension scheme operators. In each case we will only do this to the extent that we consider the information is reasonably required for these purposes.

The advisers, service providers and organisations referred to in the paragraphs above may use personal data to perform their functions as well as for statistical and financial modelling (such as calculating expected average benefit costs and mortality rates) and planning, business administration and regulatory purposes. They may also pass the data to other third parties (for example, insurers may pass personal data to other insurance companies for the purpose of obtaining reinsurance), to the extent they consider the information is reasonably required for a legitimate purpose.

Where requested or if we consider that it is reasonably required, we may also provide your personal data to government bodies and dispute resolution and law enforcement organisations, including the courts, the Pensions Regulator, the Pensions Ombudsman, the Pension Protection Fund and Her Majesty's Revenue and Customs (HMRC). They may then use the data to carry out their functions.

In some cases recipients of your personal data may be outside the UK. This means your personal data may be transferred outside the EEA to a jurisdiction that may not offer an equivalent level of protection as is required by EEA countries. If this occurs, appropriate safeguards must be implemented with a view to protecting your data in accordance with applicable laws. Please contact the Trustee, using the contact details below, if you want information about the safeguards that are currently in place.

How long we keep your personal data

We will only keep your personal data for as long as we need to in order to fulfil the purposes identified above. In practice this means that we will retain your data for such period as you (or any beneficiary who receives benefits after your death) are entitled to benefits from the Plan and for so long afterwards as may be required to deal with any questions, complaints or claims that we may receive about our administration of the Plan. We may also retain your data for a longer period to comply with our legal and regulatory obligations.

Your rights

You have a right to access and obtain a copy of the personal data that the Trustee hold about you and to ask the Trustee to correct your personal data if there are any errors or it is out of date. In some circumstances you may also have a right to ask the Trustee to restrict the processing of your personal data, to object to processing or to transfer or erase your personal data. You can obtain further information about these rights from the Information Commissioner's Office at: www.ico.org.uk or via their telephone helpline (0303 123 1113).

If you wish to exercise any of these rights or have any queries or concerns regarding the processing of your personal data, please contact the Trustee using the contact details provided below. You also have the right to lodge a complaint in relation to this privacy notice or the Trustee's processing activities with the Information Commissioner's Office, you can do this via the ICO's website or telephone helpline.

The personal data we hold about you is used to administer your Plan benefits and we may from time to time ask for further information from you for this purpose. If you do not provide such information, or ask that the personal data we already hold is deleted or restricted, this may affect the payment of benefits from the Plan. In some cases it could mean the Trustee is unable to put your pension into payment or has to stop your pension (if already in payment).

Updates

We may update this notice periodically. Where we do this we will inform you of the changes and the date on which the changes take effect.

Contacting us

Please contact the Trustee for further information using the contact details below:

IMI Pensions Administration Team
Willis Towers Watson Ltd
PO Box 545
Redhill
Surrey
RH1 1YX

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