Privacy notice for visitors to www.tpt.co.uk (“the Website”)
Last updated April 2025.
1. Introduction
This privacy notice applies to all visitors to our Website www.tpt.co.uk and other individuals who contact us or interact with us through that Website.
It explains what personal information Verity Trustees Limited (the “Trustee”) and its subsidiary companies TPT Retirement Solutions Limited and TPT Investment Management Limited (the “Companies”) (together “we”, “our” or “us”) collects about you, how we use that personal information, how we store it and with whom we share it. We are responsible for your personal information (“known as a “controller”). We are committed to protecting your information and acting in accordance with your rights under data protection law.
There may be additional personal (and other) information that we have or collect about you or your company pursuant to other relations which is subject to other notices, agreements and rules. To find out how we use your data processed by us if you visit our other Websites, Portals, Platforms, Online applications or Apps (for which you will need to register).
2. Personal Information we collect
2.1. Sources of Personal Information
We collect and process the following personal information about you only if you complete and submit a form on our Website: your personal details such as your name, membership/employer number, company, job title, email address and phone number.
We collect and process generic information about you when you visit the Website whether or not you complete and submit a form. We use third-party data processors and further detail on this can be found below. In relation to these third-party data processors, we are the data controller.
If you contact us, we will typically keep a record of that correspondence for example from live chat interactions. If we ask you to complete surveys that we use for research purposes, we will collect the information provided in the completed survey.
We collect statistical information sometimes using third parties about your use of the Website to help us develop and improve the Website and to better understand your user’ needs and to provide relevant and helpful information to you. Information we collect includes but is not limited to information about your computer or devices such as domain name, browser type and version, operating system, IP address, device screen size, unique device identifiers, geographic location (country only) and preferred language used to display our website, cookie information (see our Cookie policy for more information), time stamp, what web pages you visit on the Website, what information you download and how long you spend on each page.
2.2. Types of personal information collected
The personal information we hold and process includes:
- General data – includes your name, membership/employer number, company, job title, email address and phone number if you submit a form on our Website;
- Chatbot transcripts – includes information obtained during if you have conversations with our chatbots
- Job applications – includes any information you submit in applying for a job with us (which will be processed by a third party when you visit https://tpt.current-vacancies.com/Careers/TPT-Vacancy-Search-Page-2084);
- Customer feedback – includes responses to surveys, complaints and details of your customer experience.
2.3. Uses of personal information
The main purposes for which we use personal information are to:
- Ensure that content from our Website is presented in the most effective manner for you and your device;
- Allow you to use different resources and materials on our Website;
- Personalise the way information on our Website is presented to you. To give you information on products and services which you have asked for or which we think may be of interest to you;
- Improve our products and services, provide staff training and maintain information security, including by recording and monitoring live chat sessions;
- Improving processes and our use of technology, including testing and upgrading of systems, developing solutions for access to historic data and to learn about other processes we can use to improve the administration of the pension schemes, internal operations and other business activities;
- Conduct customer insight analysis, market research and focus groups, including customer segmentation, campaign planning, creating promotional materials, gathering customer feedback and customer satisfaction surveys;
- Where you have expressed an interest in our products and services, you may receive updates on our products, services, promotions, and news, delivered to your provided email address. You can unsubscribe at any time by clicking the "unsubscribe" link at the bottom of our emails;
- Deliver advertisements to our Website visitors on third party websites based on the pages they have visited.
- Manage complaints, including to allow us to respond to any current complaints, or challenges you or others might raise later, for internal training and monitoring purposes and to help us to improve our complaints handling processes. We may be obliged to forward details about your complaints, including your personal information, to the appropriate authorities, e.g. the relevant ombudsman;
- Manage feedback and queries, and handle requests to exercise data subject rights;
- Manage our business operations, including by carrying out internal audits, quality assurance and training, financial analysis and accounting, producing management information and performing administrative activities in connection with the services we provide;
- Comply with applicable legal, regulatory and professional obligations, including cooperating with regulatory bodies, e.g. the FCA, Pensions Regulator, ICO and government authorities, to comply with ongoing regulatory and compliance obligations, law enforcement and manage legal claims;
- Establish, enforce and defend our legal rights or those of third parties, including enforcing our terms and conditions, pursuing available remedies and limiting our damages;
- Buy, sell, transfer or dispose of any part of our business;
- Archiving, scientific or historical research or statistical purposes.
