Privacy Statement
For CWPS Members: Effective 25 May 2018
Construction Workers’ Pension Scheme Trustees Designated Activity Company and Construction Workers’
Sick Pay Trustee Designated Activity Company which are the trustees of the Construction Workers’ Pension
Scheme and Sick Pay Scheme respectively (referred to together throughout this joint data privacy notice as
the Scheme); are committed to protecting your privacy. For the purposes of the General Data Protection
Regulation (the ’GDPR’) and any related data protection legislation in Ireland, we are data controllers.
This Privacy Notice issued on behalf of both trustees sets out the basis on which we will process any personal
data we collect from you or that you or third parties provide to us, in connection with your membership in
the Scheme and which relates to you or to any individual connected with you. Please read this Privacy Notice
carefully so that you understand your rights in relation to your personal data, and how we will collect use and
process your personal data.
Information we collect about you and how we use it
Information you and your employer give us
We will collect your personal information i.e. information that identifies you for the purposes of the Scheme.
This information may be provided to us directly by you, or through your employer who requests that you be
admitted as a member of the Scheme.
We also collect information through our website and our CCTV footage.
We will sometimes record phone conversations and we will always let you know when we do this. We will take
great care of the information provided and we will take steps to keep it secure.
What types of personal data do we collect about you?
We may hold the following personal information about you:
• personal details such as your name, gender, age, date of birth, email address, postal address
telephone or mobile number and identifiers such as PPS No.
• Family details such as details about current marriage and partnerships and marital history, details of
family and dependents
• Employment details such as pensionable pay, length of service, employment and career history, job
title, financial details such as income, salary, bank account details to process pension payments, benefits
• Physical or mental health or medical conditions for the purposes of administering your Scheme benefits
• Technical information and other information about your visits to our website and to our Pensions Portal
How do we use your information?
We will use your personal information to administer the Scheme and any future agreements that we may have
with you relating to the Scheme and to manage and develop our relationship with you.
We process your data to comply with our legal obligations under the Scheme’s governing documents and
pension and trust law requirements and otherwise for the purposes of our legitimate interests in promoting
the proper and efficient administration of the Scheme in order to provide benefits for you and your dependants.
From time to time, it may be necessary process personal data relating to your health or other sensitive data
for the purpose of establishing, exercising or defending a legal claim in respect of the Scheme (which includes
assessing your eligibility or that of your beneficiaries for certain benefits).
Who we share your personal data with?
For the purposes of administering the Scheme we may provide relevant personal information to:
• The Administrator of the Scheme, CPAS.
• your employer
• other companies within our Administrator’s group
• cloud and other data storage providers
• IT service providers
• External printing and office support providers
• payment providers
• insurance companies
• legal and other professional advisers
• actuarial, administration and consultancy service providers
• The Pensions Authority and the Financial Services and Pensions Ombudsman
• Revenue Commissioners
We may also disclose personal information if required to do so by law and believe that such action is necessary
to conform with the law.
If we provide your personal information to the above-mentioned third parties, we will take all reasonable
precautions regarding the practices utilised by them in protecting your personal information. Those third
parties will be required to: (i) keep your information safe and secure and (ii) handle your information on our
behalf and in accordance with our instructions.
Where do we store your personal data?
The information that we collect from you will be transferred to, and stored at/processed in the EEA. We will
take all steps reasonably necessary to ensure that your personal data is treated securely and in accordance
with this Privacy Notice.
We will only transfer your information outside of the EEA where we have adequate measures in place to
provide appropriate safeguards such as the Privacy Shield (where recipients comply with the US Department
of Commerce’s EU-US Privacy Shield) or use of contracts approved by the European Commission.
How long will we keep your personal data?
Pension and sick pay benefits are paid over a long period and your right to benefits payable under the Scheme
is based on information that may date back many years. We may decide to delete some of the data held in
relation to you and generally operate to a retention period of life of Scheme plus 7 years. However your
personal information may be held for longer where: (i) it is required by law or a court order (ii) it is needed to
defend or pursue legal claims (iii) we consider it is necessary to ensure the Scheme pays the correct benefits
and (iv) to deal with any queries relating to your benefits as they may arise after that time.
Your rights
You have certain rights in relation to the personal information we hold about you, which we detail below.
Some of these only apply in certain circumstances as set out below. Please note that we will require you
to verify your identity before we respond to any of your requests. We must respond to a request by you to
exercise those rights without undue delay and at least within one month (although this may be extended by a
further two months in certain circumstances).
• Right of access – you have the right to request a copy of the information that we hold about you.
• Right of rectification – you have a right to correct data that we hold about you that is inaccurate or
incomplete.
• Right to object – you have the right to object to certain types of processing such as direct marketing
Please note that if you fail to provide accurate membership information or object to processing of your data it
may result in a delay or an inability to process a claim for benefit under the Scheme.
Direct Marketing
Construction Workers’ Pension Scheme Trustees Designated Activity Company, Construction Workers’ Sick
Pay Trustee Designated Activity Company and other companies within our Administrator’s group CPAS i.e.
CIRT, CERS, Milestone Advisory, CIF, construction related charities i.e. Construction Workers Health Trust and
trusted partner charities (e.g. the Irish Heart Foundation, Pieta House) may contact you about products and
services they provide where you have consented to receiving same. If you do not wish us to use your data for
this reason please telephone us on 01/4977663 or email us at optout@cpas.ie
You will be given an opportunity to opt out of receiving such messages and information on each occasion by post and email.
Technical information (including cookies) that we collect about you
When you visit our website, we collect technical information about your computer, such as your internet
protocol address (which is a number that can uniquely identify a specific computer on the internet), time
zone setting, your login information, browser type and version, browser plug-in types and versions, operating
systems and platforms
We use cookies to collect information about your browsing activities over time following your use of our
services. They allow us to recognise and count the number of users and to see how users move around our
website when they are using it. This helps us to improve the services we provide to you and the way our
website works.
Complaints
In the event that you wish to make a complaint about how we process your personal data, please contact
us in the first instance at dataprotection@cwps.ie and we will endeavour to deal with your request as soon
as possible. This does not interfere with your right to raise a complaint to the Office of the Data Protection
Commissioner, details of which can be found at www.dataprotection.ie or by contacting their office on
1890 252 231.
Changes to our Privacy Notice
We may update this privacy notice from time to time. You will be able to see when we last updated the notice
because we will include a revision date. Updates are effective from the date on which they are notified to
members or posted on the website www.cwps.ie
Contact
If you have any queries or concerns please contact:
CWPS
4 Clonskeagh Square,
Clonskeagh Road,
Dublin 14,
D14FH90.
Tel: (01) 4977 663
E-mail: www.dataprotection@cwps.ie
