TIAA Ltd. (“TIAA”, “we”, “us”, or “our”) is strongly committed to protecting personal data. This privacy statement describes why and how we collect and use personal data and provides information about individuals’ rights. It applies to personal data provided to us, both by individuals themselves or by others. We may use personal data provided to us for any of the purposes described in this privacy statement or as otherwise stated at the point of collection.
Personal data is any information relating to an identified or identifiable living person. TIAA processes personal data for numerous purposes, and the means of collection, lawful basis of processing, use, disclosure, and retention periods for each purpose may differ.
When collecting and using personal data, our policy is to be transparent about why and how we process personal data.
We take the security of all the data we hold very seriously. We adhere to internationally recognised security standards and our information security management system relating to client confidential data is independently certified as complying with the requirements of ISO/IEC 27001:2013. TIAA is also Cyber Essentials certified, and as such meets the Cyber Essentials implementation profile [BIS/14/696]. TIAA’s ICT defences are secure against commodity based cyber-attacks, ensuring your personal and sensitive information is protected to a high standard. We have a framework of policies, procedures and training in place covering data protection, confidentiality and security and regularly review the appropriateness of the measures we have in place to keep the data we hold secure.
When and how we share personal data and locations of processing
We will only share personal data with others when we are legally permitted to do so. When we share data with others, we put contractual arrangements and security mechanisms in place to protect the data and to comply with our data protection, confidentiality and security standards.
Personal data held by us may be transferred to:
- Third party organisations that provide applications/functionality, data processing or IT services to us. We use third party support to provide high level assistance for some of our key IT systems. For example, providers of information technology, cloud based software as a service providers, identity management, website hosting and management, data analysis, data back-up, security and storage services. The servers powering and facilitating any cloud infrastructure are located in secure data centres in the United Kingdom, and personal data may be stored in any one of them in a securely encrypted format.
- Third party organisations that otherwise assist us in providing goods, services or information
- Auditors and other professional advisers
- Law enforcement or other government and regulatory agencies or to other third parties as required by, and in accordance with, applicable law or regulation
Occasionally, we may receive requests from third parties with authority to obtain disclosure of personal data, such as to check that we are complying with applicable law and regulation, to investigate an alleged crime, to establish, exercise or defend legal rights. We will only fulfil requests for personal data where we are permitted to do so in accordance with applicable law or regulation.
Data controller and contact information
The data controller is TIAA Ltd. (the limited company registered in England under registration no. 04546319 and with its registration address at Artillery House, Fort Fareham, Newgate Lane, Fareham, PO14 1AH).
If you have any questions about this privacy statement or how and why we process personal data, please contact us at:
Data Protection Officer
Phone: 0845 300 3333
Individuals’ rights and how to exercise them
Individuals have certain rights over their personal data and data controllers are responsible for fulfilling these rights. Where we decide how and why personal data is processed, we are a data controller and below we have included further information about the rights that individuals have and how to exercise them.
Access to personal data
You have a right of access to personal data held by us as a data controller. This right may be exercised by emailing us at firstname.lastname@example.org. We will aim to respond to any requests for information promptly, and in any event within the legally required time limits (1 month).
Amendment of personal data
To update personal data submitted to us, you may email us at email@example.com.
When practically possible, once we are informed that any personal data processed by us is no longer accurate, we will make corrections (where appropriate) based on your updated information.
Withdrawal of consent
Where we process personal data based on consent, individuals have a right to withdraw consent at any time. We do not generally process personal data based on consent (as we can usually rely on another legal basis). To withdraw consent to our processing of your personal data please email us at firstname.lastname@example.org or, to stop receiving an email from a TIAA marketing list, please click on the unsubscribe link in the relevant email received from us.
Other data subject rights
This privacy statement is intended to provide information about what personal data we collect about you and how it is used. As well as rights of access and amendment referred to above, individuals may have other rights in relation to the personal data we hold, such as a right to erasure/deletion, to restrict or object to our processing of personal data and the right to data portability.
If you wish to exercise any of these rights, please send an email to email@example.com.
We hope that you won’t ever need to, but if you do want to complain about our use of personal data, please send an email with the details of your complaint to firstname.lastname@example.org. We will look into and respond to any complaints we receive.
You also have the right to lodge a complaint with the Information Commissioner’s Office (“ICO”) (the UK data protection regulator). For further information on your rights and how to complain to the ICO, please refer to the ICO website.
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Changes to this privacy statement
We recognise that transparency is an ongoing responsibility so we will keep this privacy statement under regular review.
This privacy statement was last updated on 14th September 2021.