Isio Group Ltd and Isio Services Ltd (“Isio”,”we” or “us”) are dedicated to protecting the confidentiality and privacy of information entrusted to us in accordance with the EU General Data Protection Regulation (GDPR) and the UK Data Protection Act 2018. Please read this Privacy Notice to learn about your rights, what information we collect, how we use and protect it.
This website is operated by Isio who are a professional services advisory firm specialising in employee benefits, pensions and investments.
1. Who are we?
This Privacy Notice applies to Isio Group Ltd and Isio Services Ltd.
2. Who can you contact for privacy questions or concerns?
If you have questions or comments about this Privacy Notice or how we handle personal data, please direct your correspondence to: Isio Group Ltd, Data Privacy Office, 15 Canada Square, London UK E14 5GL or email firstname.lastname@example.org.
If you wish to exercise any of your data protection rights as set out below then please contact us using the details above
- Accessing the data we hold about you
- Correcting data we hold about you
- Erasing data we hold about you
- Restricting how we can use your data
- Transferring your data to another party
- Details on decisions we’ve made about you using an automated means
- Opting out from direct marketing
- Removing any consent
We aim to respond within 30 days from the date we receive privacy-related communications.
You may contact the UK Information Commissioner’s Office at https://ico.org.uk/concerns/handling/ to report concerns you may have about our data handling practices.
3. How do we collect personal data?
- Directly. We obtain personal data directly from individuals in a variety of ways, including obtaining personal data from individuals who provide us with their business card(s), complete our online forms, subscribe to our newsletters, sign up for marketing, register for webinars, attend meetings or events we host, visit our offices or for recruitment purposes. We may also obtain personal data directly when, for example, we are establishing a business relationship, performing professional services through a contract, or through our hosted software applications.
- Indirectly. We obtain personal data indirectly about individuals from a variety of sources, including recruitment services and our clients. We may attach personal data to our customer relationship management records to better understand and serve our business clients, subscribers and individuals, satisfy a legal obligation, or pursue our legitimate interests.
- Public sources - Personal data may be obtained from public registers (such as Companies House), news articles, sanctions lists, and Internet searches.
- Social and professional networking sites - If you register or login to our websites using social media (e.g., LinkedIn, Google, or Twitter) to authenticate your identity and connect your social media login information with us, we will collect information or content needed for the registration or login that you permitted your social media provider to share with us. That information may include your name and email address and depending on your privacy settings, additional details about you, so please review the privacy controls on the applicable service to set how much information you want shared with us.
- Business clients - Our business clients may engage us to perform professional services which involves sharing personal data they control as part of that engagement. For example, we will review personal data to provide pension advice to both Trustees and sponsoring employers of pension schemes. Our services may also include processing personal data under our clients’ control on our hosted software applications, which may be governed by different privacy terms, policies and notices.
- Recruitment services - We may obtain personal data about candidates from an employment agency, and other parties including former employers, and credit reference agencies.
4. What categories of personal data do we collect?
We may obtain the following categories of personal data about individuals through direct interactions with us, or from information provided through client engagements, from applicants, our suppliers and through other situations including those described in this Privacy Notice.
- Personal data. Here is a list of personal data we commonly collect to conduct our business activities.
- Contact details (e.g., name, company name, job title, work and mobile telephone numbers, work and personal email and postal address).
- Other unique identifiers (e.g., date of birth, national insurance number)
- Professional details (e.g., job and career history, educational background and professional memberships, published articles).
- Family and beneficiary details (e.g., names and dates of birth).
- Financial information (e.g., remuneration, pension amounts, taxes, payroll, investment interests, assets, bank details).
- CCTV at our sites may collect images of visitors. Our policy is to automatically overwrite CCTV footage within 30 days.
- Sensitive personal data. We limit collecting sensitive or special categories of personal data about individuals other than our own employees. When we do need to process sensitive personal data from data subjects who are not our employees, it is either on the instructions of a third party, with the express consent of the individuals or as required by law. Examples of sensitive personal data we may obtain, or otherwise hold, include:
- Personal identification documents that may reveal race, sexuality, religion or ethnic origin, biometric data of private individuals, beneficial owners of corporate entities, or applicants.
- Adverse information about potential or existing clients and applicants that may reveal criminal convictions or offences information.
