Pension Potential - Privacy Policy

Punter Southall Defined Contribution Consulting Limited (“Pension Potential”, “we”, “us” or “our”) is committed to protecting and respecting your privacy.

This Privacy Policy explains how we use any personal information we may collect from you or you provide to us when we interact with you, for example, where you are an individual client receiving our Pension Potential services.

As the Data Controller of the personal data we collect from or about you, we are responsible for deciding how we hold and use that personal data and we are required to provide you with the information contained in this Privacy Policy. It is important that you read this Privacy Policy so that you are aware of how and why we are using your personal data and how we will treat it.

How to contact us

Our Data Protection Officer is Richard Garmon-Jones, who you can contact:

You can also contact us:

The type of data we collect about you, the basis for collecting it, and how we will use it

We will only use your personal data where we have a lawful basis to use it.

We will only use your data where it is necessary for us to perform our contract with you (for example, to arrange annuities you have requested), or in a way which might reasonably be expected as part of running our business and which does not materially impact your interests, rights or freedoms. For example, to provide you with information about our services that you have requested. Please get in touch with us using the contact details provided at the beginning of this Privacy Policy if you would like further information about this.

We may sometimes need to use data to comply with our legal obligations (for example to pass on details related to fraud).

In other instances, we will ask for your consent to use your data, for example, to record our calls with you or to send you direct marketing.

Further details of how we use your personal information are provided below.


Personal data may include the following:

Basis for collecting the data

Providing the Pension Potential service including providing guidance and arranging annuities.

Name, Date of Birth, Residential Address, Telephone Number, Email Address, health and lifestyle details.

We will initially process your data for the legitimate interest of enabling us to provide you with information about your pension options and to provide annuity quotations.

If you instruct us to arrange an annuity on your behalf, we will process data under the terms of our contract with you.

Dealing with any queries, issues or complaints raised by you and providing any support or customer service you have requested.

Name, Residential Address, Email Address, Telephone Number, any other personal data you provide to us.

We will process your data for the legitimate interest of dealing with your query, issue or complaint or providing you with the support/customer service you have requested.

Preventing and detecting fraud.

Name, Date of Birth, Residential Address, Telephone Number, Email Address, Payment details and details of your transactions.

We will process your data to meet our legal obligations.

Sending you email marketing about our products and services which we think will you interest you.

Name, Email Address.

Where you consent.

To undertake anti-money laundering checks

Name, Date of Birth, Residential Address, National Insurance Number, Passport Number.

We will process your data to meet our legal obligation to perform these checks.

Call recording

Any personal data you provide to us during calls.

We may record our audio or video conversations with you but only where you have consented to us doing so.

This is to ensure that we have an accurate record of your instructions, which we may refer to in the future to confirm what was discussed, and to help us to provide products and services that are suitable for your needs. The recording may also be used for internal training and monitoring purposes.

You can withdraw your consent to our use of call recordings at any time by contacting us using the details above.

Administering and improving our website and Pension Potential services,

Any personal data we collect about you when you use our website or the Pension Potential services.

We will process your data for the legitimate interest of administering and improving our website and services.

Special categories of personal data

In order to provide the annuity quotations to you, we may be required to collect, process and disclose special categories of personal data about you. Special categories of personal data include information about your race, ethnic origin, genetics, biometrics (where used for ID purposes), physical or mental health, sexual orientation, political and religious beliefs, or membership of groups such as trade unions.

Typically, to provide Pension Potential service to you, we may need to process data about your physical or mental health in relation to enhanced annuities. For example, you may be required to complete a medical and lifestyle questionnaire to allow us to provide enhanced annuity quotes.

We will only process special categories of personal data about you where:

  • the processing is necessary for an insurance purpose for reasons in the substantial public interest, so such processing is permitted by the Data Protection Act 2018 (Sch1, Part 2, s 20(1)); or
  • we have your explicit consent to process such data.

If at any time you want to withdraw your consent to our processing of your special categories of personal data, you can contact us on the details shown above.

