Rothesay Privacy Policy

Your Privacy Is Important To Rothesay

In the course of providing various products and services related to the occupational pension scheme of which you are a member (the “Scheme”), Rothesay may obtain personal information about you. Obtaining this information is important to our ability to deliver the highest level of service to you, but we also recognize that you expect us to treat this information appropriately.

This Policy describes the types of personal information we may collect about you, the purposes for which we use the information, the circumstances in which we may share the information, and the steps that we take to safeguard the information to protect your privacy. As used throughout this Policy, the term “Rothesay” refers to Rothesay Life Limited and Rothesay Pensions Management Limited.

The Sources of Information

The personal information we collect about you comes primarily from the forms and materials you submit to Rothesay during the course of your relationship with us and from third parties involved in the closure and windup of the Scheme. In addition, subject to strict compliance with all applicable laws and regulations, information may be collected about you indirectly from monitoring or other means (e.g., recording of telephone calls and monitoring emails). In these circumstances, the information is not accessed on a continuous or routine basis but it may be used for compliance or security purposes.

The Information We Have About You

The typical information we collect about you would include your name, address and other contact details and other information related to your Scheme membership. This may include certain “sensitive personal data” in the form of information on your physical or mental health or condition. While we make every effort to ensure that all information we hold about you is accurate, complete, and up to date, you can help us considerably in this regard by promptly notifying us if there are any changes to your personal information.

Our Use of Your Personal Information

We may use your personal information to:

Close and windup the Scheme and offer you various options with respect to your pension benefits. This may include sharing such information internally as well as disclosing it to third parties, as described in the following section;
Contact you or, if applicable, your designated representative(s) by post, telephone, electronic mail, facsimile, etc., in connection with your relationship with us;
Provide you with information concerning products and services offered by Rothesay; and
Facilitate our internal business operations, including assessing and managing risk and fulfilling our legal and regulatory requirements.

If your relationship with Rothesay ends, Rothesay will continue to treat your personal information, to the extent we retain it, as described in this Policy.

Disclosures of Your Personal Information

Rothesay does not disclose your personal information to third parties, except as described in this Policy. Third party disclosures may include sharing such information with affiliated and non-affiliated companies, including those providing professional, legal, or accounting advice to Rothesay, to close and windup the Scheme, assist us in administering our relationship with you, perform appropriate actions in connection with any offers extended to you, or arrange for the performance of specialised services. When so sharing your personal information, we adhere to applicable legal and industry standards regarding the protection of personal information. Additional information on how your personal information is protected while within Rothesay is provided below under Information Security: How We Protect Your Privacy.

We may also disclose your personal information to fulfil your instructions, to protect our rights and interests and those of our business partners, or pursuant to your express consent. Finally, under limited circumstances, your personal information may be disclosed to third parties as permitted by, or to comply with, applicable laws and regulations, for instance, when responding to a subpoena or similar legal process, to protect against fraud, and to otherwise cooperate with law enforcement or regulatory authorities.

You should know that Rothesay will not sell your personal information.

Information Security: How We Protect Your Privacy

Rothesay is committed to protecting the privacy and confidentiality of your personal information. We limit access to your personal information to authorised Rothesay employees or agents, and our service providers are held to stringent standards of privacy. We also maintain physical, electronic, and procedural safeguards to protect the information against loss, misuse, damage or modification and unauthorised access or disclosure. Some of the other central features of our information security program are:

A dedicated group – the Information Security Department – that designs, implements, and provides oversight to our information security program;
The use of specialised technology such as firewalls;
Testing of the security and operability of products and services before they are introduced to the Internet, as well as on-going scanning for publicly-known vulnerabilities in the technology;
Internal and external reviews of our Internet sites and services;
Monitoring of our systems infrastructure to detect weaknesses and potential intrusions;
Implementing controls to identify, authenticate and authorise access to various systems or sites;
Protecting information during transmission through various means including, where appropriate, encryption; and
Providing Rothesay personnel with relevant training and continually updating our security practices in light of new risks and developments in technology.

Privacy and The Internet

The following additional information will be of interest if you submit personal data to us via this Web site:

“Cookies” are small text files that may be placed on your Web browser when you visit our Web sites or when you view advertisements we have placed on other Web sites. The information derived from cookies is used for administrative purposes, to help us gauge the effectiveness of advertising efforts, and to improve your experience with our Web sites. For example, this information may help authenticate you (i.e., verify that you are who yousay you are), an essential component of site security. Cookies also make it easier for you to navigate a RothesayWeb site by, among other things, “remembering” your identity so that you do not have to input your password multiple times as you move between pages or services. Cookies also may be used to serve you Rothesay advertisements when you visit Web sites of third parties with whom we have marketing relationships. You can set your Web browser to inform you when cookies are set, or to prevent cookies from being set. However, if you decline to use cookies, you may experience reduced functionality and, for sites serving authentication-related cookies, declining cookies will prevent you from using the Web site altogether.
“Clickstream” data (e.g., information regarding which of our Web pages you access, the frequency of such access, and your product and service preferences) may be collected by Rothesay itself, or by our service providers, using cookies, Web beacons, page tags, or similar tools that are set when you visit our Web site or when you view an advertisement we have placed on another Web site. Clickstream data and similar information may be shared internally within Rothesay and used: for administrative purposes; to assess the usage, value and performance of our online products and services; to improve your experience with our Web sites; and as otherwise permitted by applicable law or regulation. If you are a Rothesay client, this information helps us suggest products or service offerings that may be of interest to you. This information may be processed by us for the purposes described above, or on our behalf by third parties, solely in accordance with our instructions.
When you visit this site, your browser may be momentarily directed to the Web site of an ad server or other third party service provider. This re-direction process will not be apparent to you. These third party Web sites automatically receive your IP address when this happens, and they may also collect information from your interaction with our Web sites including computer and connection information, standard Web log information, and ad information. Such information does not identify you individually.
Rothesay may make available on this Web site third party applications such as content linking or sharing facilities. Information collected by providers of such applications is governed by their privacy policies

Other Privacy Policies or Statements; Changes to Policy

This Policy provides a general statement of the ways in which Rothesay protects your personal information. You may, however, in connection with specific products or services offered by Rothesay, be provided with privacy policies or statements that supplement this Policy. This Policy may be changed from time to time to reflect changes in our practices concerning the collection and use of personal information. The revised Policy will be effective immediately upon posting to our Web site. This version of the Policy is effective September 20, 2011.

Access and Correction

You are entitled to access any personal data about you held by Rothesay by sending a written request to the individual identified below. You may be required to supply a valid means of identification as a security precaution to assist us in preventing the unauthorised disclosure of your personal information. We will process your request within the time provided by applicable law. You are also entitled to have Rothesay modify or delete any information that you believe is incorrect or out of date.

Rothesay may occasionally contact you by post, telephone, electronic mail, facsimile, etc., with details of products and services that we believe may be of interest to you. If you do not wish to be contacted in this way, if you wish to exercise your rights of correction and access, or if you require further information regarding our privacy policies and practices, please contact:

Rothesay Privacy Officer
c/o James Dickson
Goldman Sachs International
Peterborough Court, 133 Fleet Street
London EC4A 2BB