When it comes to data protection, the Swiss Federal Pension Fund PUBLICA acts in accordance with the law and communicates openly with data subjects about how it handles personal data. This privacy policy has therefore been drawn up to explain how PUBLICA processes data. It does not provide an exhaustive description; specific circumstances are dealt with in other privacy policies. This policy may be updated at any time. We therefore recommend checking it regularly. The date at the end of the policy is the date on which it was last updated.
When PUBLICA processes data about you, you have the following rights:
Please note that these rights may be restricted or excluded in certain cases, such as where there are doubts about your identity or it is necessary to do so to protect other people, safeguard legitimate interests or comply with legal obligations.
If you are concerned about whether we are processing your personal data in accordance with the law, you can submit an objection to the relevant supervisory authority, the Federal Data Protection and Information Commissioner (FDPIC).
PUBLICA performs the tasks assigned to it under the PUBLICA Act and processes personal data primarily for the purpose of administering occupational pension provision. The legal basis for this processing is Art. 85a ff. of the Occupational Pensions Act (OPA) as well as the Federal Act on Data Protection (FADP) and the associated Ordinance (FODP).
We mostly obtain personal data in connection with the administration of occupational pensions on behalf of current employers. They are required by law to supply PUBLICA with all the data it needs to administer occupational pensions. In many cases, you also disclose personal data to us yourself, for example if you transmit data to us or communicate with us.
However, we can also obtain information about you from third parties, such as
The data that we process under this privacy policy do not relate solely to insured persons but may often also concern third parties. When you transmit third-party data to us, we assume that you are authorised to do so and that these data are correct. By transmitting third-party data, you confirm that this is the case.
As part of our business activities, and for the data processing purposes set out above, we also share personal data with third parties, in particular:
We may share your personal data with companies that provide services to us, and that process those data on our behalf as “processors”. Where processors themselves use the services of third parties, we may approve this in individual cases, meaning that your data may also be shared with those third parties. Our processors are obliged to process personal data only in accordance with our instructions, and to take appropriate measures to ensure data security. By selecting our service providers and concluding appropriate contractual arrangements, we ensure that data protection is guaranteed throughout the entire period during which your personal data are processed.
We process your data for as long as required to achieve our purposes for doing so, comply with the statutory retention periods, and serve our legitimate interest in processing for documentation and evidential purposes. Except where there is a legal or contractual obligation to do otherwise, we delete or anonymise your data as part of our normal procedures once the period for storing or processing them has ended, except where there is a statutory retention requirement that extends beyond our own purposes.
Whenever possible, we process personal data in Switzerland. Your data may also be processed in Europe or the US, and exceptional cases anywhere in the world.
If a data recipient is located in a country that does not have appropriate data protection legislation, we enter into a contractual agreement with the recipient requiring them to comply with the applicable data protection. Many countries outside Switzerland, the EU and the EEA do not currently have laws in place that provide an appropriate level of data protection from the perspective of the FADP. The contractual arrangements mentioned above can partially compensate for the absence or inadequacy of statutory protection. However, they cannot entirely eliminate all risks (specifically the risks of state intervention abroad). You should be aware of these risks, even though the risk in a given case may be low and we take further steps (e.g. pseudonymisation or anonymisation) to minimise it.
Please also note that data shared via the internet are often routed via third countries. This means that your data may be sent abroad even if the sender and recipient are in the same country.
We take appropriate technical and organisational measures to ensure the security of your personal data, protect them against unauthorised or unlawful processing, and counter the danger of loss, unintentional modification, undesired disclosure or unauthorised access.
The technical security measures include, for example, encryption and pseudonymisation of data, logs, access restrictions and data back-up.
Organisational security measures include, for example, directives and training for our employees, confidentiality agreements and checks. We also require our processors to implement appropriate technical and organisational security measures.
When you share data with us electronically, we recommend that you use our contact form or the myPublica active member portal, since in both cases the data are transmitted in encrypted form.
If you contact us via e-mail, you do so at your own risk and consent to us sending our reply to the e-mail address you used via the same channel. The data transmitted are stored and used solely to process the enquiry and for any further related questions.
PUBLICA uses tracking technologies including cookies and tags to obtain information such as that set out below (under “What information do we collect about you?”) and so gain a better understanding of how visitors use the website and its online services. These technologies help us to manage the website and make it more user-friendly. For example, they allow us to see whether your computer has already connected to us previously, and also which areas of the website are used most often.
If you save your cookie settings, these should also apply for future visits to the website. For technical reasons outside PUBLICA’s control, however, this cannot be guaranteed. For example, if you reset your browser, delete your cookies or access the website from a different browser or device, your cookie settings may not be available. In some countries, you may be requested to confirm your cookie settings when you access the website for the first time, in order to comply with the applicable laws and regulations. If you are in a country where you are automatically required to specify your cookie settings, you may be requested to do this again the next time you visit.
In many cases, you can also control tracking technologies via your browser. Please set your browser up so that either you are prompted to accept or reject tracking technologies such as cookies, or you accept them automatically. You can normally find these options and instructions for using them in your browser’s help menu or support function. However, rejecting, blocking or deactivating tracking technologies may restrict the availability of the services offered by the website. Additionally, parts of the website may no longer function correctly.
