Who gathers and processes personal information (and who is in charge of processing it)?

For the purposes of the complementary pension scheme for professional salaried air crew members, your personal data is collected and processed by CRPNPAC, 14 rue des Pyramides, CS 60322, 75041 Paris Cedex 01, France (hereinafter referred to as CRPNPAC).

“Personal information” refers to any information pertaining to a natural person who is either identified or identifiable, whether directly or indirectly, through reference to an identification number or to one or more pieces of information that are unique to them.

CRPNPAC agrees to gather and process your personal information from the website crpn.fr in a manner compliant with France’s general data protection rules (RGPD) of April 27, 2016, and with France’s amended Law on Data Processing, Files and Individual Liberties of January 6, 1978.

Any personal information gathered by CRPNPAC is gathered in a fair and transparent manner based in part on displaying full user notifications.

 

How personal data is gathered 

The personal data of members, pensioners and any beneficiaries may be collected:

From third parties:

• Employers of members and pensioners;
• Partner social and tax bodies in the context of exchanges authorised by the legislation and regulations in force: Assurance retraite, France Travail, DGFIP …

Or directly from you, notably via:

• our forms;
• our website crpn.fr;
• your direct contacts with us and your letters.

Mandatory answers are indicated on the forms.

 

Why we need to process your personal information

CRPNPAC agrees to only gather personal information for clear, precise, and legitimate purposes, and to process it in accordance with stated purposes.

Each form or eservice collects the least amount of personal information possible (using the concept of data minimization).

CRPNPAC agrees to only process that personal information which is appropriate and relevant and which does not go beyond the purposes for which it was gathered.

Any personal information is only gathered and/or processed based on the legal grounds set forth by applicable regulatory policy, and for the following purposes:

• To ensure that we are in compliance with our legal and regulatory obligations under currently applicable law:
  • Administering supplementary retirement pension entitlements on behalf of companies, members, and pensioners (calculating supplementary retirement pension entitlements, administering pensions, collecting contributions, etc.);
  • Administering social protection entitlements on behalf of members and pensioners;
  • Liaising with companies and with members and pensioners;
  • Tax and social security withholdings;
  • Administering social welfare benefits on behalf of members and pensioners (calculation, administration, payment);
  • Administering the scheme by CRPNPAC;
  • anonymised statistical surveys on retirement.
• As part of the fulfillment of a contract:
  • Registration for a Personal CRPN account on our website crpn.fr (Terms of Use)

 

What personal data is processed?

The different categories of personal data collected are as follows:

Civil status, identity, identifying information	Surname(s), forename(s), date of bith and/or death, place or birth, NIR (Social Secutity number)…
Personal situation	Postal end email addresses, family/marital situation, parentage…
Professional situation	Employment contract type, carrers, employer company…
Economic and financial information	Salaries, tax status…
Login data	ID to the CRPNPAC personal account…
Banking information	Bank account details

 

Who receives and can be contracted out your personal information

Only people identified and authorized pursuant to the applicable Regulation may have access to your personal data.

CRPNPAC may work with technical subcontractors in order to process all or part of your personal information, only to the extent necessary to provide their services.

CRPNPAC does not transfer any of the personal information it gathers outside of the European Union and stores it exclusively in France.

CRPNPAC may be required to share your personal information without your prior agreement in order to comply with the law.

On this basis, you agree to allow CRPNPAC to share your personal information if it determines that this is necessary in order to comply with a subpoena, a warrant, or a court decision or order, or with an authority that has standing to conduct a specific investigation or in order to pursue a legitimate interest, including to defend its own rights.

 

Security and confidentiality

The security of your data is our primary concern and we are constantly improving this at all levels through technical and/or organisational measures in order to ensure the very best level of protection of your data.

The personal information that is gathered through the use of online services on crpn.fr is processed in accordance secure protocols and is used by CRPNPAC to handle the requests it receives through its computerized applications.

CRPNPAC shall take all necessary measures to ensure that all users’ personal information remains confidential and secure, and to prevent said information from being damaged, deleted, or accessed by unauthorized third parties.

Access to personal information is strictly limited to authorized personnel who have been assigned certain responsibilities and are bound by a confidentiality agreement.

 

How long your personal information will be stored

CRPNPAC processes and stores personal information in a secure environment for the amount of time needed to achieve the purposes for which it was gathered.

Personal information is not stored beyond the length of time CRPN needs in order to fulfill its statutory mandate.

CRPNPAC keeps a trace of exchanges with the users of its website in a file tracking the history of these exchanges. The trace of an exchange of information is kept for 3 years (1 year in an active database and 2 years in an archive database (for evidence purposes)).

 

Right to information, access, correct, delete, restrict processing, and register special directives with regard to the storage, deletion, or sharing of your information after your death.

Pursuant to currently applicable law in France (French Law on Data Processing, Files and Individual Liberties No. 78-17 of January 6, 1978) and in Europe (EU regulation No. 2016/679 of April 27, 2016) you have the right to information, access, correct, and delete your personal information as well as the right to restrict how your information is processed. In addition, you have the option to register a directive regarding the storage, deletion, and sharing of your information after your death. These directives can be amended or revoked at any time.

