Reinsurance privacy notice

‘Rothesay’ is the trading name for Rothesay Life Plc, an insurance company established in the UK with company registration number 06127279 and ICO registration Z1003678. We are authorised in the UK by the Prudential Regulation Authority and regulated by the Financial Conduct Authority and the Prudential Regulation Authority. Our registered office address is The Post Building, 100 Museum Street, London WC1A 1PB.

This privacy notice applies where your insurer has entered into a reinsurance contract with Rothesay in respect of your policy (or a policy held by the trustees of your scheme) and as a result we process your personal data.

We are a controller under data protection laws. This privacy notice explains how we use and look after your personal data. This privacy notice also tells you about your privacy rights and how the law protects you. 

This privacy notice contains information about:

• The personal data that we process as a controller
• Where the personal data has been obtained
• The reasons why we process your personal data and the lawful basis we use to do so
• The security measures that we have in place to keep your personal data secure
• The length of time we store your personal data for
• The organisations, or categories of organisation, with whom we might share your personal data
• International transfers of your personal data
• The rights you have under data protection laws in relation to our processing of your personal data

Please note that we may change this privacy notice from time to time.

To request a printed copy of this privacy notice please contact us using the contact details contained in the part of this privacy notice headed Contact details.

The categories of personal data we process include the following:

1. Insurance member personal information: Personal data relating to each individual who has pension benefits reinsured under a reinsurance contract, which may include:

• Name
• Address (email and postal)
• Date of birth
• Gender
• National Insurance number
• Policy number and other reference numbers
• Marital status, dependants and next of kin
• Retirement age
• Retirement date

2. Insurance member employment information: Personal data relating to the employment relevant to the benefits of each individual who has pension benefits reinsured under a reinsurance contract, which may include:

• Employer (or former employer) name
• Job title, job codes and job location
• Pension benefits

3. Sensitive personal data: This includes the processing of health information relating to individuals who have pension benefits reinsured under a reinsurance contract, to the extent strictly necessary to determine eligibility for any ill-health benefits.

4. Beneficiary data:The names of individuals who, on the death of an individual who has pension benefits reinsured under a reinsurance contract, are potentially entitled to any death benefits which are reinsured under that contract.

Additional personal data concerning you may be received from your insurer in cases where they believe it is necessary to enable us to service your needs.

Personal data will usually be collected from your insurer.

There will be instances where we collect personal data from other sources. This includes:

1. Tracing agencies and mortality screening companies

We engage tracing agencies to check whether we hold the correct address for an individual who has benefits reinsured under a reinsurance contract.

We engage mortality screening companies to check whether an individual who has benefits reinsured under a reinsurance contract is alive.

2 . Financial sanctions screening companies

We engage financial sanctions screening companies to ensure that we do not break laws and regulations by making a payment in respect of an individual who:

• appears on a list of financial sanctions targets: or
• is subject to a sanctions programme as determined by any government or law enforcement agency

The table below provides details of the purpose and the lawful bases upon which we process personal data.

We may also process personal data including sensitive personal data to comply with other laws, regulations or criminal reporting requirements that we are subject to. This includes compliance with law enforcement agency procedures in connection with various investigations and compliance with any requirement to prevent or detect unlawful acts.

Our commitment to corporate security is demonstrated through the implementation of policies, controls and procedures, which are externally certified and audited to the international information security standard, ISO 27001:2013.

Our security policies, controls and procedures are regularly reviewed and updated so that we maintain good practices across our business to keep your information safe.

We have contractual arrangements in place with all of our service providers who process personal data which are compliant with data protection laws. We regularly check that our service providers are complying with their contractual commitments. This includes assessing and reporting on our service providers’ information security controls to check their compliance using questionnaires and/or on-site audits.

We will only keep your personal data for so long as we reasonably require it and, in any event, only for as long as our internal rules and polices allow us to fulfil our business or legal and regulatory obligations (including obligations under the underlying policies where such policies have transferred to us pursuant to a Part VII transfer). This will usually be up to 15 years following the end of the relevant reinsurance contract with the insurer. 

We share personal data with a variety of other companies to operate our business. However, we only share the personal data that those companies need to provide their services to us.

We have detailed the types of companies with whom we currently share personal data below. 

Processors with whom we share personal data

For these companies, we determine the purposes for which the personal data we pass to them is processed and they should not process that personal data other than in accordance with our written instructions. Processors with whom we share personal data:

1.  Third Party Administrators

We use specialist third party pension administration companies to help us administer our pension annuity policies. This enables us to meet our obligations in accordance with the terms of those policies. To enable them to do this, we need to provide them with all personal data that is relevant for this purpose.