2.4. Lawful bases for uses of personal information
We are committed to collecting and using personal information in accordance with applicable data protection laws. By law, we must have a legal justification, known as a lawful basis, in order to use your personal information for the purposes described in this Privacy Policy. Depending upon the purpose, our lawful basis will be one of the following:
- Performance of a contract – to provide you with our products and services in accordance with their terms;
- Compliance with a legal obligation – to meet responsibilities we have to our regulators, government bodies, tax officials, law enforcement, or other legal responsibilities;
- Legitimate interests – to operate and improve pension options and services and keep people informed about them or for any other purposes we identify as appropriate to our business needs, or those business needs of a third party;
- Consent – where we have obtained appropriate consents to collect or use your personal information for a particular purpose.
Where we rely on legitimate interests as our lawful basis, we are required to carry out a balancing test to ensure that our interests, or those of a third party, do not override the rights and freedoms that you have as an individual. The outcome of this balancing test will determine whether we can use your personal information for the purposes described in this Privacy Policy. Where we rely on the lawful basis of legitimate interests, the interests being relied upon will usually be: - To help us better understand our customers and improve our customer engagement including by carrying out marketing analytics and profiling, e.g. by making certain predictions and assumptions about your interests;
- To provide you with helpful information relating to your pension savings and about useful tools for managing and engaging with your pension savings. These are not marketing communications;
- To comply with our legal and regulatory obligations, guidelines, standards and codes of conduct, e.g. background checks or the prevention, detection and investigation of financial crime or fraud;
- To improve and develop our business, products and services, or those of a third party, e.g. to ensure the accuracy of customer data and to develop our pricing and risk methods and models;
- To retain records for a period of time in order to ensure we have appropriate records in place in respect of any future complaints or claims that may be made against us;
- To safeguard our business, employees and customers, or those of a third party, e.g. maintaining the security of our IT network and information, enforcing claims, including debt collection;
- Ensuring that the pension schemes are run in a cost effective way and that you are offered appropriate pension options, such interests in each case not being overridden by your privacy interests;
- For the performance of a task carried out in the public interest where it is necessary;
- To facilitate the purchase, sale, transfer or disposal of any part of our business;
- To analyse and assess competition in the e.g., by carrying out market research.
3. Who personal information is shared with
In connection with the purposes set out above, we will sometimes share personal information within our group of companies and third parties, including:
- Providers who help operate our IT and back office systems and our information security controls;
- Our auditors, accountants, legal advisers, financial institutions and professional service firms who act on our or your behalf;
- Research agencies and providers of market research services, including customer feedback surveys;
- Other providers of services to us, communication, IT and hosting, archiving, marketing, and tracing providers;
- Data analysts and providers of data services who support us with developing our Website;
- Financial crime detection agencies, sanctions-checking providers, financial services organisations and third parties who maintain fraud detection databases or provide assistance with investigation in cases of suspected fraud;
- Regulators who regulate how we operate;
- Government agencies and regulatory bodies including the police and courts;
- Industry bodies;
- Third parties in connection with any sale, transfer or disposal of our business;
- Other persons from time to time when the disclosure is needed to exercise or protect legal rights, including those of the Trustee or other stakeholders or in response to requests from individuals or their representatives who seek to protect their legal rights or such rights of others.
4. Transfers of your information abroad
Sometimes we, or third parties acting on our behalf, may need to transfer personal information outside of the UK. We’ll always take steps to ensure that any transfer of personal information outside the UK is carefully managed to protect your privacy rights and ensure that adequate safeguards are in place. We comply with the requirements of applicable data protection laws in relation to international data transfers by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to by a competent approving authority provide an adequate level of protection for personal data; and
- When transferring personal data to third-party processors or controllers, we typically use standard contractual clauses approved for use by a competent approving authority.
