Privacy Notice
 
Aon Hewitt Limited provides services and products in relation to your employment and membership of your benefit scheme (“Online Benefits Services”), on behalf of your employer.
 
We are committed to protecting your privacy. This commitment reflects the value we place on earning and keeping the trust of our customers, business partners, and others who share their personal information with us.

What does this Privacy Notice do?
 
This Privacy Notice ("Notice") explains Aon Hewitt Limited's information processing practices. It applies to any personal information you provide to us and any personal information we collect from other sources in the provision of Online Benefits Services. This Notice is a statement of our practices and of your rights regarding your personal information. This is not a contractual document, and it does not create any rights or obligations on either party, beyond those which already exist under data protection laws.
 
This Notice does not apply to your use of a third party site linked to this Online Benefits platform (the “website”).
 
Who is responsible for your information?
 
Throughout this Notice, "Aon" refers to Aon Hewitt Limited including its affiliated companies and subsidiaries (also referred to as "we", "us", or "our").
 
We provide Online Benefits Services as a processor on behalf of and in accordance with the instructions of your employer which is a controller for the purposes of data protection laws. This means your employer remains primarily responsible for your information and we may re-direct a query about our use of your information to your employer. You should refer to your employer’s privacy notice for more information about their practices and your rights.
 
We have expressly indicated throughout this notice where information is collected by us as a controller (for example, information collected by cookies which we place on the website). For all other information, your employer is the controller and we are a processor.
 
When and how do we collect your information?
 
We collect personal information in the following ways:
  •  When we perform services for our clients, such as your employer. We may collect information from you, your employer or its service providers (such as payroll processors)
  •  When you register with or use the website, including third party sites linked to this website.
  •  When you provide updated information to us or our service providers (eg by telephone or post).
  •  If you contact us with a complaint or query.

What information do we collect?
 
Information you provide to us
 
When we provide the website, we may collect personal information such as:
  •   Basic personal data: including name, address, postcode, contact details;
  •   Unique identifiers: such as National Insurance Number or payroll number;
  •   Demographic information such as date of birth, age, gender, marital status;
  •   Employment information such as date of hire, employment status, pay history, tax withholding information, date of termination;
  •   Benefits programme participation and cover information such as benefit elections, pension entitlement information, beneficiary information, claims information, benefit plan account balances or accrued benefits, date of retirement and any relevant matters impacting your benefits such as voluntary contributions, or other adjustments;
  •   Financial information such as salary, tax code, third party deductions, bonus payments, benefits and entitlement data, national insurance contributions details;
  •   Where you provide sensitive personal information such as medical information such as in relation to life, health, or employee benefits programs sponsored by your employer; and where necessary in relation to ill-health early retirement and ill-health reviews to determine the benefits paid to you;

More information about the personal information collected, together with the purpose and legal basis for collecting the information is provided below.
 
We will not collect any sensitive personal information unless this is required. Sensitive personal information includes a number of types of data relating to: race or ethnic origin; political opinions; religious or other similar beliefs; trade union membership; physical or mental health; sexual life.
 
If you provide us with sensitive personal information, you understand and give your explicit consent that we may collect, use and disclose this information to appropriate third parties for the purposes described in this Notice. If you provide personal information about other individuals such as dependants, you must obtain their consent prior to your disclosure to us.
 
Information we collect over the website
 
For purposes of this Notice, "website" includes our mobile applications.
 
We may ask you for some or all of the following types of information when you register on the website, request services, manage your account, or access various content and features. We collect and use this information as a controller in our own right. This information includes, but is not limited to:
  •  Contact information, such as name, e-mail address, postal address, phone number and mobile number;
  •  User name, password, password reminder questions and password answers;
  •  Communication preferences, such as which newsletters you would like to receive;
  •  Your views on things like wellness, finance and retirement preferences and interests.

