Introduction
At PL Re we are committed to maintaining the accuracy, confidentiality and security of your personal information. This Privacy Notice describes the personal information that PL Re collects about you, and how we use and to whom we disclose that information.
The Pacific Life Re group ("PL Re") is comprised of multiple business units and operates through various legal entities, including their respective branches and representative offices, under the common control of Pacific Mutual Holding Company. All references in this Privacy Notice to "PL Re", "we", "us", "our" and like terms should be interpreted accordingly.
This Privacy Notice applies to the personal information of individuals resident in the UK and Ireland or Canada who seek to be, are, or were employed by PL Re (each an “employee” and collectively "employees".)
This Privacy Notice is not intended for individuals who have policies that are reinsured with us, or for individuals connected with, or employed by, cedants, insurance intermediaries and consultants, and other professional third parties, such as retrocessionnaires and service providers, with whom PL Re has a business relationship, please see the privacy notices for you found here.
Notice of compliance
It is PL Re's intention to comply with the privacy legislation within each jurisdiction in which we operate. Sometimes the privacy legislation and / or an individual's right to privacy are different from one jurisdiction to another. Although this Privacy Notice covers staff across multiple jurisdictions, it was developed to guide the UK activities and operations of PL Re. In addition, specific privacy practices may be adopted to address the specific privacy requirements of particular jurisdictions. This means that we will comply with the requirements of each jurisdiction we operate in, but individuals’ rights may vary.
Definition
For the purposes of this Privacy Notice, personal information is any information about an identifiable individual, (other than the person's business title or business contact information when used or disclosed for the purpose of business communications.) Personal information does not include anonymous or non-personal information (i.e., information that cannot be associated with or tracked back to a specific individual).
What personal information do we collect?
We collect and maintain different types of personal information from employment-related data subjects, including the personal information contained in:
In addition to the examples listed above, personal information also includes information such as name, home address, telephone, personal email address, date of birth, employee identification number and marital status, and any other information necessary to PL Re's business purposes, which is voluntarily disclosed in the course of an employee's application for and employment with PL Re.
We may also, with your consent, collect and store demographic information relating to ethnicity, sexual orientation, gender identity and disability status. This is to help PL Re promote and maintain a diverse and inclusive culture. You are under no obligation to provide us with this data.
How is your personal information collected?
As a general rule, PL Re collects personal information directly from you. In most circumstances where the personal information that we collect about you is held by a third party, we will obtain your permission before we seek out this information from such sources.
From time to time, we may utilize the services of third parties in our business and may also receive personal information collected by those third parties in the course of the performance of their services for us or otherwise. Where this is the case, we will take reasonable steps to ensure that such third parties have represented to us that they have the legal right to disclose your personal information to us.
Where permitted or required by applicable law or regulatory requirements, we may collect information about you without your knowledge or consent.
Why do we collect personal information?
The personal information collected is used and disclosed for our legitimate business purposes, including establishing, managing or terminating your employment relationship with PL Re. Such uses include:
Monitoring
The work output of PL Re's employees, whether in paper record, computer files, or in any other storage format belongs to us, and that work output, and the tools used to generate that work output, are always subject to review and monitoring by PL Re.
In the course of conducting our business, we may monitor employee activities and our premises and property. For example, some of our locations are equipped with surveillance cameras. These cameras are generally in reception or high risk areas. Where in use, surveillance cameras are there for the protection of employees and third parties, and to protect against theft, vandalism and damage to PL Re's goods and property. Generally, recorded images are routinely destroyed in accordance with our Data Retention Policy, and not shared with third parties unless there is suspicion of a crime, in which case they may be shared with the police or other appropriate government agency or authority. Pursuant to our Information Systems Use Policy, we have the capability to monitor all employees' computer and e-mail use.
This section is not intended to infer that all employees will in fact be monitored or their actions subject to constant surveillance. It is to bring to your attention that such monitoring may occur and may result in the collection of personal information from employees (e.g. through their use of our resources). When using PL Re equipment or resources employees should not have any expectation of privacy with respect to their use of such equipment or resources.
