Old Mutual SuperFund Unclaimed Benefit Preservation Fund Member and Beneficiary Privacy Notice
This Privacy Notice applies to members and beneficiaries of the Old Mutual SuperFund Unclaimed Benefit Preservation Fund.
The Old Mutual SuperFund Unclaimed Benefit Preservation Fund is committed to protecting your privacy and to ensure that your personal information is collected and used properly, lawfully and transparently in compliance with the Protection of Personal Information Act.
This Notice explains how we obtain, use and disclose your personal information and aims to inform you of your rights and how to exercise them.
This Notice sets out:
- Who we are
- What information we collect
- From where we collect information
- The purposes for which we use your information
- To whom we disclose your information
- How we safeguard your information
- Your rights to access, correct and delete information
- Changes to this Notice
- How to contact us
- The Information Regulator’s contact details
WHO WE ARE
In this Notice, “Old Mutual SuperFund Unclaimed Benefit Preservation Fund”, refers to the Old Mutual SuperFund Unclaimed Benefit Preservation Pension and Provident Funds.
WHAT INFORMATION DO WE COLLECT?
The information that we collect and process is information that we require to administer membership of and pay benefits from the Old Mutual SuperFund Unclaimed Benefit Preservation Fund and, depending on the purpose, may include contact detail and information about financial, medical or criminal matters. The type of information we collect will depend on the purpose for which it is collected and used. We will only collect information that we need for that purpose.
Website usage information is collected using “cookies” which allows us to collect internet visitor usage information. This includes information about how you logged on to our website, including your IP address, information about your visit, your device information and how you use our website. This will include the capture of your approximate location information. Please see the Cookies Policy on our website for further information on this.
FROM WHERE DO WE COLLECT YOUR INFORMATION?
We collect information directly from you, but also from third parties, including:
- Credit reference, fraud prevention, law enforcement and tracing agencies.
- Other insurers, retirement funds and retirement annuity funds to obtain claim related information.
- The Old Mutual Group for the purposes listed below, or when we believe it will enhance the services and products we can offer a member, but only where the member has not objected to such sharing. This includes supplementing the information that a member provides to us with information we receive from the Old Mutual Group in order to offer a member a more consistent and personalized experience in his/her interactions with us, and to ensure that we have updated member information.
We have a duty to take all reasonably practicable steps to ensure that personal information is complete, accurate, not misleading and updated on a regular basis. To achieve this, we will try to obtain personal information from you directly, and we would appreciate it if you would keep your personal information up to date and accurate. You can do so by contacting us at the numbers/addresses provided below. Where we are unable to obtain personal information from you directly, we will make use of verifiable independent third party data sources.
When you provide us with information about third parties (for example: a member’s spouse or children, persons that may be financially dependent on a member or a person that should be considered in the allocation of benefit payments), their personal information will be processed to issue a policy/pay a benefit and to pursue their or the Old Mutual SuperFund Unclaimed Benefit Preservation Fund’s legitimate interest. We will furthermore process personal information for other purposes set out in this Privacy Notice. You warrant that when you give us personal information about third parties, this information is accurate and correct and you have received their permission to share their personal information with us for the purposes set out in this Privacy Notice or any other related purposes. If you are giving consent for a person under 18 (a minor) you confirm that you are a competent person and that you have authority to give their consent on their behalf.
For what purposes do WE USE YOUR INFORMATION?
We will use your personal information only for the following purposes:
- To administer a member’s membership of the Old Mutual SuperFund Unclaimed Benefit Preservation Fund
- To process and pay benefits from the Old Mutual SuperFund Unclaimed Benefit Preservation Fund;
- To provide members with information about offerings that will support and enhance their retirement benefits;
- To provide products or services to you, to carry out the transaction you requested and to maintain our relationship;
- To assess and process claims;
- To conduct credit reference searches or verification;
- To confirm and verify your identity, address or banking details;
- To verify that you are an authorised user for security purposes;
- For maintaining the accuracy of your personal information;
- For operational purposes, and where applicable, credit scoring and assessment and credit management;
- For purposes of claim checks (e.g. the Industry Life and Claims Register);
- For the detection and prevention of fraud, crime, money laundering or other malpractice;
- To trace you where you are uncontactable;
- To conduct market or customer satisfaction research or for statistical analysis;
- For audit and record keeping purposes;
- For social responsibility purposes;
- In connection with legal proceedings.