- Information provided to us by our clients in the course of a professional engagement for example ill-health data in order for us to determine benefits due to you from a pension scheme which we advise
- Diversity and equal opportunity information volunteered by participants in certain Isio professional programmes and recruitment processes.
- Child data. Although we do not intentionally collect information from individuals under 13 years of age, we may occasionally receive details about children attending performances and other events we host with their parents or guardians or as beneficiaries of pension scheme members.
- Location-based data. We may process geographical locations you enter when seeking an office near you.
5. What lawful reasons do we have for processing personal data?
We may rely on the following lawful reasons when we collect and use personal data to operate our business and provide our products and services:
- Contract – We may process personal data in order to perform our contractual obligations owed to (or to enter into a contract with) the relevant individuals.
- Consent - We may rely on your freely given consent at the time you provided your personal data to us.
- Legitimate interests – We may rely on legitimate interests based on our evaluation that the processing is fair, reasonable and balanced. These may include:
- Delivering services to our clients – To deliver the professional services our clients have engaged us to provide.
- Direct marketing – To deliver timely market insights and speciality knowledge we believe is welcomed by our business clients, subscribers and individuals who have interacted with us.
- Legal obligations – We may process personal data in order to meet our legal and regulatory obligations or mandates.
6. Why do we need personal data?
We aspire to be transparent when we collect and use personal data and tell you why we need it, which typically includes:
- Providing professional advice and delivering reports related to our pensions and investment services. Our services may include reviewing client files for quality assurance purposes, which may involve processing personal data for the relevant client.
- Promoting our services, products and capabilities to existing and prospective business clients.
- Sending invitations and providing access to guests attending our events and webinars or our sponsored events.
- Personalising online landing pages and communications we think would be of interest based on interactions with us.
- Administering, maintaining and ensuring the security of our information systems, applications and websites.
- Authenticating registered users to certain areas of our sites.
- Seeking qualified candidates, and forwarding candidate career inquiries to our human resources team, which may be governed by different privacy terms and policies.
- Processing online requests, including responding to communications from individuals or requests for proposals and quotations.
- Contacting journalists regarding company press releases, invitations to annual press parties, highlighting messages that may be of interest on specific industry topics.
- Complying with legal and regulatory obligations relating to anti-money laundering, terrorist financing, fraud and other forms of financial crime.
- Compiling health and safety data (directly or indirectly) following an incident or accident. Indirect data can take many forms including an incident report, first aider report, witness statements and CCTV footage.
7. Do we share personal data with third parties?
We may occasionally share personal data with trusted third parties to help us deliver efficient and quality services. These recipients are contractually bound to safeguard the data we entrust to them. We may engage with several or all of the following categories of recipients:
- Parties that support us as we provide our services (e.g., providers of telecommunication systems, mailroom support, IT system support, archiving services, document production services and cloud-based software services).
- Our professional advisers, including lawyers, auditors and insurers.
- A potential buyer, transferee, merger partner or seller and their advisers in connection with an actual or potential transfer or merger of part or all of our business or assets, or any associated rights or interests, or to acquire a business or enter into a merger with it.
- Payment services providers.
- Marketing services providers.
- Law enforcement or other government and regulatory agencies (e.g., HMRC) or to other third parties as required by, and in accordance with, applicable law or regulation.
- Recruitment services providers.
8. Do we transfer your personal data outside the European Economic Area?
We store personal data on servers located in the European Economic Area (EEA). We may transfer personal data to reputable third party organisations situated inside or outside the EEA when we have a business reason to engage these organisations. Each organisation is required to safeguard personal data in accordance with our contractual obligations and data protection legislation.
10. What are your data protection rights?
- Access – You can ask us to verify whether we are processing personal data about you, and if so, to provide more specific information.
- Correction – You can ask us to correct our records if you believe they contain incorrect or incomplete information about you.
- Erasure – You can ask us to erase (delete) your personal data after you withdraw your consent to processing or when we no longer need it for the purpose it was originally collected.
- Processing restrictions – You can ask us to temporarily restrict our processing of your personal data if you contest the accuracy of your personal data, prefer to restrict its use rather than having us erase it, or need us to preserve it for you to establish, exercise, or defend a legal claim. A temporary restriction may apply while verifying whether we have overriding legitimate grounds to process it. You can ask us to inform you before we lift that temporary processing restriction.
