This section sets out the purposes for which we use personal information that we collect and, in compliance with our obligations under European law, identify the “legal grounds” on which we rely to process the information.
European Data Protection Laws allows companies to process personal information only when the processing is permitted by the specific “legal grounds” set out in the law (the full description of each of these grounds can be found here).
Please note that in addition to the disclosures we have identified below, in some circumstances we will also disclose personal information to service providers, contractors, agents and affiliates of the Company that perform activities described in this notice on our behalf.
(a) To communicate effectively with you and conduct our business
To conduct our business, including to respond to your queries, to otherwise communicate with you, or to carry out our obligations arising from any agreements entered into between you and us, which in some circumstances may include passing your data to third parties such as agents or contractors or to our advisors (e.g. legal, financial, business or other advisors).
Use justification: contract performance and legitimate interests (to enable us to perform our obligations and provide our services to you)
(b) To provide you with marketing material
To provide you with updates and offers, where you have chosen to receive these. We may also use your information for marketing our own products and services to you by post, email, SMS, phone and fax and, where required by law, we will ask for your consent at the time we collect your data to conduct any of these types of marketing. We will provide an option to unsubscribe or opt-out of further communication on any electronic marketing communications sent to you or you may opt out by contacting us as set out below.
Use justification: consent and legitimate interest (to keep you updated with news in relation to our products and services)
(c) For research and development purposes
To analyse your personal information together with information from other clients for data analytics purposes, including to create insights, reports and other analytics to better understand and improve the quality of and market Mercer’s advice, products and services. The output of such analytics does not identify particular clients or individuals.
Use justification: legitimate interests (to allow us to improve our services)
(d) To monitor certain activities
To monitor queries and transactions to ensure service quality, compliance with procedures and to combat fraud.
Use justification: legal obligations, legal claims and legitimate interests (to ensure the quality and legality of our services)
(e) To inform you of changes
To notify you about changes to our services and products
Use justification: legitimate interests (to notify you about changes to our services)
(f) To ensure website content is relevant
To ensure that content from our websites is presented in the most effective manner for you and for your device, which may include passing your data to business partners, suppliers and/or service providers.
Use justification: contract performance, legitimate interests (to allow us to provide you with content and services on the websites)
(g) To reorganise or make changes to our business
If we: (i) are subject to negotiations for the sale of our business or part thereof to a third party; (ii) are sold to a third party; or (iii) undergo a re-organisation, we may need to transfer some or all of your personal information to the relevant third party (or its advisors) as part of any due diligence process for the purpose of analysing any proposed sale or re-organisation. We may also need to transfer your personal information to that re-organised entity or third party after the sale or reorganisation for them to use for the same purposes as set out in this notice.
Use justification: legitimate interests (in order to allow us to change our business)
(h) In connection with legal or regulatory obligations
We process your personal information to comply with our regulatory requirements or as part of dialogue with our regulators as applicable which may include disclosing your personal information to third parties, the court service, regulators and/or law enforcement agencies in connection with enquiries, proceedings or investigations by such parties anywhere in the world or where compelled to do so. Where permitted, we will direct any such request to you or notify you before responding unless to do so would prejudice the prevention or detection of a crime.
Use justification: legal obligations, legal claims, legitimate interests (to cooperate with law enforcement and regulatory authorities)
(i) For Fraud, Anti-Money Laundering and Sanctions Screenings
When establishing or maintaining client relationships for the provision of certain services we process your personal information for the purposes of carrying out fraud, anti-money laundering or sanctions violations checks.
Use justification: legal obligations
(j) To provide Actuarial Services
Mercer and our Scheme Actuaries process personal data to provide actuarial services including valuing our clients’ pension schemes, carrying out complex calculations of individual pension benefits, advising regarding the management of pension scheme liabilities, complying with statutory duties or providing such other services requested by our clients and carried out by a member of the Institute & Faculty of Actuaries, including any Scheme Actuary.
Use justification: legitimate interests