Data Protection Notice
This data protection notice sets out details of the personal data relating to you that is collected by the AIB Group Defined Contribution Scheme (the “Scheme”) and how that personal data is processed.
AIB DC Pensions (Ireland) Limited is the controller of personal data collected by the Scheme. If you have any questions about our use of your personal data, please contact us by email at firstname.lastname@example.org or by post addressed to:
FAO: Trustee Secretary for the AIB Group Defined Contribution Scheme
Personal Data that We Process
The personal data that we process about you will depend on your relationship with the Scheme. This notice sets out details of personal data that is collected in relation to the following categories of people:
- Active members (i.e. a person who is currently in employment with a relevant AIB Group company).
- Deferred members (i.e. someone who has left employment with an AIB Group company, but retains a right to receive benefits at a future date).
- Former members (i.e. a member who has reached normal retirement age and has used the value of their retirement account to purchase benefits outside the Scheme such as an annuity or an approved retirement fund (ARF)).
- Non-members who may or will receive benefits from the Scheme.
- Non-members who have received benefits from the Scheme.
We may collect and process the following information in relation to all of these categories of people:
- Biographical Details – We collect your name, previous names, gender, spouse’s name, date of birth, spouse’s date of birth, and your marital status and history.
- Contact Details – We collect your home address, email address and telephone number.
- Status – We record your status in relation to the Scheme (e.g. active member, deferred member, pensioner etc.).
- Bank Details – We keep details of bank accounts in order to make payments, including BIC/IBAN numbers, payee name and address, and bank name and address.
For active members, deferred members, and former members we may collect and process the following additional information:
- Employment History – We collect the date that you joined the Scheme, the date you joined the company to which the Scheme is connected, the date you left the company/retired, details of your employment (e.g. job title, department, job class etc.), periods of service (e.g. details of part time work, leaves of absence, maternity leave, job share details etc.).
- Salary and Contributions – We collect details of your salary and contributions to the Scheme, including employer contributions, transfers from other schemes and additional voluntary contributions.
- Disability Benefits – Where a claim for disability benefits are made, we record the claim start and end date, the status of the claim, any special terms that apply, and details of the claim itself.
- Transfer in Benefits – Where you transfer from another scheme we record details of the scheme you transferred from, the amount that transfers into the Scheme, service dates for previous service and any additional service/benefits that you have purchased.
- Benefits under the AIB Group Irish Pension Scheme – In order to produce an amalgamated annual benefits statement, we receive details of your entitlement under the AIB Group Irish Pension Scheme.
- Your PPS Number.
For active members, deferred members, former members, and non-members who will or may receive benefits from the Scheme we may collect and process the following additional information:
- Death Benefits – We record details of who you have nominated to receive death benefits, including their name, address and their relationship to you, beneficiary payment details and any special terms that apply.
For deferred members and former members we collect and process the following additional information:
- Benefits on Leaving/Retirement – When you leave the Scheme we keep details of the date you leave/retirement date, any dependant’s date of birth, any deferred or preserved benefits that you hold, benefit details that you are entitled to, any transfer of funds or refunds that are taken (including tax free cash), and details of pension benefit amount/annuity purchased.
Sources of Personal Data
We collect personal data from you directly, and from the following sources:
- Employer – Where the personal data above relates to your employment, we will generally receive it directly from your employer where you have not provided it to us yourself.
- AIB Group Irish Pension Scheme – We receive details of your entitlement under the AIB Group Irish Pension Scheme in order to produce an amalgamated annual benefits statement.
- Government Bodies – We may receive certain data from government agencies, such as in relation to your tax status or where we seek assistance in tracing deferred members.
- Court Services – Where a pensions adjustment order is in place we will receive details of this from the Courts Services.
- Publically Available Sources – Where we are seeking to trace deferred members we will consult publically available sources of information.
Purposes of Processing and Legal Basis
We process your personal data in order to administer the Scheme and comply with our obligations under the law in relation to pensions in Ireland and the trust deed that established the Scheme. This involves the following processing of personal data:
- General Administration – We will process your personal data in order to operate the Scheme on a day to day basis, including making actuarial calculations. We will also process your personal data in order to respond to any queries you may have in relation to the Scheme. We process such personal data on the basis of our legitimate interests in operating the Scheme for the benefit of all members and beneficiaries.
- Calculating and Paying Benefits – We will process your personal data in order to calculate what benefits you are entitled to under the Scheme and to make payments of those benefits. We process such personal data on the basis of our legitimate interests in operating the Scheme for the benefit of all members and beneficiaries.
- Purchasing ARFs and Annuities – Where we pass details onto service providers in connection with your purchase of ARFs and Annuities at your request, we will do this on the basis of your consent. You can withdraw your consent to our processing of your personal data for these purposes at any time by contacting us through the same method you used to provide us with your instructions, or using the contact details above, but please note that this would mean that we would no longer be able to comply with your instructions.
- Assessing Eligibility – We will process your personal data in order to assess your eligibility under the Scheme for benefits, including disability benefits. We process such personal data on the basis of our legitimate interests in operating the Scheme for the benefit of all members and beneficiaries. Where we process personal data in relation to your health in connection with a disability claim, we will process that personal data on the basis of the provisions of the Data Protection Act 2018 (when enacted) in relation to the processing of such data.
