This Privacy Notice describes how Phoenix collects and uses personal information and sensitive information relating to Phoenix People (see section 17 for definition of Phoenix People). This will include what information is collected, why we ask for it, and how we use it.
This document applies to all Phoenix People covered by the following legal entities:
- Pearl Group Management Services Limited (PGMS)
- Pearl Group Management Services Ireland (PGMSI)
- Pearl Group Services Limited (PGS)
- Pearl Group Holdings (No.1) Limited (PGH)
- Abbey Life Assurance Company Limited (ALAC)
The data controller processing your personal data as an employee will be your employing entity. Your contact for each data controller will be the Phoenix HR Team (See section 15 for contact details).
At Phoenix we are committed to:
- Processing your personal information fairly and in accordance with applicable regulations.
- Informing you about how we will use your personal information.
- Only collecting information from you when we need it for legitimate purposes, or for legal reasons.
- Ensuring that your personal information is adequate, relevant and not excessive for the purpose for which we collect it.
- Not keeping your personal information for longer than we need to.
- Keeping your personal information secure, and limiting the people who can access it.
- Ensuring that you know how to access your personal information and to exercise your legal rights, including keeping your information accurate and up to date.
- Ensuring any third parties we share your information with take appropriate steps to protect it.
The personal information we collect about you will depend on the nature of the role you carry out for us and your personal circumstances. Whilst the list below is not exhaustive, it sets out examples of the types of information which, depending on your role, we will collect about you:
|Type of Information||Example|
|Basic personal details||Name
Date of Birth
|Equal opportunities monitoring details||Ethnicity
Date of Birth
|Information to contact you at home or in an emergency||Home telephone number
Personal email address
|Information about your suitability to carry out your role and to work for Phoenix||CV
Phoenix online application form
References (Collected from your previous employer(s))
Right to work in the UK check (passport, visa)
Criminal record check (Collected from Experian)
Credit check (Collected from Disclosure Scotland and Disclosure Barring Service)
|Information to enable us to pay you||Bank account information
National Insurance Number
|Information required to access buildings and systems||CCTV footage
Image used for security passes
Monitoring security access to Phoenix premises
|Information about your terms of employment and information captured as part of your contract administration||Offer letter
Contract of employment
Annual Leave information
Bonus payment information
|Information relating to Phoenix People processes (performance management, capability, grievance, and disciplinary)||Minutes from interviews and meetings
|Any other information||For example, images from corporate events or information about beneficiaries and dependants in order to administer certain elements of your contract and benefits package.|
|Reason for collecting your data||Example of use|
|Recruitment||To assess your suitability to the role
To conduct screening, assessments, and interviews
To maintain communication during recruitment stage
|Pre-employment vetting||To carry out:
Criminal record checks
Previous employment reference checks (up to 6 years depending on the role)
|To administer your contract of employment and general HR or business administration purposes||Payroll
Completing company induction
Performance management and succession planning
Business travel and expenses
Flexible working arrangements
Adhering to Health & Safety good practice
Mandatory regulatory training
Visa renewal applications
Provision of references
|Security||Prevention and detection of crime through:
CCTV footage on all Phoenix sites
Oversight of access to systems and other Phoenix equipment in accordance with our Group policies and procedures
|To make Phoenix a better place to work||Diversity monitoring
Equal Opportunities monitoring
|Legal and Regulatory||Anything we are required or permitted to do to meet our regulatory and good governance obligations; to meet our legal obligations ( e.g. HMRC tax legislation compliance) and obligations we have in relation to the prevention and detection of crime (including fraud)|
There may be times where we need to obtain your explicit consent to collect and use your personal information (for example, when we process sensitive personal information for equal opportunities monitoring). If we ask for your consent to process your personal information, you may withdraw your consent at any time (see section 10).
We will only collect, use and share your information where we have a valid reason to do so. We have 3 main reasons for using your information:
Contract - to fulfil our obligations to you under your employment contract. In order to perform that contract we need certain information from you (e.g. contact details and bank account details).
Legal obligation - we may need certain information from you in order to meet our legal obligations (e.g. proof of identity to meet our anti-money laundering obligations, our health and safety obligations to you, or our obligations to a third party (e.g the taxation authorities))
To meet our legitimate interests in order to protect our business - (e.g we will undertake checks to safeguard our business and our people against criminal activity). When we process personal information to meet our legitimate interests we put in place robust safeguards to ensure that your privacy is protected and to ensure that our legitimate interests are not overridden by your interests or fundamental rights and freedoms.