Further details of these transfers including the form of safeguards used are available from us on request using the contact details below.
5. Retention of your information
We keep your information for as long as is reasonably required for the purposes explained in this Privacy Policy and in order to meet our legal or regulatory responsibilities.
To support us in managing how long we hold your data and our record management, we maintain a data retention policy which includes clear guidelines on data retention and deletion.
6. Your rights
You have legal rights under data protection laws in relation to your personal information.
We may ask you for proof of identity when you make a request to exercise any of these rights. We do this to ensure we only disclose information to the right individual.
We aim to respond to all valid requests within one month. It may take us longer if the request is particularly complicated or we need further information. We’ll let you know if we think a response will take longer than one month. We may also ask you to provide more detail about what you want to receive or are concerned about.
We may not always be able to do what you have asked. This is because your rights will not always apply, e.g. if it would impact the duty of confidentiality we owe to others, or if the law allows us to deal with the request in a different way. We will always explain to you how we are dealing with your request. In some circumstances (such as the right to erasure or withdrawal of consent), exercising a right might mean that we can no longer provide any products to you.
Your rights are as follows:
Access to your personal information
You may ask us for a copy of your personal information together with specified details about how we use your information. This is commonly known as a ‘subject access request’.
If you wish to make a subject access request, please contact us using the details set out below.
Rectification of your personal information
We do our best to ensure that your personal information is accurate and kept up to date. If you believe your information is inaccurate or incomplete, then please contact us using the details set out below to request that we amend or update it.
Erasing your personal information
- You may ask us to erase your personal information, but this right only applies in certain circumstances, e.g. where:
it is no longer necessary for us to use your personal information for the original purpose; - our lawful basis for using your personal information is consent and you withdraw your consent; or
- our lawful basis is legitimate interests and there is no overriding legitimate interest to continue using your personal information if you object.
This isn’t an absolute right and we have to balance your request against other factors such as legal or regulatory requirements, which may mean we cannot erase your personal information.
Restricting processing of your personal information
You may ask us to stop using your personal information in certain circumstances such as:
- where you have contacted us about the accuracy of your personal information and we are checking the accuracy; or
- if you have objected to your personal information being used based on legitimate interests.
This isn’t an absolute right and we may not be able to comply with your request.
Data portability
In some cases, you can ask us to transfer personal information that you have provided to us to another third party of your choice. This right only applies where we have justified our use of your personal information based on your consent or the performance of a contract with you.
This isn’t an absolute right and we may not be able to comply with your request.
Right to object
You may also object where you have grounds relating to your particular situation and the lawful basis we rely on for using your personal information is our (or a third party's) legitimate interests. However, we may continue to use your personal information where there are compelling legitimate grounds to do so.
Withdrawing consent
In some circumstances we ask for your consent to use your personal information. You have the right to withdraw your consent to the use of your information to the extent such use is based on your consent. You can notify us of your withdrawal of consent by contacting us at the details set out below. This will not affect the lawfulness of any processing conducted before your consent was withdrawn.
7. Contacting us or the Information Commissioner
If you wish to exercise your rights described in paragraph 6 above, or if you have any questions about our use of information or this notice, please contact us by letter, phone call or email at:
TPT Retirement Solutions Limited, Verity House, 6 Canal Wharf, Leeds LS11 5BQ
privacy@tpt.co.uk
0113 394 2677
If you’re not happy with the way we’re handling your personal information, you have a right to make a complaint with your local data protection supervisory authority at any time. In the UK this is the Information Commissioner's Office (ICO). We ask that you please attempt to resolve any issues with us before contacting the ICO.
8. Updates
This Privacy Policy is updated from time to time to take account of changes in our business activities, legal requirements and to make sure it’s as transparent as possible, so please check back here for the current version. You can see when this Privacy Policy was last updated by checking at the top of this page.