In some instances, we automatically collect certain types of information when you visit our websites and through e-mails that we may exchange. Automated technologies may include the use of web server logs to collect IP addresses, "cookies" and web beacons. Further information about our use of cookies can be found in our Cookie Notice.
 
Mobile Devices
 
If you access our website on your mobile telephone or mobile device, we may also collect your unique device identifier and mobile device IP address, as well as information about your device's operating system, mobile carrier and your location information. We may also ask you to consent to providing your mobile phone number (for example, so that we can send you SMS notifications). We collect and use this information as a controller in our own right.
 
How do we use your personal information?
 
The following is a summary of the purposes for which we use personal information. More information about the personal information collected for each of our services, together with the purpose and legal basis for collecting the information will be provided to you below.
 
a) Provision of website: to make the online benefits platform available to you, including providing links to other websites and displaying information from other providers;
 
b) Scheme Management: to help our clients run their benefit arrangements.
 
c) Regulatory Compliance: for meeting on-going regulatory, legal and compliance obligations including assisting with investigations or prevention of crime, providing you with updated versions of this Privacy Notice (where required);
 
d) Process and service improvement: to maintain and improve processes used in running the scheme (for example, automated benefit calculation routines), products or services and uses of technology, including testing and upgrading of systems;
 
e) Anonymisation: we will anonymise personal information (such that it can no longer be reidentified) in order that it can be used with other data for data analysis, modelling, benchmarking and research purposes. We may share aggregated and anonymised data with third parties provided that we shall not publish externally or otherwise disclose any information which might reasonably identify you;
 
f) Benchmarking, Modelling & Analysis: personal information will (in some instances in identifiable form, in others anonymous form) be processed for data analysis, modelling, benchmarking, and research purposes in order to improve understanding of life expectancy and other demographic aspects relevant for assessing pensions and insured liabilities. We may share limited identifiable data with third party agencies such as existence tracing providers to support these purposes. We will not otherwise publish externally or otherwise disclose any information which might reasonably identify you.

If we wish to use your personal information for a purpose which is not compatible with the purpose for which it was collected for, we will request your consent. In all cases, we balance our legal use of your personal information with your interests, rights, and freedoms in accordance with applicable laws and regulations to make sure that your personal information is not subject to unnecessary risk.
 
Legal basis
 
All processing (i.e. use) of your personal information is justified by a "lawful basis" for processing.
 
As a processor we process your information solely in accordance with the contractual obligations agreed with your employer.
 
You should refer to your employer’s privacy notices for full details of the legal basis relied upon by your employer. The types of legal basis which may be relied upon by your employer are as follows:
 
a. Necessary to pursue your employer’s legitimate commercial interests ensuring that the processing does not infringe the rights and freedoms conferred to you under applicable data privacy law;
 
b. Pursuant to legal or regulatory obligations, including requirements to make any disclosures to authorities, regulators or government bodies (including HMRC);
 
c. Necessary for performance of a contract: where necessary to take steps to fulfil obligations in accordance with the terms of your pension scheme agreement or employment contract and website terms of use; and
 
d. In limited circumstances, necessary for statistical purposes e.g. to improve understanding of benefit trends and other demographic aspects, appropriate steps to ensure that any output of statistical analyses will not include personal information which might reasonably identify you.
 
e. In limited circumstances, processed with your consent, for example where you are required to provide sensitive information such as medical details to process a claim, or where your prior consent is required in order to send you marketing communications. Before collecting and/or using any personal information, or criminal record data, a lawful basis will be established which will allow use of that information. This basis will typically be:
  •  your explicit consent;
  •  the establishment, exercise or defense by us or third parties of legal claims; or
  •  a context specific exemption provided for under local laws of EU Member States and other countries implementing the GDPR, such as in relation to the processing of personal data for insurance purposes, or for determining benefits under an occupational pension scheme.

How long do we retain your personal information?
 