|Who do we share information with?||Why|
|Third parties||We use a third party to support us with the administration of your contract, for example processing your salary and administering transactions through the HRSS system. Other third parties we use include providers of pension administration and flexible benefits, IT service providers to help us to manage our email and messaging services and analyse information; and training providers to help us support your learning and development needs.|
|Other companies within the Phoenix Group||We will share some information across The Phoenix Group as may be required for administration, analysis, and Group statutory reporting purposes|
|Anyone you ask us to||If you ask us to share your information e.g. providing a reference to a prospective employer, we will check with you to confirm that the person asking for information on your behalf has your authority to do so.|
|Regulatory, government and industry bodies e.g. HMRC
Fraud Prevention Organisations
Credit reference agencies
Law enforcement bodies
|To comply with our legal and regulatory obligations.|
|Those involved in any legal process including law enforcement authorities, courts, regulators, government authorities or other third parties||If a court requires us to disclose your information or if it needs to be disclosed as part of a legal process, or to enable us to meet a legal or regulatory obligation, or otherwise to protect our rights, or the rights of any third party.|
|Anyone in the future who may buy or merge with our business||If we merge with another company or if we are sold then we may need to share your information with the other party depending on the nature of the transaction|
|Information required to submit regulatory approvals (where required for your role, for example if you undertake a controlled function or Senior Insurance Management role)||
We operate primarily in the United Kingdom. However, sometimes the information that we collect from you may be viewed from, transferred to, or stored, outside the European Economic Area (EEA).
We ensure that we put in place appropriate safeguards when we allow your information to be processed outside the EEA. Please contact our Data Protection Officer using the details below if you would like more information on the appropriate safeguards we have in place.
We try not to ask you for personal information that we don't need. If you do not provide certain information you may not fulfil your contractual obligations and we may not be able to continue with your employment (e.g. if you don't provide evidence that you are entitled to work in the UK this will mean Phoenix are non-compliant to UK Home Office legislation and we will not be able to employ you). We will try to make clear what information is essential and what information would help us but is not essential. If you don't want to provide certain information but are not sure of the impact that will have on our relationship with you as your employer please get in touch using the contact details at the end of this notice.
We have explained your rights below, but to keep things simple we have not included all the circumstances or conditions which apply to them. If you would like to exercise these rights please contact our HR team on the numbers at the end of this notice. If for any reason the right is limited or doesn't apply we will explain to you why this is the case.
Stop using my information - In certain circumstances you can ask us to stop using your information. If we can stop using your information we will, but sometimes we have to use your information for legal reasons. If we cannot comply with your request then we will contact you to explain why.
Access - you have the right to ask for a copy of the information that we hold about you in the form of a Subject Access Request. We only charge a fee in exceptional circumstances. For your security, we will take reasonable steps to confirm your identity before providing you with any personal information we may hold about you. You may address any Subject Access Requests to the Phoenix Data Protection Officer whose contact details appear at the end of this document. The Phoenix Data Protection Officer will be able to assist you with any questions that you may have about exercising this right.
Transfers- in certain circumstances you can request that we transfer information we hold about you to you, or a third party in electronic form.
Remove my information - in certain circumstances you can ask us to stop using and/or delete your information. If we can delete your information we will, but sometimes we have to maintain records for legal reasons. If we cannot comply with your request then we will contact you and explain why.
If we have shared the personal information in question with another company we will also let them know that you have asked us to stop using or retaining your information, where it is reasonably practicable to do so.
It is important that the information we hold about you is accurate and up to date. Please let us know if your information changes, or the information we hold about you is incorrect. You are able to update your details on our HR self-service system or alternatively you can ask our HR Direct Team to update or correct your information free of charge using the contact details at the end of this notice.
If we have disclosed the personal information in question to another company (including another company within the Phoenix Group), we will also let them know about the changes where it is practicable to do so.
We will retain your personal information for a period of time that enables us meet our legal and regulatory responsibilities which will vary depending on the nature of the information; and defend or bring any existing or potential legal claims.
We will delete your personal information when it is no longer required for these purposes. If there is any information that we are unable, for technical reasons, to delete entirely from our systems, we will put in place appropriate measures to prevent any further processing or use of your personal information.
We may change this privacy notice from time to time to keep it up to date, or to comply with legal requirements. Any changes we make in the future will be posted on this page and we will notify you of any material changes.
If you have any questions or concerns about our use of your information or would like a copy of the information we hold about you, please write to:
Phoenix Data Protection Officer
1 Wythall Green Way
Telephone: +442035679233 Email: DataProtection@thephoenixgroup.com
For general queries regarding the use of your personal or sensitive information please contact the HR Services Team using the following details:
For amending your details held within our HR system:
Telephone: 0845 882 6747 Email: HRDirect@Diligenta.co.uk
If you are unhappy with any aspect of the use of your data, please let us know using the HR Team details above. You have the right to complain to the Information Commissioner whose contact details are:
Information Commissioner's Office
Tel: 0303 123 1113 (local rate) or 01625 545 745 if you prefer to use a national rate number.
"Phoenix People" and "you" mean prospective, present, and past employees, directors, Non-Executive Directors, Committee Members of the Phoenix Life Company Boards, contractors, and agency staff undertaking work for Phoenix.
"personal information" means information about you, and from which you could be identified, including information which may be protected under the privacy or data protection laws of the country in which you are employed.
"sensitive information" means information that could be used in a discriminatory way and is likely to be of a private nature. This includes ‘special category' data which includes (but is not limited to) race, ethnic origin, religion, health information, and sexuality; and information about criminal convictions.