Currently, we engage as administrators, companies trading as:

• Capita Employee Benefits Limited
• Aptia UK Limited
• Towers Watson Limited

2. Tracing agencies, mortality screening companies and financial sanctions screening companies

We may use these companies in order to check one or both of the following:

• Whether an individual who has pension benefits reinsured under a reinsurance contract is alive and that the individual’s address remains current
• Whether an individual appears on a list of financial sanctions targets or is subject to a sanction programme.

3. IT service providers
Our main IT infrastructure and core software is provided by Goldman Sachs Group, Inc.. This means that personal data we process is stored on Goldman Sachs’ IT systems.

4. Other service providers to our business
Other companies who process personal data on our behalf include those who provide day-to-day operational business services such as emails, archiving, document scanning and copying, document destruction and printing.

Controllers with whom we share personal data

For these companies, we do not determine the purposes for which the personal data we pass to them is processed once it is shared. To understand how the other controllers process your personal data , you should refer to their privacy notices. Controllers with whom we share personal data:

1. Reinsurers

We provide information about the liabilities insured under our reinsurance contracts to third party reinsurers with whom we reinsure some of the risks to which we are exposed under those contracts. The main such risk is that individuals who have pension benefits reinsured under our reinsurance contracts live longer than we anticipated. You can request a list of reinsurers to whom we have disclosed your personal data using the details contained in the part of this privacy notice headed Contact details.

2. Trend analysis providers

We provide information to, and use services provided by, third parties to analyse how long people in the UK live and other demographic trends. We use information provided to us by these third parties in connection with the performance of our business. For example, we use it to help us to estimate how long individuals insured under our reinsurance contracts are likely to live in order to understand our liabilities in respect of our current and future policyholders.

3. Professional advisers

We sometimes have to share personal data with our professional advisers (including accountants and lawyers) where it is required for the purposes of their advice.

4. Regulators, law enforcement and auditors

We will share personal data when requested by regulators, law enforcement agencies or other third parties to comply obligations imposed on us by laws and regulations.

Where personal data is transferred to and processed in a country outside of the UK or the EEA (as applicable), we take steps to provide appropriate safeguards to protect your personal data, including by entering into approved standard contractual clauses obliging recipients to protect your personal data and only transferring personal data to the extent that an adequate level of protection for the rights and freedoms of data subjects in relation to the processing of personal data is ensured in compliance with data protection laws.

If you want further information on the specific mechanisms used by us when transferring your personal data outside of the UK or EEA, please contact us using the details contained in the part of this privacy notice headed Contact details.

Under certain circumstances, you have the following rights under data protection law:

• The right of access to personal data relating to you (known as Subject Access Requests)
• The right to correct any mistakes in your personal data
• The right to require us to delete your personal data
• The right to restrict our processing of your personal data
• The right to object to us processing your personal data, including for marketing purposes
• The right to have your personal data provided to another controller

How to exercise your rights

If you wish to exercise any of your rights, please contact us using the details contained in the part of this privacy notice headed Contact details.

You can also make a request to exercise your rights via your insurer, or the trustees of your scheme (if applicable). If you choose to do this, your insurer will notify us and we will respond to your request. When seeking to exercise any of your rights, please ensure that your request contains sufficient information and supporting documentation to enable us to consider your request and take appropriate action. There are exemptions that apply to some of your rights. If any of these are applicable such that we are unable to comply with your request, we will confirm this to you when responding to your request and apply those exemptions in accordance with data protection laws.

How to contact us regarding this privacy notice

You may want to contact us to:

• Ask any questions you have in relation to the information contained in this privacy notice
• Exercise any of your rights under the data protection laws
• Request a printed copy of this privacy notice printed in large print or braille
• Request an audio version of this privacy notice
• Make a complaint (see below)

To contact us you can email our Data Protection Officer (DPO) at dpo@rothesay.com or write to:

Data Protection Team, Rothesay Life Plc, The Post Building, 100 Museum Street, London WC1A 1PB

If you live within the European Union, you can also contact our European representative. Their details are as follows:

Address: Bird & Bird GDPR Representative Services SRL, Avenue Louise 235, 1050 Bruxelles, Belgium.

Or email: EUrepresentative.Rothesay@twobirds.com

How to make a complaint

If you have a problem or concern relating to the ways we process your personal data or the contents of this privacy notice, please contact us in the first instance.

We hope that we will be able to address the problem or concern to your satisfaction. However, you also have the right to make a complaint to the Information Commissioner’s Office. The process for making a complaint to the Information Commissioner’s Office is available here: 

www.ico.org.uk/make-a-complaint

Their contact details are as follows:

Address: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

Or phone: 0303 123 1113

ico.org.uk