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 our website, including the News by Email service
  • through the Trustee eLearning system
  • when conducting consultations and customer 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 which include:
    • registration of occupational pension schemes
    • PRSA supervision including collection of PRSA data from PRSA providers
    • compliance activities including:
      - supervision of Pensions Act requirements
      - requests for information from regulated entities
      - audits of regulated entities
      - investigations of regulated entities
      - prosecutions of regulated entities
  • information services to the public which include:
    • providing responses to queries on pensions matters
    • conducting customer 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 subjectsCategories of personal data includesLawful basis for processing
Regulated entities

(including scheme trustees, Registered Administrators, employers and PRSA providers)

• Identity 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 dataThe 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 dataSubscribers 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.

* 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 the data subjects 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 partyReasons for sharing data
RevenueTo 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 Employment Affairs and Social ProtectionTo assist and report to our parent department, as required.
Financial Services and Pensions OmbudsmanTo refer investigation cases where there is a legislative basis to do so.
Other regulators or supervisory authoritiesWhere 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)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. Google is certified under the EU-US Privacy Shield Framework.

Our News by Email service is managed using MailChimp. MailChimp’s servers are located in the United States. MailChimp is certified under the EU-US Privacy Shield Framework.

Our website is hosted on Amazon Web Services (AWS) servers and may transfer data outside the EEA. AWS is certified under the EU-EU Privacy Shield Framework.

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.

Your legal rights

Under certain circumstances, you have rights under Data Protection Laws in relation to your personal data as set out below:

Access to your personal data

You have the right to request a copy of the personal data we hold about you together with other information about our processing of that personal data (known as a “subject access request”).

Correction of your personal data

You have the right to request that any incomplete or inaccurate data we hold about you is corrected or if we have incomplete information you may request that we update the information so that it is complete. We may need to verify the accuracy of the new data you provide to us.

Erasure of your personal data

You have the right to request us to delete or remove personal data that we hold about you. We may not be able to comply with your request of erasure for specific legal reasons, which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data

You have the right to object to our processing of your personal data for particular purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Restriction of processing your personal data

You have the right to request that we no longer process your personal data in certain circumstances.

Transfer of your personal data

You have the right to request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format.

Withdrawal of consent

You may withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.

Exercising your rights

If you wish to access your data please fill out the Subject Access Request form that is available under Related Files below.

Information we require to process requests

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Fees

Usually you will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

Response times

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Contact details for further information

Data Protection Officer

The Authority’s data protection officer (DPO) has responsibility for ensuring compliance with Data Protection Laws. Individuals who have questions on the Authority’s compliance with Data Protection Laws can contact the DPO.

The Pensions Authority
Verschoyle House
28/30 Lower Mount Street
Dublin 2, D02 KX27
Email: dpo@pensionsauthority.ie
Phone: (01) 613 1900

The Data Protection Commission

The Data Protection Commission is responsible for upholding the rights of individuals under Data Protection Laws. Individuals who feel their rights are being infringed can complain to the Data Protection Commission, who will investigate the matter, and take whatever steps may be necessary to resolve it.

Canal House
Station Road
Portarlington
Co. Laois, R32 AP23
www.dataprotection.ie
Email: info@dataprotection.ie
Phone: 1 890 252231