- Data portability – In some circumstances, where you have provided personal data to us, you can ask us to transmit that personal data (in a structured, commonly used, and machine-readable format) directly to another company if is technically feasible.
- Automated Individual Decision-making – You can ask us to review any decisions made about you which we made solely based on automated processing, including profiling, that produced legal effects concerning you or similarly significantly affected you.
- Right to Object to Direct Marketing including Profiling – You can object to our use of your personal data for direct marketing purposes, including profiling. We may need to keep some minimal information to comply with your request to cease marketing to you.
- Right to Withdraw Consent – You can withdraw your consent that you have previously given to one or more specified purposes to process your personal data. This will not affect the lawfulness of any processing carried out before you withdraw your consent. It may mean we are not able to provide certain products or services to you and we will advise you if this is the case.
If you would like to exercise your Data Subject Rights, you can email email@example.com. We may need to request specific information from you to help us confirm your identity and ensure your right to access the information or to exercise any of your other rights. This helps us to ensure that personal data is not disclosed to any person who has no right to receive it. No fee is required to make a request unless your request is clearly unfounded or excessive. Depending on the circumstances, we may be unable to comply with your request based on other lawful grounds.
11. What about personal data security?
We have put appropriate technical and organisational security policies and procedures in place to protect personal data (including sensitive personal data) from loss, misuse, alteration or destruction. We aim to ensure that access to your personal data is limited only to those who need to access it. Those individuals who have access to the data are required to maintain the confidentiality of such information. We may apply pseudonymisation, de-identification and anonymisation techniques in efforts to further protect personal data.
If you have access to parts of our websites or use our services, you remain responsible for keeping your user ID and password confidential. Please be aware that the transmission of data via the Internet is not completely secure. Whilst we do our best to try to protect the security of your personal data, we cannot ensure or guarantee the security of your data transmitted to our site; any transmission is at your own risk.
12. How long do we retain personal data?
We retain personal data to provide our services, stay in contact with you and to comply with applicable laws, regulations and professional obligations that we are subject to. We retain such personal data for seven years, unless a different time frame applies as a result of business need or specific legal, regulatory or contractual requirements. As an example, we retain correspondence with pension scheme members for 75 years from the end of our contract to allow us to answer member/benefit queries and prove benefit entitlement once they retire.
13. Do we link to other websites?
Our websites may contain links to other sites. Please review the destination websites’ privacy notices before submitting personal data on those sites. Whilst we try to link only to sites that share our high standards and respect for privacy, we are not responsible for the content, security, or privacy practices employed by other sites.
14. Do we change this Privacy Notice?
We regularly review this Privacy Notice and will post any updates to it on our webpage.
1.1 Automatic collection of personal information
1.1.1 IP addresses
An IP address is a number assigned to your computer whenever you access the internet. It allows computers and servers to recognise and communicate with one another. IP addresses from which visitors appear to originate may be recorded for IT security and system diagnostic purposes. This information may also be used in aggregate form to conduct web site trend and performance analysis.
Cookies may be placed on your computer or internet-enabled device whenever you visit us online. This allows the site to remember your computer or device and serves a number of purposes.
On some of our web sites, a notification banner will appear requiring your consent to collect cookies. If you do not provide consent, your computer or internet-enabled device will not be tracked for marketing-related activities. A secondary type of cookie referred to as "user-input" cookies may still be required for necessary functionality. Such cookies will not be blocked through the use of this notification banner. Your selection will be saved in a cookie and is valid for a period of 90 days. If you wish to revoke your selection, you may do so by clearing your browser's cookies.
Although most browsers automatically accept cookies, you can choose whether or not to accept cookies via your browser's settings (often found in your browser's Tools or Preferences menu). You may also delete cookies from your device at any time. However, please be aware that if you do not accept cookies, you may not be able to fully experience some of our web sites' features.
