1. WHAT IS PERSONAL DATA?
Personal data is data that says something about you or data we can link to you.
For example, you share personal data with us if you are a pension plan member or if you are in contact with us. This may include details like your name, telephone number or email address, but also your computer's IP address. Information is only considered personal data if we can trace it back to you.
2. WHY DO WE COLLECT PERSONAL DATA?
Stichting Mars Pensioenfonds, also referred to as MPF, collects and processes personal data to implement and administrate your pension as best possible. We also collect personal data to comply with statutory obligations and contractual agreements. To do so in the best way possible, your personal data may be processed for the following purposes:
- For compliance with pension- and benefits legislation
- To determine the amount and payment of pension rights and pension benefits
- To calculate, establish and collect contributions from employers
- To observe contractual agreements, for example, pursuant to the pension agreement that was concluded with you
- When processing disputes
- For fraud prevention
- To perform static analyses and ALM studies
- To improve the website's user-friendliness
- For internal (quality) analyses and product development to improve the schemes and service
- To communicate adequately with you, as a member of the fund
The pension fund collects your details with due care and in accordance with the General Data Protection Regulation (GDPR). The manner in which we do so, is explained below.
3. WHOSE PERSONAL DATA DO WE PROCESS?
Here is a non-exhaustive list of the individuals whose personal data is being processed:
- all (former) pension fund members and other persons ineligible for benefits from MPF
- all website visitors
- anyone who initiates contact with us
- MPF's visitors
4. WHICH PERSONAL DATA DO WE COLLECT?
We collect the personal data to properly implement and administrate your pension and to inform you as well as possible, amongst other things. Therefore, we can collect details about your person, your financial situation, your employment and family situation, and with respect to your preferences or IT details. For example:
- Name and (various) contact and communication details
- Date of birth
- Citizen Service Number (BSN)
- Pension number
- Bank account number
- Details and documents relating to your marital status
- Information pertaining to your (former) employment
- Pension rights / pension entitlements
- Indication of conscientious objectors
- Details on seizures
- Risk profile / investment profile / investment choices
- Biometric data like a fingerprint if we have a copy of your passport
- Certificate of life
- Details relating to incapacity for work
- Details about your children
- Other (personal) data provided by you actively in correspondence or over the telephone
- Information about your activities on our website
5. WHO CAN WE SHARE PERSONAL DATA WITH?
We may share your personal data with other parties if and only insofar as necessary for the administration of the Pension Agreement or to comply with statutory obligations. In order to guarantee the level of protection and confidentiality of your details we conclude a Data Processing Agreement with these parties. Moreover, we remain responsible for the processing. The parties we may share your (personal) data with are categorised as follows:
- Pension administrator
- Government agencies, such as the Basic Register of Persons (BRP) and the Tax Administration
- (Former) employer(s)
- Employee Insurance Schemes Implementing Body (Dutch: UWV)
- Chamber of Commerce
- Other pension administrators
- (Debt) collection agencies
- Mailing processors and/or printing companies
- Archive departments
- Audit parties, for example, for salary audits
- ICT database/website administration-, security- and maintenance firms
- Research parties
- Parties in the context of audit purposes, reporting and disputes
- The bank, for payment purposes
Our pension administration tasks are outsourced to TKP Pensioen BV (TKP). Therefore, TKP has access to your (personal) data. We have made agreements with TKP regarding the way they should handle your data, who they may share your data with and how they should secure your data.
We will not process your data outside of the EU. The information we collect from Google's Cookies is shared with Google's servers in the United States. To ensure the protection of this information, Google has joined the EU-US Privacy Shield, in respect of which the European Commission has decided that an adequate level of protection for personal data is provided.
7. RECORDING OF TELEPHONE CONVERSATIONS
The telephone calls you make to our MPF Pension Desk may be recorded. The recordings are used for training and coaching purposes. You have a right to request a copy of/listen to the telephone conversation within the retention period of one week.
8. HOW LONG WILL WE KEEP YOUR DATA?
Your personal data shall not be kept for longer than strictly necessary to accomplish the purposes for which the data was collected. Since we work with long-term pension obligations, the retention period can be extensive. We will, in any event, keep your personal data which is required for the administration of the Pension Agreement, until the prescribed period has ended after your right to a pension has lapsed or after termination of the Pension Agreement. We will delete your personal data when it is no longer required.
9. WE TAKE CARE OF YOUR PERSONAL DATA
We take the protection of your personal data very serious and, therefore, have taken appropriate measures to combat misuse, loss, unauthorised access, accidental disclosure and unauthorised changes. The measures that are taken will at least comply with the general information security requirements. We have made agreements with the processors and regularly evaluate and adjust these measures as needed.
If you feel that your data, despite these measures, is not properly secured, or you suspect misuse, please contact us:
Stichting Mars Pensioenfonds
5466 AE Veghel
Alternatively, call us on 0800 - 02 02 156 (on Monday to Friday between 9:00 and 17:00)
An email will also suffice: firstname.lastname@example.org
10. YOUR RIGHTS RELATING TO YOUR PERSONAL DATA
You have the right to inspect and modify your personal information. In specific cases, you may also ask us to limit the processing of your personal data, to delete your personal data or to transfer your personal data to another so-called controller.
How can you exercise your rights?
You may send a request to inspect your personal data or to have it modified or deleted to email@example.com. You may also use this email address to withdraw your consent for the use of your personal data. Please include a copy of your identity document with your request, so we can determine that you are indeed the person who submitted the request. In order to protect your privacy please black out your ID photo, the MRZ (machine readable zone, the bar with numbers at the bottom of the ID/passport), your passport/ID number and your Citizen Service Number (BSN) on the copy you send to us. We will respond to your request as soon as possible, but certainly within four weeks.
Right of complaint
You may submit a complaint to the Dutch Data Protection Authority if we fail to comply with your request to inspect, modify, limit, delete or transfer your personal data. If you are dissatisfied with the way your complaint is processed, you may appeal to the court.
Withdrawal of consent
In order to properly administrate your pension scheme we need specific personal data. However, this does not apply to all data processed by us. Therefore, you may ask us to refrain from or stop using your data for specific situations. For example, if you do not wish to be contacted by telephone or email, or when you have an important personal reason why we should refrain from using your data.
11. ARE WE ALLOWED TO AMEND THIS PRIVACY STATEMENT?
Yes. We reserve the right to amend this Privacy Statement. Every change will be published on this page. Therefore, we recommend that you read this Privacy Statement on a regular basis. This page was last generated/amended on 22 August 2018.