Global Identity Privacy Notice

We are committed to protecting your privacy when dealing with your personal information. This privacy notice provides details about the information we collect about you, how we use it and how we protect it. It also provides information about your rights.

If you have any questions about how we handle your information, please contact us at dataprotection@bupa.com.

This privacy notice is solely for the data processing that takes place as a part of the Global Identity platform (the 'Platform'). For all other data not covered by this privacy notice, please refer to your local privacy notice.

1. Information about us

In this privacy notice, 'we', 'us' and 'our' mean The British United Provident Association Limited who is the data controller of your information for the purposes of the Platform. For more information about how we handle your information, please contact us at dataprotection@bupa.com.

2. What this privacy notice covers

This privacy notice applies to current employees who do not have a work email address and who will be providing a personal email address for the purpose of creating a global employee identity ("Global ID").

3. How we collect personal information

We collect personal information from you through your interactions with us, and your use of, the Platform.

4. Types of personal information

We may process standard personal information about you (for example, information we use to contact you, identify you or manage our relationship with you). Standard personal information will include contact information (for example, your name, username and personal email address) and information about the way you use your Global ID.

5. What we use your personal information for

We process your personal information for the purpose of creating a Global ID which will allow you to log in to a variety of global communication, engagement, financial and/or e-learning Bupa applications and systems.
Your personal email address will also be used to communicate with you for the purpose of administering your account and to provide service notifications from other service providers you access your Global ID with.

6. Legal grounds

By law, we must have a lawful reason for processing your personal information. These are set out below.
We process your personal information about you if:

• it is in our own or a third party's legitimate interests (see below for more details) or
• we have to or are allowed to do so by law (for example, in line with employment and social-security laws).

7. Legitimate interest

Legitimate interest is one of the legal reasons why we may process your personal information. Taking into account your interests, rights and freedoms, the legitimate interest which allows us to process your personal information is to facilitate our employees’ access to global or local centralised platforms which are required for the management, administration and growth of careers at Bupa, now and in the future.

Sharing your information

We share your information, for the purposes set out in this privacy notice, with:

• other members of the Bupa Group; and
• the police and other law-enforcement agencies to help them perform their duties, or with others if we have to do this by law or under a court order.

If we share your personal information, we will make sure appropriate protection is in place in line with data protection laws.

8. Transferring information outside the UK and the European Economic Area (EEA)

We deal with many international organisations and use global information systems. As a result, we transfer your personal information to countries outside the UK and the EEA (the EU member states plus Norway, Liechtenstein and Iceland), for the purposes set out in this privacy notice.

We take steps to make sure that, when we transfer your personal information to another country, appropriate protection is in place in line with data protection laws. Often, this protection is set out under a contract with the organisation who receives that information. For more information about the measures we take to protect your data, please contact us at dataprotection@bupa.com.

9. How long we keep your personal information

In general, we will keep your information for seven years after the date you leave your employment. However, there may be circumstances that mean we must keep your personal information for longer. For example, if there was an ongoing tribunal, court or another type of proceeding, we would keep your information until the end of those proceedings and any possible appeals, and the end of any relevant claims periods.

10. Your rights

You have rights to have access to your information and to ask us to correct, erase and restrict use of your information. You also have rights to object to your information being used; to ask us to transfer information you have made available to us; to withdraw your permission for us to use your information; and to ask us not to make automated decisions which produce legal effects concerning you or significantly affect you. Please contact us at dataprotection@bupa.com if you would like to exercise any of your rights.

11. Data protection contacts

If you have any questions, comments, complaints or suggestions relating to this notice, or any other concerns about the way in which we process information about you, please contact our Data Protection Officer and Privacy Team at dataprotection@bupa.com.

You also have a right to make a complaint to your local privacy supervisory authority. Our main office is in the UK, where the local supervisory authority is the Information Commissioner (ico.org.uk).

Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
United Kingdom
SK9 5AF

Phone: 0303 123 1113 (local rate) or 01625 545 745 (national rate).

You can also make a complaint with another supervisory authority which is based in the country or territory where:

• you live
• you work
• the matter you are complaining about took place.