To exercise your rights, you can send your request in writing to the following address (attaching any document that can serve as proof of your identity):
CRPNPAC
Data Protection Officer
14 rue des Pyramides
CS 60322
75041 Paris Cedex 01

Or by filling out the form below:

 

After having contacted the CRPNPAC DPO, and if you feel that any processing infringes your rights, you can lodge a complaint with the CNIL, French data protection regulatory authority, on the website www.cnil.fr or by post.

Compliance with france’s law on data processing, files and individual liberties

You are required to abide by the provisions of France’s amended law of January 6, 1978, on data processing, files, and individual liberties, and with France’s general data protection rules (RGPD) of April 27, 2016, violating which is liable to criminal prosecution.

This means that each user must refrain from collecting, processing, or inappropriately using the personal information they access and, in a general sense, from engaging in any action liable to infringe on another individual’s privacy or reputation.

 

Changes to the personal information processing rules

This policy is subject to change without notice in order to take account of the changes to the processing of the personal data of the CRPNPAC complementary pension.

If any changes are made to the rules set forth above, the latter will be published online on crpn.fr and become effective from the date of publication. Please refer to these rules every time you stop by the site in order to review the most recent version available on the site.

 

Contacts

If you have any questions about CRPNPAC’s use of your personal information, please contact our Data Protection Representative (“Délégué à la Protection des Données”/ DPO) at the address below:
CRPNPAC
Délégué à la protection des données
14 rue des Pyramides
CS 60322
75041 Paris Cedex 01

or by clicking on the following link: protection.donnees@crpn.fr

 

Cookies

Our website stores audience-measuring cookies (number of visits, pages viewed) in accordance with the terms of exemption from user consent set forth by the French Data Protection Authority (CNIL)’s “Cookies” recommendation, using Matomo (formerly known as Piwik), a free, open-source solution which has been set up for this specific purpose. This means, in particular, that these cookies are used only to produce anonymous statistics and cannot be used to track a user over to other websites.

This website also deposits browsing cookies for technical purposes only; they are not saved to your machine.

Platform performance is not affected if a user’s browser has cookies disabled.

 

Specific information

Inter-scheme sample of contributors (EIC) 2021

Information about the establishment of an inter-scheme sample of contributors and the right of access laid down by the GDPR and the French Data Protection Act

In order to examine pension entitlements, the Directorate for Research, Studies, Evaluation and Statistics (DREES) of the Ministry of Solidarity and Families has created a tool called inter-scheme sample of contributors (EIC) which makes it possible to reconstitute the retirement pension entitlements of individuals in the mandatory schemes. Its creation is laid down by Law no. 2000-1257 of 23 December 2000 on the financing of Social Security for 2001 (Article 27), amended by Article 62 of Law no. 2002-1487 of 20 December 2002 on the financing of Social Security for 2003.

The EIC 2021 is constituted of information concerning people born:

• On 2^nd and 3^rd January, 1^st and 2^nd April, 1^st and 2^nd July, and 1^st to 10^th October of the years 1946, 1950, 1954, 1958, 1962, 1966, 1970, 1974, 1978, 1982, 1986, 1990, 1994 and 1998.
• On 2^nd and 3^rd January, 1^st and 2^nd April, 1^st and 2^nd July, and 1^st and 2^nd October of the years 1956, 1960, 1964, 1968, 1972, 1976, 1980, 1984, 1988, 1992 and 1996.

It also includes people whose month of birth is unknown in the National Directory for Identification of Natural Persons.

This information relates to the pension entitlements acquired individually.

This information is described in Article R. 161-67 of the French Social Security Code. It is the following: personal and anonymous register number specific to the processing, sex, year of birth, place of birth (country, département or territory), pension schemes, information necessary to calculate the retirement pension, information making it possible to establish the ratio between the amount of the entitlements or the retirement pension on the one hand, and the income and replacement income received on the other, socio-professional or statutory category, family status information in connection with the purpose of the processing (marital status, legal partnership agreement, cohabiting arrangement, number of children), département or territory of residence.

These data are collected by the DREES from the managing bodies of the mandatory pension schemes, from the INSEE, and from France Travail. The data transferred, extracted from their management, are anonymous and exclusively used to draw up statistics.

Pursuant to Articles 15, 16 and 18 of Regulation EU 2016/679 of 27 April 2016 (General Data Protection Regulation or GDPR) and the French Data Protection Act no. 78-17 of 6 January 1978 amended, the persons born in one of the periods mentioned above can obtain disclosure of their personal data from the DREES, via the CRPNPAC, which will provide them with the information necessary to exercise their rights of access, rectification and restriction of processing.

In that context, you can write to the following address (attaching any proof of identity and your request):

CRPNPAC
Délégué à la protection des données
14 rue des Pyramides
CS 60322
75041 Paris Cedex 01

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