Privacy Policy

1. About us and this privacy notice

This notice explains how we, the RMCPP Trustees Limited (the Trustee of the Royal Mail Collective Pension Plan), will use any personal data that we collect about you through this website or the online surveys that you can access through it. It also explains how we may use some of the other more general information that we collect through this website or these online surveys.

It is important that you read this privacy notice together with any other privacy notice or policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements any other notices and privacy policies and is not intended to override them.

This notice does cover any of your personal data that we may collect in other circumstances, such as personal data we collect to administer, manage, calculate and pay benefits under the Collective Plan. We will provide you with separate notices where we do this. 

This website may also contain links to sites that are run by other people. Those sites will have their own policies which will apply to the information collected through those sites.

Personal data means information about you from which you can be identified (either from the information itself or with other information that we may hold). We will be the 'controller' for any of your personal data that we collect through this website or these online surveys. This means that we are generally responsible for how and why this data is used. Personal data does not include data where identification information has been removed so that you cannot be identified from it (either directly or in combination with other information that we may hold).

2. What information we collect through this website and the surveys you can access through it

When you visit this website we collect information like your IP address, the browser and device you are using. We may also collect information about how you use the website. We do this so that we can operate the website effectively, analyse how it is used and make improvements to it. We may collect this information directly or through third party providers such as Google.

We collect some of this information through the use of cookies. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy.

When you complete surveys that we make available through the website we collect your responses to the survey questions and certain information about how you complete the survey. 

This may include:

• answers to questions about your experiences of the Collective Plan and its communications

• answers to questions about your characteristics (such as age range and gender) that we may use to put your other answers in context

• comments that you provide in response to open-ended questions

• your IP address, location data (such as IP address), device type used (computer or mobile device) and web browser

• survey completion times

• your name and email address where you choose to provide this information

You are completely free to decide whether or not to take part in these surveys. You can also decide whether or not to provide your name or email address when you complete any survey. You are free to decide what information to include in free text/comment boxes included within surveys. However, we advise you not to disclose any information in your comments in free text/comment boxes which might identify yourself or others.

3.    Why we use this information

We collect information about your use of the website so that we can operate the website effectively, analyse how it is used and make improvements to it.

We use the information we collect when you complete surveys to help us understand the effectiveness and quality of our management of the Collective Plan and the Collective Plan’s communications and to help us to design and improve member communications and our management of the Collective Plan.  

Where this information includes your personal data we can only use it where we have a 'legal basis' (i.e. a genuine legal reason) for doing so. The legal basis we generally rely on when we use any personal data collected through these surveys is compliance with our obligations under pensions laws. In particular, our obligations to operate the Collective Plan and to have adequate systems and processes for communicating with members. Where this legal basis does not apply, we rely on our legitimate interests in the efficient operation of the Collective Plan. 

Where we use personal data to operate our website, analyse how it is used and make improvements to it, we rely on our legitimate interests in providing an effective website, working out how well it is working and in making improvements to it.

4. Organisations with whom we may share this information

Our service providers will process this information in the course of providing services to us. 

These include:

• Royal Mail Group Limited and its IT providers (including hosting providers)

• Our own IT providers (including Google who provide web analytics services)

• Our survey suppliers (currently Qualtrics)

• Providers of on-line survey analysis tools

Where requested or if we consider that it is reasonably required, we may also provide this information to government bodies and dispute resolution and law enforcement organisations, including the courts, The Pensions Regulator, the Pensions Ombudsman and the Pension Protection Fund. They may then use the data to carry out their functions.

We may also freely share any information where it has been fully anonymised so that it cannot identify any individual.

5. International transfers

Information collected from your use of our website or completion of surveys may be transferred outside the UK. For example, survey information will be stored on IT systems controlled by our survey provider, which are currently located in Germany. 

In very limited circumstances this may involve the transfer of your personal data to countries which the UK has not determined to have adequate safeguards for the protection of personal data. If this should occur then we will put in place appropriate procedures for the protection of this data. Please contact us using the contact details below if you require further information.

6. How long we will retain this information

Website usage data will generally be held for up to 5 years. Google will hold this data for so long as they need to provide services, and in line with Google’s standard data retention policy.  

Survey data will generally be held for up to 5 years after the date the survey is completed. 

However, where data obtained from the analysis of survey or website usage data is anonymous (i.e. we cannot link it to an identifiable individual) then this may be held indefinitely, or until it is no longer considered useful.

7. Your rights

You have a right to access and obtain a copy of the personal data that we hold about you, and to ask us to correct your personal data if there are any errors or it is out of date or incomplete. In some cases you may also have a right to ask us to erase or restrict the processing of your personal data or to transfer your personal data. 

In certain circumstances, you have the right to object to the processing of your personal data; for example, you have the right to object to processing of your personal data which is based on legitimate interests.

You can obtain further information about these rights from the Information Commissioner's Office at: www.ico.org.uk or via its telephone helpline (0303 123 1113).

If you wish to exercise any of these rights or have any queries or concerns regarding the processing of your personal data, please contact us using the contact details provided below. You also have the right to lodge a complaint in relation to our processing of your personal data with the Information Commissioner's Office - you can do this via the ICO's website or telephone helpline.

Please note that these rights only apply to information that we collect which is your personal data. They do not apply to any anonymous data that we collect or to any data once it has been effectively anonymised.

8. Contacting us

If you wish to obtain further information, please contact us using the contact details below.

Postal Address:

Scheme Secretary, RMCPP Trustees Limited, 185 Farringdon Road, London, EC1A 1AA.

Email: rmcppsecretariat@royalmail.com