How long we retain your personal information depends on our instructions from your employer, as the controller. Your employer's retention practices will, in part, be determined by the purpose for which your information was obtained and its nature. We will keep your personal information for no more than the time required to fulfil the purposes described in this privacy notice unless a longer retention period is permitted by law. We have implemented appropriate measures to ensure your personal information is securely destroyed in a timely and consistent manner when instructed by your employer.
 
In specific circumstances we may store your personal information for longer periods of time where either we or your employer is under a legal obligation to do so that we have an accurate record of your dealings with us in the event of any complaints or challenges, or if we reasonably believe there is a prospect of litigation relating to your personal information or dealings.
 
Do we disclose your personal information?
 
We will disclose your personal information in accordance with your employer’s instructions and authorisations, which may include the recipients described below:
 
a) Within Aon: We may share your personal information with other Aon entities, brands, divisions, and subsidiaries to serve you, including for the activities listed above.
 
b) Your employer, and their service providers such as pension administrators and payroll providers;
 
c) Business Partners: We disclose personal information to business partners who provide certain specialized services to us, or who co-operate with us on projects. These business partners operate as separate controllers, and are responsible for their own compliance with data protection laws. You should refer to their privacy notices for more information about their practices. Examples include:
  •   Banking and finance products - credit and fraud reporting agencies, debt collection agencies, insurers, reinsurers, and managed fund organizations for financial planning, investment products and trustee or custodial services in which you invest
  •   Insurance broking and insurance products - insurers, reinsurers, other insurance intermediaries, insurance reference bureaus, medical service providers, fraud detection agencies, our advisers such as loss adjusters, lawyers and accountants and others involved in the claims handling process

d) Authorised Service Providers: We may disclose your information to service providers we have retained (as processors) to perform services on our behalf. These service providers are contractually restricted from using or disclosing the information except as necessary to perform services on our behalf or to comply with legal requirements. These activities could include any of the processing activities that we carry out as described in the above section, ‘How we use your personal information.’ Examples include:
  •   Benefit providers who administer services that we provide to your employer;
  •   IT service providers who manage our IT and back office systems and telecommunications networks; and
  •   contact center providers.

These third parties appropriately safeguard your data, and their activities are limited to the purposes for which your data was provided.
 
e) Authorised third parties: third parties you have authorised us to share information with such as nominated beneficiaries or third party sites linked to this website;
 
f) Legal Requirements and Business Transfers: We may disclose personal information (i) if we are required to do so by law, legal process, statute, rule, regulation, or professional standard, or to respond to a subpoena, search warrant, or other legal request. (ii) in response to law enforcement authority or other government official requests, (iii) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss, (iv) in connection with an investigation of suspected or actual illegal activity or (v) in the event that we are subject to a merger or acquisition to the new owner of the business. Disclosure may also be required for company audits or to investigate a complaint or security threat.

Do we transfer your personal information across geographies?
 
We are a global organization and may transfer certain personal information across geographical borders to our, authorized service providers or business partners in other countries working on our behalf in accordance with applicable law. Our affiliates and third parties may be based locally or they may be overseas some of which have not been determined by the European Commission to have an adequate level of data protection.
 
When we do, we use a variety of legal mechanisms to help ensure your rights and protections travel with your data:
  • we ensure transfers within are covered by agreements based on the EU Commission's standard contractual clauses, which contractually oblige each member to ensure that personal information receives an adequate and consistent level of protection wherever it resides within;
  • where we transfer your personal information outside of us or to third parties who help provide our products and services, we obtain contractual commitments from them to protect your personal information. Some of these assurances are well recognized certification schemes like the EU - US Privacy Shield for the protection of personal information transferred from within the EU to the United States, or the standard contractual clauses; or
  • where we receive requests for information from law enforcement or regulators, we carefully validate these requests before any personal information are disclosed.

Examples of countries we transfer personal information to include, but are not limited to, the United States of America, the United Kingdom, Ireland, Poland, Singapore, India and the Philippines.
 