We will also use your personal information to comply with legal and regulatory requirements or industry codes to which we subscribe or which apply to us, or when it is otherwise allowed by law (for example to protect Old Mutual SuperFund Unclaimed Benefit Preservation Fund’s interests).
We may also process your information, including personal and special personal information, to conduct sanction screening against all mandatory and non-mandatory sanctions lists, and we may communicate such personal information to local and international Regulatory Bodies as well as to other entities in the Old Mutual Group if you are matched to one of these sanctions lists.
DISCLOSURE OF INFORMATION
We may disclose your personal information to our service providers who are involved in the delivery of products or services to you. We have agreements in place to ensure that they comply with these privacy terms.
We may share your personal information with:
- Third parties for the purposes listed above, for example credit reference and fraud prevention, law enforcement and tracing agencies;
- Other insurers, retirement funds and retirement annuity funds to obtain claim related information;
- The Old Mutual Group for the purposes listed above, or when we believe it will enhance the services and products we can offer to a member, but only where the member has not objected to such sharing. This includes supplementing the information that a member provides to us with information we receive from the Old Mutual Group in order to offer a member a more consistent and personalized experience in his/her interactions with us, and to ensure that we have updated information.
- Your intermediary/broker when applicable.
We may also disclose your information:
- Where we have a duty or a right to disclose in terms of law or industry codes; or
- Where we believe it is necessary to protect our rights.
We are legally obliged to provide adequate protection for the personal information we hold and to stop unauthorised access and use of personal information. We will, on an ongoing basis, continue to review security controls and related processes to ensure that your personal information is secure.
Security policies and procedures cover:
- Physical security;
- Computer and network security;
- Access to personal information;
- Secure communications;
- Security in contracting out activities or functions;
- Retention and disposal of information;
- Acceptable usage of personal information;
- Governance and regulatory issues;
- Monitoring access and usage of personal information;
- Investigating and reacting to security incidents.
When we contract with third parties, we impose appropriate security, privacy and confidentiality obligations on them to ensure that personal information that we remain responsible for, is kept secure.
We may transfer your personal information to another country for processing or storage. We will ensure that anyone to whom we pass your personal information agrees to treat your information with the same level of protection as we are obliged to.
We will take all reasonable steps to confirm your identity when you exercise your rights.
Access to information
You have the right to request a copy of the personal information we hold about you. To do this, simply contact us at the numbers/addresses listed below and specify what information you would like.
Please note that any such access request may be subject to a payment of a legally allowable fee and we will let you know what it is at the time of your request.
Objection to processing
In certain cases you have the right to object to the processing of your personal information. You may do this by contacting us at the numbers / addresses provided below.
Correction of your information
You also have the right to ask us to update or correct your information. You may do this by contacting us at the numbers/addresses provided below.
Deletion of your information
You agree that we may keep your personal information until we destroy your information based on Old Mutual SuperFund Unclaimed Benefit Preservation Fund’s retention policy. You have the right to ask for deletion or destruction of your personal information – we will do that unless the law requires us to keep it or if we need it for legitimate business purposes. You may do this by contacting us at the numbers/addresses provided below.
Automated decision making
You agree that we may process your personal information by using automated means (without human intervention in the decision making process) to make a decision about you or your application for any product or service. You may query the decision made about you.
CHANGES TO THIS NOTICE
Please note that we may amend this Notice from time to time. Please check this website periodically to inform yourself of any changes.
HOW TO CONTACT US
If you have questions about this Notice or believe we have not adhered to it, or need further information about our privacy practices or wish to give or withdraw consent, exercise preferences or access or correct your personal information, please contact us at the following numbers/addresses:
- Service Centre: 0860 20 30 40