PRIVACY POLICY

London Pensions Fund Authority Privacy Policy 

The London Pensions Fund Authority (LPFA) respects your privacy and is committed to protecting your personal data. 

Purpose of this Privacy Policy
This privacy statement sets out how the LPFA uses and protects any information that you give us including when visiting our website. Should we ask you to provide certain information by which you can be identified when using this website, then you can be assured that it will only be used in accordance with this privacy statement. LPFA may change this privacy statement from time to time by updating this page and it is advised that you check this page periodically to ensure that you are aware of any changes.

Data controller
LPFA is the data controller and is collectively referred to as ‘LPFA’, ‘we’, ‘us’ or ‘our’ in this Privacy Policy. We have a separate privacy policy when applying for LPFA career opportunities which may be accessed on LPFA’s website. LPFA is also a joint data controller with our pension administrator, Local Pensions Partnership Administration Ltd (LPPA) and the privacy policy regarding information we may jointly hold with LPPA can be found following this link: https://www.lppapensions.co.uk/information/privacy-policy/ 

Third-party links on LPFA’s website
LPFA’s website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy policies. When you leave our website, we encourage you to read the privacy policy of every website you visit.

Data Protection Officer
Should you have any questions in relation to this Privacy Policy or wish to exercise your legal data protection rights or make a complaint about the use of your personal information, you can contact Mark Anderson, Compliance and Regulation Manager, by email at: legal@lpfa.org.uk.

You can also make a complaint to the Information Commissioner’s Office by contacting the helpline number: 0303 123 1113 or visiting the ICO website: https://www.ico.org.uk for more information.

 How and where we may receive your personal information
We may collect and hold your personal information such as personal identifiers, contact details and other personal information which you either share with us or we directly obtain when:

• You contact or correspond with us by post, phone and email 
• You request information from us 
• You provide us with information we have requested 
• You use our website, post comments on our website or via social media 
• You report a problem with our website 
• You apply for a job 
• You attend our events 
• You interact with us at third-party events 
• You subscribe for blog alerts and bulletins 
• You sign up to receive news and updates from us 
• You participate in our surveys and questionnaires, etc. 
• You provide us with feedback, opinions and/or comments regarding the website or our services 
• You have a pension matter that is shared with us directly or through our pension administrator, LPPA. 
• You make a complaint 

Data we indirectly gather about you:
We use Google analytics which may collect information about your computer including details of your usage including the date, time, location, or duration of the usage as well as certain technical information, for example:

• The type of device (and its unique device identifier) you use to access the website 
• The internet protocol (IP) address used to connect your device to the internet 
• Your login information and browser type and version 
• Time zone setting, browser plug-in types and versions 
• Operating system and mobile network information 
• The full Uniform Resource Locators (URL) 
• Clickstream to, through and from the website 
• Pages you viewed, page response times 
• Download errors 
• Length of visits to certain pages 
• Page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page 

How we store your information
We are committed to ensuring that your information is kept secure. We have put in place suitable physical and electronic systems, controls and procedures to safeguard the information we collect in order to prevent unauthorised access or disclosure. We only keep personal information for as long as is necessary and will dispose of your information securely. We do not collect or retain excessive amounts of data and we protect personal data from loss, misuse, unauthorised access or disclosure.

Our legal basis for processing your personal information
The legal bases we may rely on for processing your personal information are:

• We have a legitimate interest when processing your information as a pension member, an employee and for website security purposes. 
• Your consent is required when processing anonymised data for analytics purposes; and when you take part in surveys, newsletters, questionnaires and other engagement activities. 
• We have a legal obligation to fulfil our responsibilities as an Administering Authority or employer. 
• We may need to perform a public task as a public body in order to fulfil our functions and powers. 
• We have contractual obligations to you regard to the pension fund as the Administering Authority. 

Sharing your information
If you are a member of our pension scheme or looking to join the scheme, we may share your personal information with our pension administrator, LPPA, the scheme employers, other service providers and our advisers. Your personal information will not be shared with third parties for marketing purposes without your express permission and we will not sell or rent your data to third parties. We will also share your personal information when we are required to do so by law, or to prevent fraud or any other crime.

Your data protection rights
Under data protection law, you have rights including:

• Your right of access - You have the right to ask us for copies of your personal information. 
• Your right to rectification - You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
• Your right to erasure - You have the right to ask us to erase your personal information in certain circumstances. 
• Your right to restriction of processing - You have the right to ask us to restrict the processing of your personal information in certain circumstances. 
• Your right to object to processing - You have the right to object to the processing of your personal information in certain circumstances. 
• Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances. 

For more information about your legal rights please visit www.ico.org.uk 

Copyright
Unless otherwise stated, the LPFA owns the copyright and other intellectual property rights in this website and all material published within it. In accordance with the licence terms below:

• You may save and print copies of extracts of this website for your personal use. 
• You may save a copy of all documents that can be downloaded from our website. 
• You may pass on a copy of a website extract or downloaded document from our website to a third-party individual including others within your organisation, provided that: 
• You acknowledge that the extract or document came from the LPFA’s website, including the website address and the date it was accessed. 
• You do not pass off the extract or document as your own work. 
• You inform the third party that they too must comply with these conditions. 

We may revise, modify or withdraw any website content including documents at any time without prior notice. 

Third-party links
Links to external websites are provided for information purposes only. Accessing an external website makes you subject to the policies of that site. The LPFA assumes no responsibility for any decisions made based on information provided on external sites. The inclusion of links to external websites does not imply endorsement or support by the LPFA of the content, products, services or viewpoints found.