Disclosure of your information

We will share your data with other companies to help us provide our services to you. The Recipients set out below may process your data:

Organisation / Entity

Information shared

Reason for sharing

Annuity providers

Personal information you have provided in relation to the annuity being used or applied for

To obtain quotations, arrange annuities for you, and to help administer them

Intelligent Office

Personal information you have provided in relation to the annuities being used or applied for

To provide back office systems which help us provide the products and services we are contracted for

The Exchange from IRESS

Personal information you have provided in relation to the annuities being used or applied for

To obtain quotations on annuities


Browsing history, publicly available information such as job title etc. and any preferences saved via cookies

To collect information about you when providing the services to you, and to manage how we provide information on services and products and financial news updates that may be of interest to you

Microsoft Teams and Skype for Business

Video and voice call recordings

For recording video and voice calls to monitor our call quality for training purposes, as well as for regulatory Compliance. You will be notified if your call is being recorded


Undertaking anti-money laundering identification checks.

To comply with our legal obligations and help us make personal recommendations to you

We enter into agreements with these third parties, part of which is to ensure that they respect the security of your data and use it only in accordance with data protection laws.

We will also disclose your personal data to third parties if we are under a duty to disclose or share your personal data in order to comply with any legal obligation.

If you would like confirmation of the third parties we have shared your data with, and how those companies process your data, please let us know.

Collection of personal data about other people (e.g. your spouse/partner/dependant)

To allow us to provide our services to you, we will collect personal data about you, and may collect personal data about other people you wish us to consider as potential recipients of your annuity, such as a spouse, partner, dependant or beneficiary. Some of this data may be special categories of personal data, for example, information about relevant health conditions.

You must ensure that, where you provide personal data relating to another individual to us, that individual has explicitly consented to you doing so and read and understood this Privacy Policy.

International transfer of your personal data

As some of our service providers may be located in countries outside of the UK or the EEA, it may be necessary for the personal data that we collect from you to be transferred to or accessed from outside the UK or the EEA in order for you to use our services.

If we do this, we have procedures in place to ensure your data receives the necessary protections.

Where we transfer your personal information to countries deemed to provide an adequate level to data protection by the UK Information Commissioner’s Office, we rely on that decision to transfer your personal information.

For transfers to service providers outside the UK or the EEA where no adequacy decision applies, we use standard contractual clauses or other transfer tools provided for in the applicable data protection legislation to protect your personal information. Any transfer of your personal data will comply with applicable laws and we will treat the information according to the principles set out in this Privacy Policy.

You can obtain further information regarding the mechanisms used to safeguard your data by contacting our Data Protection Officer at the contact details listed above.

Storage of your personal data

We will only keep your personal data for as long as we need to in order to fulfil the relevant purpose(s) it was collected for, as set out above in this Privacy Policy, and thereafter for as long as we need to keep it for legal purposes. Generally we will delete your records six years after our relationship with you comes to an end. However, we are obliged to retain some data for longer, for regulatory purposes. For more information about how long we will keep your personal data, please contact us at the details shown above.

We take the security and confidentiality of your personal data very seriously. We will use strict procedures and security features to aim at preventing unauthorised access, disclosure, alteration or deletion of your data. This includes restrictions on who can access data, using encryption to protect data when it is being transferred or stored, and maintaining corporate firewalls to safeguard against unauthorised access. For full details of the security measures we have in place, please contact us using the details shown above.

Your rights

You have certain rights with respect to your information which are summarised below. Some of the rights are complex therefore, not all details are included in the summary:

  • Right of access: you can ask for copies of all the information that we process about you;
  • Right to rectification: you can ask to have inaccurate information held about you corrected;
  • Right to erasure: you can ask for the information held about you to be erased (subject to certain criteria);
  • Right to restriction of processing: you can ask us to restrict the processing of your information (under certain circumstances);
  • Right to data portability: you can, under certain circumstances, request that we transmit your personal information to another provider of services.

You also have the right to object to the processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights above). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive, for example if you keep requesting copies of the same data. Alternatively, we may refuse to comply with the request in such circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal data is not disclosed to any person who has no right to receive it.

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues. They can be contacted at:

The Information Commissioner's Office
Wycliffe House
Water Lane

Telephone: 0303 123 1113 or 01625 545745
Fax: 01625 524510

Changes to our Privacy Policy

Any changes we make to our Privacy Policy in the future will be posted on this page and, where appropriate, notified to you. Alternatively, please check back frequently to see any updates or changes to our Privacy Policy.