- Compliance – We will process your personal data in order to ensure that we comply with our legal requirements in relation to the operation of the Scheme, which includes engaging auditors to assist in assessing compliance. We process such personal data on the basis of our legitimate interests in operating the Scheme for the benefit of all members and beneficiaries, and to ensure compliance with our legal obligations.
Personal Data that We Require You to Provide
You are required to provide all of the information that we set out above in order for us to operate the Scheme. If you fail to provide the information above, you may not be able to avail of benefits under the Scheme.
Recipients of Data
We may disclose your personal data to various recipients in connection with the above purposes, including:
- Employer – We may provide your employer with any of the details that we hold about you in connection with your participation in the Scheme.
- Administrator – The registered administrator of the Scheme is Allied Irish Banks p.l.c. (“AIB”), who employ a third party service provider, Aon Hewitt (Ireland) Limited (“AON”), to operate the Scheme on our behalf. AIB and AON process all of the data referred to above.
- Consultants – We employ consultants to provide us with advice in connection with the operation of the Scheme, and in particular investment advice. In general consultants are provided with aggregated data in relation to members of the Scheme so that they can use this to provide us with assistance in analysing how the Scheme is functioning and to put in place plans for the future operation of the Scheme. This means that we do not routinely provide consultants with your name or address, so that they cannot link the data that they are provided with directly back to you.
- Actuary – The Scheme engages with an actuary in order to provide projections in relation to your potential income in retirement. These calculations are dependent on the status of members and beneficiaries, and therefore require the actuary to be given details about the members and beneficiaries.
- Auditors – We engage third party auditors in order to ensure that the Scheme is operating in compliance with applicable law. In the process of undertaking an audit the auditor will be given access to all of our data, and may therefore process your personal data in the context of undertaking the audit.
- Insurer – We engage the services of an insurance broker and insurance companies. These parties may require access to your personal data in order put in place a policy, and to process a claim that is made under a relevant insurance policy.
- Legal Advisors – We do not generally need to provide our legal advisors with personal data in relation to members and beneficiaries. However, there may be instances where there is a dispute with a member or beneficiary that requires us to get legal advice. In those circumstances, we will provide such personal data in relation to that member or beneficiary as is required in order to receive such legal advice.
- Service Providers – We engage various service providers, often through AIB and AON, who provide services to the Scheme to assist in its operation. These service providers include companies that provide company secretarial services, document storage and disposal, printing and mailing services and IT services. Where we engage a service provider, we ensure that they are subject to appropriate contractual obligations to protect your personal data, and that we do not give them access to personal data other than as required for them to provide their services.
- Government Bodies – Where required by law we will provide your personal data to relevant government bodies and regulatory authorities. These include the Courts Service, Pensions Authority, the Revenue Commissioners, the Financial Services & Pensions Ombudsman, Department of Social Protection and the Data Protection Commissioner.
- Medical Assessment – When you are sent for medical assessment in connection with your entitlement to benefits under the Scheme, we will provide your details to a medical assessor in order for them to make an appointment with you. The medical assessor then becomes the controller of the personal data that you provide as part of the assessment and only provides an assessment report back to us.
- Your Advisors and Service Providers – We will transfer your personal data to third parties at your request, including your advisors, AVC PRSA providers, providers of ARF and annuity products, and where you transfer out of the Scheme to another scheme. The personal data that we provide to these parties will be in accordance with your instructions.
In connection with the above we may transfer your personal data outside the European Economic Area, including to a jurisdiction which is not recognised by the European Commission as providing for an equivalent level of protection for personal data as is provided for in the European Union. If and to the extent that we do so, we will ensure that appropriate measures are in place to comply with our obligations under applicable law governing such transfers, which may include entering into a contract governing the transfer which contains the ‘standard contractual clauses’ approved for this purpose by the European Commission or, in respect of transfers to the United States of America, ensuring that the transfer is covered by the EU-US Privacy Shield framework.
Further details of the measures that we have taken in this regard are available from the Trustee Secretary on request, who can be contacted using the details set out above.
Due to the long term nature of the Scheme, and the possibility for queries regarding the operation of the Scheme arising at any point during your participation in the Scheme and your retirement, we will retain your personal data for the life of the Scheme, and thereafter for a period of 12 years in order to deal with any claims that might arise.
You have the following rights, in certain circumstances, in relation to your personal data:
- Right to access the data – You have the right to request a copy of the personal data that we hold about you, together with other information about our processing of that personal data.
- Right to rectification – You have the right to request that any inaccurate data that is held about you is corrected, or if we have incomplete information you may request that we update the information such that it is complete.
- Right to erasure – You have the right to request us to delete personal data that we hold about you. This is sometimes referred to as the right to be forgotten.
- Right to restriction of processing or to object to processing – You have the right to request that we no longer process your personal data for particular purposes, or to object to our processing of your personal data for particular purposes.
In order to exercise any of the rights set out above, please contact the Trustee Secretary using the contact details set out above.
Updates to your Personal Data
Please let us know as soon as possible if there are any changes to your personal details by contacting the Trustee Secretary using the contact details set out above.
You have the right to lodge a complaint with the Irish Data Protection Commission (see https://www.dataprotection.ie for more details).