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Zur UmfrageData protection notice relating to the online account of the Vodafone GmbH company pension plan
We provide information about your company pension!
We, Lurse Pension & Benefits Consulting GmbH, as a service provider, process your personal data on behalf of Vodafone GmbH within the framework of the online account for company pension schemes, which we make available to Vodafone GmbH and its subsidiaries. With these applications, we inform you about the individual status of your company pension scheme at Vodafone GmbH and give you further information on the subject of company pension schemes. Furthermore, we inform you about the rights to which you are entitled under the applicable data protection law.
Personal data is any information relating to an identified or identifiable natural person, such as personal data, address data and billing data that is an expression of an individual's identity.
The personal data entered by you in our online account will be processed by us or the respective legal entities of Vodafone GmbH for the purposes of determining and managing your company pension claims.
Entitlements to company pension schemes are established in connection with your employment relationship with a Vodafone GmbH company and are processed by Lurse employees, the responsible specialist departments or HR departments.
We respect your privacy
The protection of your privacy in the processing of personal data as well as the security of all business data is an important concern for us, which we take into account in our business processes. We process personal data collected during your visit to our online offers confidentially and only in accordance with the legal provisions.
Data protection and information security are part of our corporate policy.
Contact information of the controller for data processing and the data protection officer
The controller for the processing of your data is the respective legal entity of Vodafone where you are employed. Lurse acts as a processor within the meaning of Article 28 of the EU General Data Protection Regulation (GDPR) for Vodafone GmbH.
You can find the contact details of the data protection officer in the General Data Protection Notice for Employees on the intranet.
To assert your rights and report data protection incidents, please contact the data protection officer.
Your company pension
In connection with your employment relationship with a company of Vodafone GmbH, you may have receive a commitment to a company pension scheme. Your entitlement to a company pension is explained in more detail in this application, the online account.
Processed data categories
The categories of personal data processed include in particular:
- Master data (e.g. name; date of birth; residence)
- Duration of employment with the company or group; status (active/non-active); position; leaving date
- Detailed information about pay and pension claims
- Insurance data
- Bank data (in case benefits are paid out)
- Possibly comparable data of dependants entitled to benefits (in case survivor’s benefits are paid out)
- Log data created when IT systems are used.
These may also include special categories of personal data such as data concerning health.
Sources of the personal data
Your personal data are for the most part transmitted from the respective Vodafone GmbH accounting system on the basis of which your pay is determined and paid out. Further data will be provided directly by you in connection with your company pension claims in the context of the online account or determined by us in connection with the administration of your company pension claims.
Processing purposes and legal bases
Willis Towers Watson GmbH and the Vodafone GmbH companies process your personal data in compliance with the provisions of the EU General Data Protection Regulation (GDPR), national data protection laws and further relevant national laws. Data processing serves to determine and administer your company pension claims resulting from your employment with a legal entity of Vodafone GmbH.
The primary legal basis for this is Article 6 paragraph 1 sentence 1 lit. b GDPR (performance of a contract). Further legal bases are:
- Article 6 paragraph 1 sentence 1 lit. a GDPR ("consent"): in the context of the establishment of your employment relationship;
- Article 6 paragraph 1 sentence 1 lit. f GDPR ("weighing up of interests"): legitimate interest of the controller.
Special categories of data
Insofar as special categories of personal data in the sense of Article 9 paragraph 1 GDPR (e.g. data concerning health) are processed, this will occur on the basis of Article 9 paragraph 2 lit. b. GDPR.
Disclosure of data
Within Lurse Pension & Benefits Consulting GmbH and within the respective legal entity of Vodafone GmbH where you are employed, only those persons and entities that are commissioned to process your company pension claims will have access to your personal data.