How do we use your personal information?
We may use your personal information:
When do we disclose your personal information?
We may share your personal information with our employees, contractors, consultants and other parties (including other members of the PL Re group) who require such information to assist us with establishing, managing or terminating our employment relationship with you, including: parties that provide products or services to us or on our behalf and parties that collaborate with us in the provision of products or services to you. In some instances, such parties may also provide certain information technology and data processing services to us so that we may operate our business. We may share personal information with such parties both in and outside of your home jurisdiction, and as result, your personal information may be collected, used, processed, stored or disclosed in the USA, and in some cases, other countries outside the EEA. Personal information is only transferred by us to another country, including within the Pacific Life group, if this is required or permitted under the applicable privacy legislation.
When we share personal information with such parties, we typically require that they only use or disclose such personal information in a manner consistent with the use and disclosure provisions of this Privacy Notice.
In addition, personal information may be disclosed or transferred to another party (including to another member of the PL Re group outside of your home jurisdiction) in the event of a change in ownership of, or a grant of a security interest in, all or a part of PL Re through, for example, an asset or share sale, or some other form of business combination, merger or joint venture, provided that such party is bound by appropriate agreements or obligations and required to use or disclose your personal information in a manner consistent with the use and disclosure provisions of this Privacy Notice, unless you consent otherwise.
Further, your personal information may be disclosed:
Notification and consent
Privacy laws do not generally require PL Re to obtain your consent for the collection, use or disclosure of personal information for the purpose of establishing, managing or terminating your employment relationship. To the extent that your consent is required, we will assume, unless you advise us otherwise, that you have consented to PL Re collecting, using and disclosing your personal information for the purposes stated above (including any other purposes stated or reasonably implied at the time such personal information was provided to us).
Where your consent was required for our collection, use or disclosure of your personal information, you may, at any time, subject to legal or contractual restrictions and reasonable notice, withdraw your consent. All communications with respect to such withdrawal or variation of consent should be in writing and addressed to our Data Protection Officer.
How is your personal information protected?
We have in place physical, electronic, and procedural safeguards to protect personal information that we hold against unauthorised disclosure or unlawful processing. Safeguards include only holding personal information on secure servers, the use of encryption, firewalls and access controls and the separation of duties within our organisation to ensure appropriate organisational controls are in place.
How Long is Your Personal Information Retained?
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal or regulatory requirements.
Updating Your Personal Information
It is important that the information contained in our records is both accurate and current. If your personal information happens to change during the course of your employment, please keep us informed of such changes.
In some circumstances we may not agree with your request to change your personal information and will instead append an alternative text to the record in question.
Access to Your Personal Information
You can ask to see the personal information that we hold about you. If you want to review, verify or correct your personal information, please contact the PL Re Data Protection Officer using the contact information set out below. Please note that any such communication must be in writing.
When requesting access to your personal information, please note that we may request specific information from you to enable us to confirm your identity and right to access, as well as to search for and provide you with the personal information that we hold about you.
Your right to access the personal information that we hold about you is not absolute. There are instances where applicable law or regulatory requirements allow or require us to refuse to provide some or all of the personal information that we hold about you. In addition, the personal information may have been destroyed, erased or made anonymous in accordance with our legal retention obligations.
In the event that we cannot provide you with access to your personal information, we will endeavour to inform you of the reasons why, subject to any legal or regulatory restrictions.
Enquiries or concerns?
If you have any questions about this Privacy Notice or concerns about how we manage your personal information, please contact the Data Protection Officer at dpo@pacificlifere.com or your usual HR contact.
We will endeavour to answer your questions and advise you of any steps taken to address the issues raised by you. If you are unsatisfied with our response, you have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues.
Revisions to this privacy notice
PL Re may from time to time make changes to this Privacy Notice to reflect changes in its legal or regulatory obligations or in the manner in which we deal with your personal information, and will communicate such updates through our Intranet. We will not do so where we believe the changes would materially impact your rights and freedoms: in those circumstances we will expressly notify you.
This Privacy Notice was last updated May 2024.