Privacy Policy
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1.0 Introduction
1.1 Pursuant to its statutory mandate of administering the pension of contributors and retirees under the Contributory Pension Scheme (CPS) in Nigeria, Trustfund Pensions Limited collects and keeps in custody, personal data of pension contributors, retirees and their related persons, such as beneficiaries, next-of-kins and their employers. The data include but are not limited to the biometrics and bio data of contributors, retirees and related persons.
1.2 This Data Privacy Policy (the Policy) is, therefore instituted by Trustfund Pensions Limited to inform pension contributors, retirees and other related persons of the protection of their personal data collected and stored by Trustfund Pensions Limited pursuant to the performance of its statutory responsibilities. The Policy also explains how the data are collected, stored, used, and in addition the exceptions where such data may be disclosed.
2.0 Nature and reason for collection of personal data
2.1 Pursuant to the provisions of the Pension Reform Act (PRA) 2014 and extant regulations, Trustfund Pensions Limited collects data of pension contributors, retirees, and their stated related persons; This information may include name, gender, marital status, date of birth, nationality, National Identification Number, employment, and Next-of-Kin detail, amongst others.
2.2 Trustfund Pensions Limited collects the personal data of a pension contributor to open a Retirement Savings Account (RSA) for him/her and to administer the retirement benefits under the CPS. In this regard, it is necessary to collect personal data of contributors to ensure that uniquely identifiable persons are registered under the CPS and that their data are linked to their various employers. This also facilitates the remittance and accurate computation of pension contributions and other entitlements to the RSAs of contributors and seamless payment of benefits. Collection of data of the next-of-kins and beneficiaries of contributors and retirees further ensures that Trustfund Pensions Limited has contact with their chosen closest relatives.
3.0 Consent of Data Subject
Collection of data of the contributors, retirees and/or their related persons by Trustfund Pensions Limited shall be subject to the consent and authorization of the data subjects. Consequently, RSA registration and data recapture forms, including the electronic formats, contain data authorization clauses which are activated when the data subject completes the form.
3.1 Processing and Protection of Personal Data
3.2 Trustfund Pensions Limited shall process personal data of contributors, retirees and other related persons only for the purpose for which the data is collected. Trustfund Pensions Limited shall process such data on both electronic and manual platforms, as may be required.
4.0 Only authorized officers of Trustfund Pensions Limited shall have access to the personal data collected. Pursuant to Section 113 of the PRA 2014, such authorized persons shall include every member of the Board, officer, employee, agent or any other person engaged or authorized by Trustfund Pensions Limited to examine any document or make an inquiry thereto. Such authorized persons have confidentiality obligation not to disclose or use any information or data of such person obtained directly or indirectly, except under the express authority of Trustfund Pensions Limited or as otherwise provided for under this Policy or required by law.
4.1 Storage and Retention of Personal Data
4.2 Trustfund Pensions Limited shall securely store the personal data of pension contributors, retirees and related persons collected in hard paper copies, computers, servers, and other electronic devices.
5.0 Trustfund Pensions Limited shall hold personal data of contributor, retirees and related persons for as long as may be deemed necessary to keep track of contribution remittances and payments of benefits. The retention period shall however not be less than ten (10) years, pursuant to the provisions of the National Archives Act, CAP.N6 Laws of the Federation of Nigeria, 2004.
5.1 Disclosure of Personal Data
5.2 Without prejudice to the foregoing provisions, however, Trustfund Pensions Limited may be obliged to disclose personal data in its custody in the following circumstances:
- Where disclosure is made in compliance with statutory obligation or pursuant to an order of a court of competent jurisdiction.
- Where the data owner has expressly consented to the disclosure or instructed that his/her data be fully or partially disclosed to a named person or persons;
- Where the disclosure is made to the owner of the data for his/her personal use or record.
6.0 Violation of Data Privacy and Remedies
Contributors, retiree, or their related persons whose data privacy rights are violated under this Policy shall report in writing, such violation to National Pension Commission and Trustfund Pensions Limited for immediate redress. Pursuant to the provisions of the PRA 2014 and extant Regulations of the Commission, the Commission shall direct Trustfund Pensions Limited to redress the right of the affected contributor, retiree, or related person immediately. Failure of Trustfund Pensions Limited to restore such rights as appropriate shall entitle the contributor, retiree, or related person to legal remedies, subject to the provisions of the PRA 2014.
6.1 Governing Laws
This Data Privacy Policy is issued by Trustfund Pensions Limited, pursuant to the provisions of the PRA 2014, and is consistent with Sections 13 of the Constitution of the Federal Republic of Nigeria 1999 (as amended), Clause 2.5 (a-i) of the Nigeria Data Protection Regulation 2019 issued by the National Information and Technology Development Agency (NITDA) and Article 8 of the International Convention on Data Protections.
6.2 Review and Enquiries
This Privacy Policy is subject to review by Trustfund Pensions Limited from time to time as the need arises. All enquiries regarding the Policy should be directed to the e-mail address Compliance@Trustfundpensions.com