Further information about managing cookies can be found in your browser's help file or through sites such as www.allaboutcookies.org.Below is a list of the types of cookies used on our web sites:
|Purpose||Description||Type & Expiry|
|Performance (i.e. User’s Browser)||Our web sites are built using common internet platforms. These have built-in cookies which help compatibility issues (e.g., to identify your browser type) and improve performance (e.g., quicker loading of content).||Session Deleted upon closing the browser|
|Security (e.g. Asp .NET) Cookies||If you register for access to a restricted area, our cookies ensure that your device is logged for the duration of your visit. You will need your username and password to access the restricted areas.||Session Deleted upon closing the browser|
|Site Preferences||Our cookies may also remember your site preferences (e.g. language) or seek to enhance your experience (e.g. by personalising a greeting or content). This will apply to areas where you have registered specifically for access or create an account.||Session Deleted upon
|Analytical||We use several third party analytics tools to help us understand how site visitors use our web site. This allows us to improve the quality and content on all our Isio website (mainly isio.com) for our visitors. The aggregated statistical data cover items such as total visits or page views, and referrers to our web sites. For further details on our use of Google Analytics, see below||Persistent|
|Site visitor feedback||
We use a third party survey tool to invite a percentage of visitors to provide their feedback. Cookies are used to prevent visitors from being invited multiple times.
The first cookie (1) is set if the visitor is not invited to participate in the survey, and is used to ensure visitors are not invited after their first page view.
The second cookie (2) is set if the visitor is invited to participate in the survey, and is used to ensure the visitor is not invited again to participate for a period of 90 days.
2 Persistent Deleted
We use third party social media widgets or buttons to provide you with additional functionality to share content from our web pages to social media websites and email. Use of these widgets or buttons may place a cookie on your device to make their service easier to use, ensure your interaction is displayed on our webpages (e.g. the social share count cache is updated) and log information about your activities across the Internet and on our web sites. We encourage you to review each provider's privacy information before using any such service. For further details on our use of social media widgets and applications, see below.
|Persistent, but will be deleted automatically after two years if you no longer visit isio.com|
Other third party tools and widgets may be used on our individual web pages to provide additional functionality. Use of these tools or widgets may place a cookie on your device to make their service easier to use, and ensure your interaction is displayed on our webpages properly.
Cookies by themselves do not tell us your email address or otherwise identify you personally. In our analytical reports, we may obtain other identifiers including IP addresses, but this is for the purpose of identifying the number of unique visitors to our web sites and geographic origin of visitor trends, and not to identify individual visitors.
BY NAVIGATING ON OUR WEB SITES OR ENTERING YOUR LOGIN DETAILS TO ACCESS AREAS RESERVED FOR REGISTERED USERS, YOU AGREE THAT WE CAN PLACE THESE COOKIES ON YOUR COMPUTER OR INTERNET ENABLED DEVICE.
1.1.3 Google Analytics
Isio uses Google Analytics. More information about how Google Analytics is used by Isio can be found here: https://www.google.com/analytics/terms/us.html.
1.1.4 Web beacons
A web beacon is a small image file on a web page that can be used to collect certain information from your computer, such as an IP address, the time the content was viewed, a browser type, and the existence of cookies previously set by the same server. Isio only uses web beacons in accordance with applicable laws.
Isio or its service providers may use web beacons to track the effectiveness of third party web sites that provide us with recruiting or marketing services or to gather aggregate visitor statistics and manage cookies.
You have the option to render some web beacons unusable by rejecting their associated cookies. The web beacon may still record an anonymous visit from your IP address but cookie information will not be recorded.
In some of our newsletters and other communications, we may monitor recipient actions such as email open rates through embedded links within the messages. We collect this information to gauge user interest and to enhance future user experiences.
1.1.5 Location-based tools
Isio may collect and use the geographical location of your computer or mobile device. This location data is collected for the purpose of providing you with information regarding services which we believe may be of interest to you based on your geographic location, and to improve our location-based products and services.
1.2 Social media widgets and applications
Isio web sites may include functionality to enable sharing via third party social media applications, such as the Facebook Like button and Twitter widget. These social media applications may collect and use information regarding your use of Isio web sites (see details on 'Social Sharing' cookies above). Any personal information that you provide via such social media applications may be collected and used by other members of that social media application and such interactions are governed by the privacy policies of the companies that provide the application. We do not have control over, or responsibility for, those companies or their use of your information.
In addition, Isio web sites may host blogs, forums, crowd-sourcing and other applications or services (collectively "social media features"). The purpose of social media features is to facilitate the sharing of knowledge and content. Any personal information that you provide on any Isio social media feature may be shared with other users of that social media feature (unless otherwise stated at the point of collection), over whom we may have limited or no control.