City Actuaries takes its obligations under the General Data Protection Regulation (Regulation (EU) 2016/679) and Data Protection Act 2018 very seriously and strives for the highest standards. Our lead data protection supervisory authority is the Information Commissioner’s Office (ICO) in the United Kingdom.
General Data Protection Regulation
On 25 May 2018, the Data Protection Act 1998 was replaced by the European Union’s General Data Protection Regulation (GDPR). The GDPR forms part of the data protection regime in the United Kingdom, together with the new Data Protection Act 2018 (DPA 2018).
City Actuaries is responsible for complying with the GDPR and its Data Protection Principles, along with the other provisions in the DPA 2018.
The GDPR includes the following rights for individuals:
There are six lawful bases for the processing of personal data. At least one of the following must apply whenever City Actuaries processes personal data:
Consent: the individual has given clear consent to process their personal data for a specific purpose.
Contract: the processing is necessary for a contract with the individual, or because they have asked for specific steps before entering into a contract.
Legal obligation: the processing is necessary to comply with the law (not including contractual obligations).
Vital interests: the processing is necessary to protect someone’s life.
Public task: the processing is necessary to perform a task in the public interest or for official functions, and the task or function has a clear basis in law.
Legitimate interests: the processing is necessary for legitimate interests or the legitimate interests of a third party unless there is a good reason to protect the individual’s personal data which overrides those legitimate interests.
City Actuaries focuses pro-actively on compliance with data protection regulations and in addition, adheres to its own principles:
Personal data covers both facts and opinions about an individual where that data identifies an individual. The personal data held by City Actuaries falls into three categories:
Processing of personal data
City Actuaries will only process personal data when a legal basis has been clearly identified.
Staff, associates, potential recruits: City Actuaries processes employment details and other employment-related data for potential recruits, and current and former staff. City Actuaries carries out this processing in order to prepare for and carry out employment contracts and to comply with legal obligations as an employer.
Individuals with whom City Actuaries has a business relationship: City Actuaries processes contact details of these individuals, such as names, addresses, email addresses and professional interests. If the individual has specifically opted-in, City Actuaries uses this information to send out communications related to City Actuaries business. Other business contact information is used by City Actuaries for its legitimate business interests. This involves contacting specific people in connection with current business or future business issues. The information may be passed to third parties that provide services to City Actuaries to enable City Actuaries to carry out the purposes referred to above.
Individuals who hold investments/insurance: When City Actuaries provides a service to an individual who holds financial investments, or to an individual whose financial investment and insurance needs are analysed by City Actuaries as part of a service contract with an organisation, the only data City Actuaries obtains is that required to provide the service. The data will be obtained from the individual directly or from elsewhere at the specific request of the individual via the relevant data controller. Upon the evaluation of data obtained for the performance of contracts, if City Actuaries becomes exposed to information that is in addition to the information required to performing the required service, City Actuaries will only use the information that is required to provide the service and will take measures, where possible, to limit such exposure. City Actuaries has written contracts with the clients for whom City Actuaries processes this information and City Actuaries complies with their written instructions for how the information may be used.
Sensitive personal data
City Actuaries may hold sensitive data about its staff which will have been provided to facilitate employment duties and information which would be relevant to their employment and relationships with other members of staff. Information relating to City Actuaries’ use of personal information relating to staff is set out in the Staff Handbook.
Due to the nature of the services which City Actuaries provides, City Actuaries can hold sensitive personal data about individuals. This data may contain a variety of information including financial details (including historic), family details and health information. The situation arises because City Actuaries provides services to independent financial advisers, insurance companies, regulators, solicitors, courts of law and others who in the course of their business need to consider the holdings of investments and investment and insurance needs of individuals, sometimes on the instructions of the individual but sometimes in an adversarial, monitoring or other capacity. City Actuaries processes this information to comply with the service contracts that relate to the individuals.
City Actuaries will only accept consent as any freely given, specific, informed and unambiguous indication of the data subject's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.
Retention of data
City Actuaries will not retain personal data for longer than it is needed for its authorised purpose. Where City Actuaries processes data on the basis of an individual’s consent, once consent has been withdrawn, our systems will be updated immediately and the personal data will be removed from use (as defined within the request for the withdrawal of consent) and will be deleted. For the performance of contracts, a defined period for the retention of data will be agreed with the data controller.
City Actuaries periodically reviews the data held about individuals with whom City Actuaries maintains a business relationship to ensure that it is still relevant to City Actuaries' business needs.
Subject access requests
City Actuaries will provide access to personal data which it holds, upon request, subject to checking that the personal data may legally be provided and with agreement from the data controller (either City Actuaries or client; whichever is the data controller).
There will be no charge for providing this information unless they are manifestly unfounded or excessive. City Actuaries will ensure that the information is made available within 30 days. City Actuaries may require further time (up to a maximum of 2 further months) if the request for information is complex – in this case, we will inform the data subject accordingly.
If City Actuaries refuses a request for personal data, it will inform the individual of the reasons why and that they have the right to complain to the supervisory authority and to a judicial remedy.
To make a formal request to access personal data that we hold about you, please contact us.
City Actuaries provides highly secure computer systems, applications and devices for its staff. It also hosts a range of computer applications and services to organisations as part of a contract. Large volumes of data pass over this network of computers, applications and devices which contain adequate controls for the separation and management of data. City Actuaries monitors the data and traffic in the capacity of a network administrator as well as in the capacity of the operator of its own business and as an employer. City Actuaries makes it clear to all those individuals and organisations affected what roles it carries out in the operation of the network.
City Actuaries staff will only have access to personal data that is relevant to fulfil their roles and for the performance of contracts.
City Actuaries has strict policies and procedures for its staff around the use of computer systems, applications and devices to minimise the risks to personal data, which includes the use of personal data within external communications and systems outside the control and monitoring of City Actuaries.
City Actuaries policies and procedures extend to all other methods for containing personal data, which includes printed documents and all paper files.
Personal data breaches
City Actuaries has procedures to effectively detect, report and investigate a personal data breach. If a personal data breach has been verified, then City Actuaries will take immediate action by informing the data controller (if not City Actuaries), and where appropriate informing affected data subjects (in liaison with the data controller), and the supervisory authority.
For all data protection matters, please contact us.
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