This Policy sets out the obligations of DG Publishing Limited, a company registered in England and Wales under number 04992946, whose registered office is at 108 Sandford Road, Chelmsford , Essex, CM2 6DH (“the Company”) regarding data protection and the rights of clients, contacted parties and employees (“data subjects”) in respect of their personal data under EU Regulation 2016/679 General Data Protection Regulation (“GDPR”).
This Policy sets the Company’s obligations regarding the collection, processing, transfer, storage, and disposal of personal data. The procedures and principles set out herein must be followed at all times by the Company, its employees, agents, contractors, or other parties working on behalf of the Company.
The Company is committed not only to the letter of the law, but also to the spirit of the law and places high importance on the correct, lawful, and fair handling of all personal data, respecting the legal rights, privacy, and trust of all individuals with whom it deals.
Keeping your data safe
At DG Publishing we are committed to keeping your personal data safe and secure, and handling it in accordance with our legal obligations.
Who is DG Publishing Ltd?
The Pension Funds Performance Guide (LGPS & Funds Edition), www.pensionsperformance.com, and LAPF Investments Magazine are published by DG Publishing Ltd. DG Publishing Ltd also organises events for pensions professionals including the LAPF Strategic Investment Forum, LGPS Question Time, DC Question Time, DC Strategic Summit, DB Strategic Investment Forum and LAPF Investments Awards.
These publications and events provide information and services to the pension fund sector in the UK. We will contact you only with highly relevant information related to our pensions-related products and services.
How DG Publishing Ltd manages your data
The new GDPR data legislation came into effect on the 25 May 2018. The following information notice outlines important information related to your professional contact data and GDPR.
DG Publishing Ltd holds and processes data in accordance with principles in Article 5 of GDPR.
- Processed lawfully, fairly and in a transparent manner.
We have identified an appropriate lawful basis (or bases) for our processing of Local Authority and Company Data accounts, documents and other information within the relevant industry. We do not deceive or mislead people when we collect their personal data. We are open and honest, and comply with the transparency obligations of the right to be informed.
- Collected for specified, explicit and legitimate purposes.
We have clearly identified our purpose or purposes for processing to support our main business model. We regularly review our processing and, where necessary, update our documentation and our privacy information for individuals.
All personal data is held centrally on our internal network server and online database www.pensionsperformance.com. This is encrypted and password protected. Certain information is held on a need to know basis, which means that only required members of the Company have access to the data.
- Adequate, relevant and limited to what is necessary.
We only collect personal data we actually need for our specified purposes. We periodically review the data we hold, and delete anything we don’t need, subject to retention of continuing business interests.
- Accurate and, where necessary, kept up to date.
We have appropriate processes in place to check the accuracy of the data we collect, and we record the source of that data. We have a process in place to identify when we need to keep the data updated to properly fulfil our purpose, and we update it as necessary. We comply with the individual’s right to rectification and carefully consider any challenges to the accuracy of the personal data. This involves regular checks independently and also correspondents with Local Authority, Companies and relevant personnel.
- Retained only for as long as necessary.
We know what personal data we hold and why we need it. We carefully consider and can justify how long we keep personal data subject to retention of continuing business interests.
- Processed in an appropriate manner to maintain security.
We undertake an analysis of the risks presented by our processing, and use this to assess the appropriate level of security we need to put in place. We have an information security policy (or equivalent) and take steps to make sure the policy is implemented. We understand the requirements of confidentiality, integrity and availability for the personal data we process.
DG Publishing Ltd data is collated under the legal basis of the principles above based on the nature of the services and communications that we provide to pension professionals. We provide information and event services to the pension fund sector and this notice is relevant to you if you have received an email communication from us.
What data do we collect and from where?
We have obtained your data from local authority websites or related websites, pension fund or company accounts, or through telephone, email, paper or primary source research. Our database covers key individuals in pension funds, actuaries, investment consultants, auditors, solicitors, fund management firms, custodians or other professional advisers, who have either been self-declared, peer-nominated or identified as someone who has a role to play in the pension fund information sector.
Collected personal data can include the following:
- Full name.
- Political affiliation/locality.
- Committee membership.
The driver of our products is to provide transparency and highly relevant information in the area of pension fund management, and since 2005 our products have become central to pension fund managers and other members of the wider pension fund community to benchmark the performance of their pension funds and to obtain necessary advice and services from relevant adviser companies.
What will my professional details be used for?
Your professional details are included in our publications to help pension funds and their professional advisers work together to ultimately improve the financial performance of the pension fund. Professional information may be used by a select group of relevant organisations who work in or closely with pension funds, namely:
1. Individuals at pension funds such as pension fund managers who want to benchmark their performance and identify new advisers to work with.
- Professional advisers to pension funds, including analysts and business development managers at investment managers, investment consultants, auditors, pension administrators, fiduciary managers and actuaries who subscribe to our products. These advisers use our services to access historic trends, benchmark financial performance and identify the individuals responsible at the fund to enable them to better service funds and offer relevant products and services that aim to improve their performance.
- Service providers who wish to send you highly relevant pension fund related content
We also maintain your professional contact information, including your email address, to enable us to provide you with information on services which we feel would be of use to you. DG Publishing Ltd reviews any potential new client to ensure that the services offered are highly relevant to pension funds. We will never knowingly allow for your professional contact information to be used for anything other than relevant pension fund related services or communications.
Can I opt out?
The aim of The Pension Funds Performance Guide – LGPS & Funds Edition and pensionsperformance.com is to provide transparency on the financial performance and management of pension funds. We only process limited personal data on people in their professional roles, and in some circumstances we may continue to publish contacts who have financial responsibility and are available in the public domain. You may opt out of further communications by replying directly to the sender of the email you received and requesting removal, or by emailing us at email@example.com.
How will my information be stored?
Your data is held on a secure server in the UK with restricted access. We ensure the protection of the confidentiality, integrity and security of all data provided to us. No information will be disclosed if it is the view of the company that to do so would be a breach of data protection laws.
Individual rights and subject to access requests
If you object to our processing of your personal information for certain purposes or you want us to stop using or to delete your personal information, you can contact us and tell us why. In certain circumstances we may not be able to stop using your personal information but, if that is the case, we will let you know and tell you why.
You also have a right to ask us to send you a copy of your profile and all other personal data that we hold about you. A request to exercise this right is called a “subject access request” and we will act on the subject access request without undue delay and at the latest within one month of receipt.
If you wish to raise a complaint on how we have handled your personal data, or you have any questions regarding this information notice, you can contact the Data Compliance Officer to have the matter investigated at firstname.lastname@example.org or in writing to Data Compliance Officer, DG Publishing Ltd, Temple Chambers, 3-7 Temple Avenue, London, EC4Y 0HP.