UBA Pensions' Privacy Policy
This Privacy Policy regulates how personal information can be used by UBA Pensions.
The Privacy Policy
This Privacy Policy regulates how personal information is processed by UBA Pensions Custodian Limited (UBA Pensions)
In line with the provisions of the Nigeria Data Protection Act (NDPA), 2023, UBA Pensions maintains the following privacy principles, which govern how we collect, use, record, organise, structure, store, adapt or alter, retrieve, consult, disclose, disseminate, align, combine, restrict, erase or destroy and generally manage your personal data (“processing” or “process” of your Personal Data”).
Personal Data under this privacy policy is as defined by the Nigeria Data Protection Act (NDPA), 2023, and the Nigeria Data Protection Commission, which is the body empowered to make regulations or directives prescribing categories of sensitive personal data, further grounds for processing same, and the safeguards that must apply.
Basis for collecting and processing Personal Data by the UBA Pensions Custodian
UBA Pensions processes your personal data relying on any of the following legal grounds:
- Where you have opened a Retirement Savings Account (RSA) with a licensed Pension Fund Administrator (PFA), and the processing of your data is required to manage your account and provide pension-related services.
- Where your Consent as the Data Subject has been obtained.
- Offer of employment to the Data Subject. Where the processing of your personal data is necessary for the performance of a contract to which you are a party.
- For compliance with a legal obligation to which the data controller is subject.
- Where it is necessary to protect the vital interests of a person in line with Data Privacy regulations.
- Where it is necessary for the performance of a task carried out in the public interest.
- Where it is in the legitimate interests of the Custodian (except where the interests or rights and freedoms of the data subject override those interests)
Collection of Personal Information
UBA Pensions Custodian Limited (UBA Pensions) is a wholly owned subsidiary of UBA Plc, incorporated in September 2005 in accordance with the Pension Reform Act 2014 (as amended)
We are located in an access-controlled and serene environment with high safety and security standards. The quest to be the leading pension fund custodian in Nigeria drives UBA Pensions to develop high quality client services, along with best-in-class technology as key competitive advantages.
As a responsible business, UBA Pensions is committed to complying with the relevant applicable data protection regulations when processing your personal data.
The NDPA gives you certain rights regarding our use of your personal data, including the right to:
- Request access to the personal data we have collected about you to review, modify, or request deletion of your Personal Data.
- Request a copy of the Personal Data we have collected about you and correct any inaccuracies.
- Request that we cease processing your Personal Data.
- Lodge a com pliant with the Nigeria Data Protection Commission(NDPC) if you believe your rights have been violated.
- Request for your personal data to be transferred to another organisation in a commonly used and machine-readable format.
Note that some laws or our requirement to comply with a Legal obligation to which UBA Pensions is subject to may prevent us from providing access to your personal data or fully complying with your request, depending upon the circumstances and the request. For example, producing your information may reveal another person’s identity.
Thus, kindly note that we reserve the right to charge an appropriate fee for complying with your request where applicable law allows and/or deny your requests where they may be manifestly unfounded, excessive, or otherwise objectionable or unwarranted under applicable law.
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What do we need?
UBA Pensions will be known as the “controller” and “processor” of the personal data you provide to us.
- We may collect your information from our website visits, applications and channels, identification documents, curriculum vitae, interactions with relationship managers, and other third parties.
- We collect and use the personal information you provide to us as part of our services (e.g., Name, Address, Nationality, Email, Phone number, ID Number, Bank Verification Number (BVN), and family-related information).
- We may also collect visual images and video footage when you visit our premises.
- We also collect data from prospective employees as part of our recruitment processes.
- We may also process sensitive personal information for specific and limited purposes, such as detecting and preventing financial crime or making our services accessible to customers.
- We will only process sensitive personal information where we have obtained your explicit consent or, where applicable, compliance with a legal obligation or for legal proceedings/advice.
Why do we need it?
We require your basic personal data to provide you with the services you have engaged us for based on the requirements of the respective pension regulations, which align with the applicable Data Privacy regulations and our Data Privacy Framework/Policy.
What do we do with it?
We collect, store, and process some of your personal data as required by law to enable you to obtain services through us.
All the personal data that we collect from you will be held and processed securely by our Facilities at Lagos Headquarters or our Parent Company and/or authorised service providers (third parties), where applicable. Your data will be confidential unless required by a Legal or regulatory requirement for the custodian services or where there is a legal basis for the processing of your processing of your personal data.
We will take all reasonable actions to ensure that all personal data are handled securely and in a controlled manner.
How long do we keep it?
As a regulated pension custodian services institution, we will retain your personal data as may be required by regulation in the country under consideration, after which it will be disposed of as required under the respective Government laws and pension regulations.
Please note that regulations may require us to retain your personal data for a specified period, even after the end of your relationship with us.
Sharing of Personal data
Personal data may be shared with third parties and service providers to deliver our services to you in accordance with the Nigeria Data Protection Act, 2023, and any applicable Data Protection Laws.
In addition, we may disclose your personal data:
- If we are required to do so by law or legal process.
- To law enforcement authorities or other government officials.
- When we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity;
- If disclosure is necessary to protect the vital interests of a person.
- To enforce our Terms and Conditions
- To protect our property, services, and legal rights.
- To support auditing, compliance, and corporate governance functions; or
- To comply with any applicable laws.
Data Security
- At UBA Pensions, security is our top priority, and we always strive to ensure that your personal data is protected against unauthorised or accidental access. We maintain this commitment to data security by implementing appropriate physical, electronic, and managerial measures to safeguard and secure your personal data with us.
- Our web servers are protected behind “firewalls”, and our systems are monitored to prevent unauthorised access. We will not send confidential information to you by ordinary email, as the security of ordinary email cannot be guaranteed.
- All practical steps shall be taken to ensure that personal data will not be kept longer than necessary and that we will comply with all statutory and regulatory requirements concerning the retention of personally identifiable information.
- Our commitment to Data Security is paramount to us at UBA Pensions. Your personal data is kept secure in line with applicable Data Protection Regulations. Only our authorised staff, agents, and contractors (who have agreed to keep information secure and confidential) have access to this information.
Remedies for Personal data violation
If your personal data is violated at any given time, you are at liberty to contact the Data Protection Officer (DPO) at ubapencompliance@ubagroup.com
- Within a reasonable time frame of UBA Pensions receiving a complaint, UBA Pensions shall notify the Individual in line with data privacy requirements of either,
(i) UBA Pension’s position concerning the complaint and any action UBA Pensions has taken or will take in response; or,
(ii) When the individual will be informed of UBA Pension’s position on the complaint in accordance with data privacy requirements - Remedies shall include but are not limited to investigating and reporting to appropriate authorities, recovering the personal data, correcting it and enhancing controls around it.
- Within a reasonable time frame of UBA Pensions receiving a complaint, UBA Pensions shall notify the Individual in line with data privacy requirements of either,
Changes to Privacy Policy
We review this Privacy Policy regularly and reserve the right to make changes at any time to take account of changes in our business and legal requirements. We will place updates on our website (ubapensions.com)
Privacy Contact Information
If you have any questions, concerns, or comments about our privacy policy, you may contact us using the information below:
- Data Protection Office, UBA Pensions Custodian
- Email: ubapencompliance@ubagroup.com
- Phone: 02012718008
- 3rd and 4th Floor, 22b Idowu Taylor Street, Victoria Island, Lagos Nigeria.
You may also engage the supervisory authority (Nigeria Data Protection Commission) if you wish to complain about how UBA Pensions handles or has handled your personal data or have concerns about how your complaint has been handled.