As a matter of principle, we will only transmit your personal data to other controllers if and to the extent that this is necessary to process your company pension claims, we or the third party have a legitimate interest in passing it on or you have given your consent to do so. Details of the legal bases can be found in the section "Processing purposes and legal bases". Third parties may also be other legal entities of Vodafone GmbH. If data is transmitted to third parties on the basis of a legitimate interest, this is explained in this data protection notice. In addition, we may transmit your personal data to other recipients outside of Lurse Pension & Benefits Consulting GmbH and Vodafone GmbH, insofar as this is necessary to fulfil contractual and legal obligations.
Contractors and service providers (processors)
If we use service providers, we have carefully selected them and monitor them regularly, in particular their careful handling of personal data and the security of the data stored by them. We oblige all service providers to maintain confidentiality and comply with legal requirements. Service providers can also be other legal entities of Lurse Pension & Benefits Consulting GmbH or Vodafone GmbH.
Disclosure to recipients outside the European Economic Area
If we transfer personal data to contractors, service providers or group companies outside the European Economic Area (EEA), the transfer will only take place if the third country has been confirmed by the EU Commission to have an adequate level of data protection or other appropriate data protection guarantees (e.g. binding internal company data protection regulations or EU standard contractual clauses) are in place.
You can get an overview of the recipients in third countries and a copy of the specifically agreed regulations to ensure the appropriate level of data protection. Please use the contact information above.
Duration of storage; retention periods
We will delete your personal data as soon as it is no longer necessary for the purposes mentioned above or there is no longer a legitimate interest in storing the data. After the termination of the employment relationship, your personal data will be stored as long as we are obliged to do so due to continuing company pension claims or in accordance with national legislation. In addition, it may happen that personal data is stored for the time in which claims can be asserted against us or against Vodafone GmbH.
Security of data processing
We will take all necessary technical and organisational measures to ensure an appropriate level of security and to protect your processed data, especially against the risks of accidental or unlawful destruction, manipulation, loss, alteration or unauthorised disclosure or access. Our security measures are continuously improved in line with technological developments.
Rights of the users
To assert your rights, please use the information shown in the contact information section. In so doing, please make sure that we can uniquely identify you.
Right to information and right of access
You have the right to obtain information about the processing of your data from Vodafone GmbH. For this purpose you can assert a right of access with regard to your personal information which we process.
Right to rectification and erasure
You can request the rectification of any inaccurate data and – if the statutory requirements are fulfilled – the completion or erasure of your data from Vodafone GmbH.
This does not apply to data that are required for accounting and bookkeeping purposes or the determination and administration of your company pension claims or that are subject to statutory retention obligations. Insofar as access to such data is not required, their processing will be restricted, however (see below).
Restriction of processing
If the statutory requirements are fulfilled, you can request Vodafone GmbH to have us restrict the processing of your data.
Objection to data processing
In addition, you have the right to object at any time to data processing by Vodafone GmbH. We will then stop processing your data, unless we can demonstrate – in accordance with statutory requirements – compelling legitimate reasons for continued processing that override your rights, especially your rights to object.
Objection to data processing on the legal basis of a "legitimate interest"
In addition, you have the right to object at any time to data processing by Vodafone GmbH insofar as it occurs on the legal basis of a legitimate interest. We will then stop processing your data, unless we can demonstrate – in accordance with statutory requirements – compelling legitimate reasons for continued processing that override your rights, especially your rights to object.
Withdrawal of consentg
If you have consented to the processing of your data, you can withdraw this consent at any time with effect for the future. This will not affect the lawfulness of the processing of your data until the time of withdrawal.
Data portability
You furthermore have the right to receive transmission of the data you have provided to us in a structured, commonly used and machine-readable format and/or to request – insofar as this is technically feasible – that the data be transmitted to another controller.
Right to lodge complaints with the supervisory authority
You have the right to lodge a complaint with a data protection authority. To do so, you can contact the data protection authority that is competent for your place of residence or your federal state, or the data protection authority that is competent for us.
You can find the contact details of the data protection authority responsible for us in the General Data Protection Notice for Employees on the intranet.