If you would like further information about whether your information will be disclosed to overseas recipients, please contact us as noted below. You also have a right to contact us for more information about the safeguards we have put in place (including a copy of relevant contractual commitments, which may be redacted for reasons of commercial confidentiality) to ensure the adequate protection of your personal information when this is transferred as mentioned above.
 
Do we have security measures in place to protect your information?
 
The security of your personal information is important to us and, in co-operation with your employer, we have agreed upon reasonable physical, technical and administrative security standards to protect personal information from loss, misuse, alteration or destruction. We protect your personal information against unauthorized access, use or disclosure, using security technologies and procedures, such as encryption and limited access. Only authorized individuals access your personal information, and they receive training about the importance of protecting personal information.
 
Our service providers and agents are contractually bound to maintain the confidentiality of personal information and may not use the information for any unauthorized purpose.
 
What choices do you have about your personal information?
 
We offer certain choices about how we communicate with you.
 
How can you update your communication preferences?
 
You can update your communications preferences after you log into your account on the website.
 
Other rights regarding your data
 
Subject to certain exemptions, and in some cases dependent upon the processing activity we are undertaking, you have certain rights in relation to your personal information.
 
As a controller your employer remains primarily responsible for your information and we may re-direct a query about our use of your information to them.
 
Where authorised by your employer to respond on their behalf to a request or query you make, we may ask you for additional information to confirm your identity and for security purposes, before disclosing the personal information requested to you.
 
Subject to your employer’s instructions, legal and other permissible considerations, we will make every reasonable effort to honour your request promptly or inform you if we require further information in order to fulfil your request.
 
We may not always be able to fully address your request, for example if it would impact the duty of confidentiality we owe to others or if we are legally entitled to deal with the request in a different way.
 
Right to Access
 
You have right to access personal information which we hold about you. If you have created a profile, you can access that information by visiting your account.
 
Right to Rectification
 
You have a right to request us to correct your personal information where it is inaccurate or out of date.
 
Right to be Forgotten (Right to Erasure)
 
You have the right under certain circumstances to have your personal information erased. Your information can only be erased if your data is no longer necessary for the purpose for which it was collected, and we have no other legal ground for processing the data.
 
Right to Restrict Processing
 
You have the right to restrict the processing of your personal information, but only where:
  •   its accuracy is contested, to allow us to verify its accuracy; or
  •   the processing is unlawful, but you do not want it erased; or
  •   it is no longer needed for the purposes for which it was collected, but we still need it to establish, exercise or defend legal claims; or
  •   you have exercised the right to object, and verification of overriding grounds is pending.

Right to Data Portability
 
You have the right to data portability, which requires your employer to provide personal information to you or another controller in a commonly used, machine readable format, but only where the processing of that information is based on (i) consent; or (ii) the performance of a contract to which you are a party.
 
Right to Object to Processing
 
You have the right to object the processing of your personal information at any time, but only where that processing is has our legitimate interests as its legal basis. If you raise an objection, your employer has an opportunity to demonstrate that it has compelling legitimate interests which override your rights and freedoms.
 
International Transfers
 
As noted above, you can ask to obtain a copy of, or reference to, the safeguards under which your personal information is transferred outside of the European Union.
 
Contact Us
 
If you have questions about this Privacy Notice or the privacy and security of your information, please send an email to: abc@def.com
 
If you have further questions, would like further information about our privacy and information handling practices, would like to discuss opt-outs or withdrawing consent, or would like to make a complaint about a breach of the law or this Privacy Notice, please contact the abc@def.com address. Alternatively, you have the right to contact your local Data Protection Authority. Our Data Protection Authority is the Information Commissioner’s Office (www.ico.org.uk).
 
You should also refer to your employer’s privacy notice for more information about their practices and your rights.
 
Changes to this Notice
 
We may update this Notice from time to time. When we do, we will post the current version on this site, and we will revise the version date located at the bottom of this page.
 
We encourage you to periodically review this Notice so that you will be aware of our privacy practices.
 
This Notice was last updated May 25, 2018.
 
 
 

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