When you apply for a position with us, we process your personal data to administer the application procedure. Your personal data are normally provided to us either directly by you or by someone acting as a recruitment agent on your behalf. Without these data, we are unable to assess your application and decide on your suitability for the position concerned.
For example, we use your contact details to make appointments with you. We gather personal information such as that contained in your CV, and process data obtained from references and education certificates. In addition to these necessary data, you have the option to provide us with additional information for the application procedure. We use the data you supply to us in order to assess your application and make decisions.
The data you provide for the purposes of your application are shared only with those involved in the application procedure, such as human resources staff and managers of the specialist area concerned. Your data may also be shared with the authorities where we are under a legal obligation to do so. The data related to your application are treated as confidential at all times. If we wish to process those data for purposes other than the administration of the application procedure, we will inform you of this in advance and, where necessary, obtain a separate confirmation of consent from you.
In principle, the data of those who apply for a position with us are deleted no later than three months after the application procedure is completed. This does not apply where there is a legitimate reason for continuing to process them, such as where the law prohibits their deletion, continued storage of the data is required for evidential purposes, or you agree to them being stored for longer.
If your application is successful and you sign an employment contract with us, the data will continue to be stored and used for the customary organisational and administrative process and to administer your employment relationship. Further details of this are set out in the documentation accompanying the employment contract.
Data on your user behaviour (such as search terms, access details, surfing behaviour and the like) are collected in order to optimise search results and the user experience. These data are used to make our website more user-friendly and to continually improve your web experience. You can find more information about this in the “Cookies” section. The data you share with us when visiting our website will depend in particular on the browser you use and its settings. If your settings permit, we use cookies and similar tools to provide you with the best possible surfing experience on our website. This will include information such as the region in which you are located, the language you have selected, and the services you prefer.
There is a contact form on our website which you can use to contact us electronically. If you use it, the information entered in the form is transmitted to us and stored in our systems. When you send the form, additional data such as your IP address and time of sending are also transmitted.
The data in the contact form are encrypted for transmission. Use of the boxes in the form is voluntary and the data are only transmitted when it is used. The data transmitted are stored and used to process the enquiry and for any further related questions.
Whenever you visit PUBLICA’s website (https://www.publica.ch), PUBLICA automatically collects details of your visit. These include:
The data we collect do not allow PUBLICA to identify the person concerned, and are retained in aggregated form for two years.
PUBLICA can disclose your data to its own agents and third-party service providers within or outside the country you live in, in order to provide PUBLICA’s services and for the purposes set out above. Our agents and third-party providers that have access to personal data collected via the website are required to comply with data protection rules.
PUBLICA uses the Matomo software solution for web analytics of non-personal data. Matomo is operated by Ops One AG and Metanet AG in Switzerland. The data obtained are used exclusively for web analytics. They are not shared for other purposes.
We may also disclose your data to government authorities or bodies and supervisory authorities or other persons if this is prescribed or permitted by law. This is done in compliance with all applicable laws, regulations, court judgments or requests from the authorities or in accordance with all guidelines issued by supervisory and other authorities or similar procedures, or for their purpose.
PUBLICA performs the tasks assigned to it under the PUBLICA Act and processes personal data primarily for the purpose of administering occupational pension provision. The legal basis for this processing is Art. 85a ff of the Occupational Pensions Act (OPA) as well as the Federal Act on Data Protection (FADP) and the associated Ordinance (FODP). We also use the information to optimise the user experience and your user behaviour (e.g. search terms, instances of access, surfing behaviour and the like). These data are used to make our portal solutions more user-friendly and to continually improve your web experience. You can find more information about this in the “Cookies” section. The data you share with us when visiting our portal solutions will depend in particular on the browser you use and its settings. If your settings permit, we use cookies and similar tools to provide you with the best possible surfing experience on our website. This will include information such as the region in which you are located, the language you have selected, and the services you prefer.
There is a contact form on our portal solutions which you can use to contact us electronically. If you use it, the information entered in the form is transmitted to us and stored in our systems. When you send the form, additional data such as your IP address and time of sending are also transmitted.
The data in the contact form are encrypted for transmission. Use of the boxes in the form is voluntary and the data are only transmitted when it is used. The data transmitted are stored and used to process the enquiry and for any further related questions.
Whenever you visit PUBLICA’s portal solutions, PUBLICA automatically collects details of your visit. These include:
We also collect the following personal data provided to us by users:
The requirement to retain the data contained in the portal is dictated by the legal basis governing the data concerned, specifically:
When personal data are sent abroad, we ensure that the applicable laws and regulations are complied with, for example by concluding agreements that ensure the recipients of your data maintain an appropriate level of data protection.
When managing its real estate portfolio, PUBLICA processes personal data (e.g. name, address, income) to administer the rental process.
PUBLICA can disclose your data to its own agents and third-party service providers within or outside the country you live in, in order to provide PUBLICA’s services and for the purposes set out above. Our agents and third-party providers that have access to personal data collected in the context of property management are required to comply with data protection rules. We may also disclose your data to government authorities or bodies and supervisory authorities or other persons if this is prescribed or permitted by law. This is done in compliance with all applicable laws, regulations, court judgments or requests from the authorities or in accordance with all guidelines issued by supervisory and other authorities or similar procedures, or for their purpose.
Our data protection staff will be happy to help you. E-mail us at
Swiss Federal Pension Fund PUBLICA
Eigerstrasse 57
3007 Bern
datenschutz@publica.ch