Privacy Notice

This Privacy Notice is applicable to our suppliers, contractors and sub-contractors relationships.  If you are a customer or potential customer of Prudential International Assurance plc (PIA) please see our customer privacy notice via the following link:

PIA Privacy Notice

We, Prudential International Management Services Limited (PIMS), take the privacy and protection of your personal information seriously. PIMS will operate as the data controller in respect of the data we collect about you.

So we've set out below information about our processing of your personal information, what rights you have, and how you can get in touch if you want to know more.

When we say personal information, we mean information about you, such as your name, date of birth and contact details. We collect personal information from you that is necessary for us to fulfil our contractual relationship with you or to comply with legal, statutory, regulatory or contractual requirements. Unfortunately, if you don't provide all of the information we require this may mean we are unable to have a contractual relationship with you.

Part A – How we use your personal information and why

We, PIMS, together with M&G plc Group* and our Business Partners**, will use the personal information you provide to us, together with other information, for the following purposes:

• compliance with the applicable legal, regulatory or professional requirements (anti-money laundering);
• addressing requests and communications from regulators, government bodies and other competent authorities;
• general contract administration, financial accounting (invoicing) and statistics;
• internal compliance and risk analysis (including investigating or preventing security incidents);
• protecting our rights and legitimate interests;
• general supplier, contractor or sub-contractor relationship purposes;
• utilisation of internal or hosted (cloud) information technology systems, services and applications (for communication, data sharing, data storage and archiving purposes).

Some of the purposes above are necessary to allow us to perform our contractual obligations to our suppliers, contractors or sub-contractors or to comply with applicable laws and regulation.  We’ll use your personal information in accordance with this data privacy notice. We may use your personal information to enhance our operative systems to enable us to provide you with efficient and effective business services.  For example, we use your personal information:

• to detect and prevent financial crime;
• market research, data analytics including profiling, staff training and provision of online services;
• for management information purposes including risk assessments, performance and management reporting.

Where we rely on legitimate interests, we will always balance this against your rights and freedoms. Where your rights override our legitimate interests we will cease to process personal data.

We do not collect or process any ‘sensitive’ or ‘special categories’ of personal data as defined in the Irish Data Protection Act 2018 (“Act 2018”).

Please note that this Privacy Notice does not include the information on the processing of personal data for the purposes of marketing, direct mailing and recruitment. The processing of personal data for such purposes is described in the specific privacy notices that may be also part of your consent with such personal data processing (where relevant). We do not process your personal data for direct mailing and marketing purposes without your explicit consent. However, we may ask you for such consent in the course of personal data processing.

Who we share your personal information with and why

We are the data controller in respect of the personal information we collect about you and in this capacity we will share your personal information within M&G plc and with our Business Partners for any of the purposes set out in Part A above.  If appropriate, we may also pass on your personal information to financial crime prevention agencies, legal, regulatory or government bodies.

As we, M&G plc, and some of our Business Partners are global companies, we might need to send your personal information to countries that have different data protection laws to the European Economic Area. These transfers will only be to countries in respect of which the European Commission has issued a data protection 'adequacy' decision, or to other countries, such as India or the United States of America, but only where appropriate safeguards have been put in place first. Such safeguards being in line with Act 2018 requirements.  In more limited circumstances, we may also need to rely on a derogation under applicable privacy laws.

If you want to know more about these safeguards - like our use of the European Commission's Model Clauses which govern the transfer of information outside of the European Economic Area - further information is available on request.  Just contact us at the details noted in Part D below.

We keep your personal information for a set amount of time

We'll keep your personal information for seven years following the end of our contractual relationships with our suppliers, contractors or sub-contractors or as required by the applicable laws or relevant regulations.  It'll always be in line with our data retention policy.

Part B – Reference checks

We may use approved credit reference agencies, tracing companies, financial crime prevention agencies, or publicly available information, to help us to check your identity, as well as to prevent fraud and money laundering. Results of these may be recorded for future reference.

Any transfer of your personal information will always be done securely.

Part C – You're in control

When it comes to how we use your personal information, you've got the right to:

• request a copy of your personal information for free. We shall respond as soon as reasonably possible and at the latest within one month of the date of receiving your request;
• in certain circumstances, you are able to request that we move your personal information to another organisation if you want us to;
• request that we correct anything that's wrong, or complete any incomplete personal information;
• ask us to delete your personal information if it is no longer needed for the purposes set out in Part A or if there is no other legal basis for the processing;
• limit how we use your personal information or withdraw your consents you have given for the processing of your personal information;
• object to us using your personal information for our legitimate interests;
• complain to a data protection authority or another independent regulator about how we're using it.

If you want to do any of these things, or would like an explanation as regards these rights, we've explained how you can get in touch in the 'Contact Us' section.

If you do need to speak to us, it'll be useful to have to hand that the data controller of your personal information is PIMS. PIMS has also appointed a Data Protection Officer who can be reached at the details shown in the 'Contact Us' section of this document.

Part D – Acting on someone else's behalf?

If you give us personal information about another person (or persons), we'll take that to mean they have appointed and authorised you to act on their behalf. This includes providing consent to:

• our processing of their personal information (as we've explained in Parts A and B);
• you getting any data privacy notices on their behalf.

If for any reason you are concerned as to whether you are permitted to provide us with the other person's information, please contact us via the contact details provided in the 'Contact Us' section before sending us anything.

Contact Us

If you want to exercise your rights in Part C or if you require any other information about any other part of this privacy notice, you can contact us in a number of different ways.

Write to us at:

Data Protection Officer
Prudential International
Montague House
Adelaide Road
Dublin 2

Email us on: pia.dpo@prudential.co.uk

*M&G plc Group means any directly or indirectly connected companies of PIMS within M&G plc Group (including but not limited to Prudential International Assurance plc, The Prudential Assurance Company Limited, Prudential Distribution Limited, Prudential Pensions Limited, and M&G Wealth Advice Limited, Prudential Services Limited, PGDS (UK ONE) Limited, M&G Global Services Private Limited, M&G Investments Group and Prudential Corporate Pensions Trustee Limited).

**Business Partners means our service providers, accountants, auditors, IT service and platform providers, intermediaries, reinsurers, retrocessionaires, investment managers, agents, pension trustees (and other stakeholders), scheme advisors, introducers, selected third party financial and insurance product providers and our legal advisers.