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ABBVIE PENSION AND DEATH BENEFIT PLAN
DATA PROTECTION NOTICE

Effective: 25 May 2018


The Trustees ("Trustees" or “We” or “Our”) of the AbbVie Pension and Death Benefit Plan (the “Plan”) acts as the data controller for individually identifiable data ("Personal Data") collected by us to facilitate the operation of the Plan.  This document is referred to as the "Notice" and provides information about how we collect process, and share such Personal Data. This Notice takes into account General Data Protection Regulation requirements (GDPR) and is pursuant to local law, where it exists.

Please take time to read this notice carefully. If you have any questions about how we use your personal data, please contact the Trustee Chairperson of the Plan at the contact details below.

As trustees of your pension plan, we need to collect and use personal data. This notice sets out how we collect, use and protect your personal data and your rights in relation to your personal data. This personal data is collected on our behalf as your pension scheme Trustees (“data controller”) and processed by the scheme administrator in the most part (“data processor”).

1. What Personal Data do We collect?

We hold or will collect personal data about you from a variety of sources, including personal data directly from you, or data provided by your current or past employer or data we get from other sources, such as Revenue Commissioners or personal representatives of deceased member’s estate for example.  

The type of personal data can vary depending on your personal circumstances. For example, whether you are a member or a beneficiary /potential beneficiary or if you are a member, the status of your membership (i.e. whether you are active, deferred or pensioner member) and whether you choose to take up certain options (for example, to nominate beneficiaries or apply for retirement in circumstances of ill health).

The Personal Data may include some or all of the following

  • Master data: personal and family data, including name and contact data (home address, telephone and fax numbers, and email address), gender, marital/civil partnership status, date of birth, citizenship, Personal Public Service number (PPSN), bank account details, other identification data and certain tax-related data to the extent permitted by applicable law;
  • Work contact details: work contact data, office location and address, telephone and fax numbers, and email address;
  • Organisational data: employee and membership number, employer and company code.
  • Employment data: employment data (current and past salary information and employment dates), employment status, commencement date, departure date (where applicable), extended leave periods ;
  • Benefits and data: details about your dependents and/or beneficiaries (if provided), other benefit information

We may also process sensitive Personal Data ("Sensitive Personal Data"), to the extent permitted by local law such as health data in regard to pension planning and administration.

If you provide us with personal data about your spouse, domestic civil/partner, and/or dependents (e.g., for pension benefit administration purposes), it is your responsibility to inform them of their rights with respect to such data and that you may disclose their personal data to us for these purposes. You are also responsible for obtaining the consent of these individuals, if such consent is required by law for the collection, use, storage,  transfer, and processing of their personal data.

2. For what purposes do We use and process Personal Data?

Trustees may use and process your personal data to ensure that we can properly operate and administer the pension plan, including using and processing the following categories of Personal Data for the following purposes ("Pension Scheme Purposes").

  • To provide benefits, including that benefits are calculated correctly, properly funded for and protected;
  • To communicate with you or your nominated beneficiary, including information about your membership and benefits options, to give you relevant information and to deal with queries;
  • To pay benefits, including that benefits are paid to and in respect of the right member, both now and in the future;
  • To identify members, including you and your nominated beneficiaries and ensuring that your details are up to date;
  • To implement Trustee decisions, including such items as to whether to agree to early retirement and how to distribute benefits in the case of a member’s death;
  • To perform actuarial computations, including both plan actuarial valuations or individual member benefit computations;
  • To enhance the operation of the plan, including such items as ways to improve how we operate the plan, secure and provide benefits in the future or to provide you with new options;
  • To respond to requests and legal demands from regulators or other authorities, including exercising a right or obligation conferred or imposed by law (such as complying with mandatory reporting obligations and other legal requirements);
  • To perform internal statistical or financial modelling, to assist with plan administration; and
  • To perform certain limited activities with respect to Sensitive Personal Data, including such items as health data to support insurance renewal purposes or early retirement decision-making.

Trustees will not process personal data for any other purpose incompatible with the purposes outlined in this section, unless it is required or authorized by law to comply with domestic or international legal demands, or as authorized by you.

When processing your Personal Data, we will ensure there is a legal basis for that processing. The legal basis may include,

  • To comply with our legal obligations under the documents governing the Plan and legislation governing the operation of the pension plan;
  • For the performance of rights and obligations under the Plan;
  • Where we have legitimate interest in holding and processing personal data in order to properly administer and manage the Plan and its liabilities;
  • To establish, exercise or defend legal claims.

3. in what circumstances will my Personal DATA BE transferred to other recipients?

We may transfer Personal Data with a range of third parties who would be involved in the day-to day operation and wider management of the plan. For example

  • Our advisers (such as scheme actuary, our auditors, investment and legal advisors) and their sub-contractors to facilitate the administration of the plan and your benefits;
  • Medical advisers for example where a member has requested an ill health benefit, annuity/retirement brokers and payroll providers who process pension benefits;
  • The Revenue Commissioners, Pension Authority and other Government organisations, including the Financial Services and Pensions Ombudsman and Irish courts for the purpose of processing pension sharing benefits:
  • Insurance companies;
  • Communication and printer providers who assists in various communications which are sent to members and beneficiaries;
  • AbbVie to facilitate decision making relevant to their role as sponsoring employer, as well as for normal administration reasons as checking benefits and establishing eligibility, international assignments etc.;

Note, AbbVie has concluded several data transfer agreements with its affiliates, including with its parent company AbbVie Inc., to ensure that an adequate level of data protection is in place for any personal data that is transferred internationally by them, including:

  • The AbbVie Inter-affiliate Data Transfer Agreement, which is based on the EU model contract for data transfers to controllers  and covers all personal data transfers between AbbVie affiliates worldwide;
  • The WEC-EEMEA Regional DPA Framework Agreement, covers the transfer of data for payroll and financial operations, the operation and maintenance of a regional IT infrastructure system and other activities as may be specified in annex 1.1 of that Agreement that are outsourced from AbbVie to the data processors stated in annex 5.1 of that Agreement.

Transfers of data outside the EEA

Data protection law restricts the transfers of personal data outside the EEA unless there are adequate safeguards in place to ensure that the personal data is appropriately protected.

Although the Plan is based in Ireland, your personal data may be shared outside the EEA in some circumstances where a service provider performs part of their service outside the EEA, or if you live outside the EEA or want to transfer your benefits abroad. However, personal data will only be shared outside the EEA where appropriate safeguards are in place, such as:

  • Contractual privacy & security provisions to ensure that the confidentiality and privacy of such Personal Data is protected;

For more information on any safeguards in place, please contact us as detailed below.

4. What security and storage measures do the trustees implement?

The Trustees recognize the importance of keeping your data safe and take appropriate technical and organizational security measures to safeguard your personal data, including for example ensuring restricted access to data and using secure methods to transfer data.

When sharing your data with our administrators (data processor) or other third party we will ensure that they also have measures in place to protect it and keep it confidential and agree to use the personal data only for the purposes we set out.

Pension benefits are paid over a long period of time and your rights to benefits payable under the plan is based on information that may date back years. We will keep your personal data for as long as it is needed to (i) to ensure the pension plan pays the correct benefits to you, (ii) to deal with any queries relating to your benefits as they may arise over time, (iii) to defend or pursue legal claims or is required by law or court order. We take into account our legal obligations and regulators’ expectations.

If we decide that certain personal data that we hold is no longer needed, we will take steps to ensure that it is securely destroyed, erased and made inaccessible.

5. How can I exercise access, correction, or other rights?

We have appointed a contact person identified at the end of this Notice (“Contact Person”) to respond to your access and correction requests, questions, and complaints. Under applicable data protection laws, you may be entitled to request access to and/or correct, block, or delete your personal data, transmission to another controller, or object to any use of personal data. If we will not be able to provide the requested data or make the change you request, you will be provided with reasons for such decision. Under local law you are also entitled to lodge a complaint with your local data protection supervisory authority which can be contact at +353 761 104 800 or by email at info@dataprotection.ie.

It is important that the personal data we hold about you is accurate and current. Please notify us without delay in the event of any change in the personal data we hold about you, to enable us to comply with our obligations to keep your personal data up to date.

Please note that if you refuse or fail to give us access to your personal data where requested, or you exercise your rights to restrict our ability to hold or process your personal data, this could affect your membership of the Plan and our ability to pay benefits to or in respect of you.

6. How do I reach the Contact Person for questions?

The Contact Person for AbbVie is:

Trustee Chairperson - The AbbVie Pension and Death Plan,
AbbVie Limited, 14 Riverwalk,
Citywest Business Campus,
Dublin 24, Ireland.
Telephone +353 1 4287900

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