Personal data is subject to certain protections under UK data protection law. Under that law, we are the ‘data controller’ in respect of the personal data that we, or our service providers, process. This means we decide the purposes for and how the personal data we hold about you and other Fund members and beneficiaries is processed.
We often receive this information because you share personal data with us. Other sources of this information may include your spouse, civil partner, partner or other relatives, your employer, former employer, our advisers, government agencies, any former pension scheme trustee or manager and our service providers including those providing tracing, existence checking, data cleansing and/or data enrichment services.
As we will likely receive data about your dependants and your partner, spouse or civil partner, you should ensure that any such adult individual is aware that we may hold some personal data in respect of them and share this privacy notice with them or direct them to it.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
How we use that information
As Trustee, we have a number of legal bases and purposes for processing your personal data including:
As part of running the Fund, we may also need to hold and process sensitive information about you and your dependants and beneficiaries (known as “sensitive” or “special category” personal data). Under law, details relating to health, racial or ethnic origin, religious or other similar beliefs, sexual orientation and political affiliations are regarded as sensitive personal data. Except where the legislation allows it, this information cannot be processed or passed to a third party without your express consent.
We may hold and process sensitive personal data for the purposes of:
In most circumstances we will process this data as necessary for the lawful reasons of: (i) establishment, exercise or defence of legal claims to benefits; and/or (ii) in the performance of our legal obligations in connection with employment, social security and social protection. If we cannot lawfully process your special category data for the above reasons or another lawful reason, we will obtain your consent before carrying out any such processing.
Personal data relating to the Fund may be held on paper, microfiche and computer systems. As the data controller, we must process this information fairly and lawfully.
We are committed to protecting your personal data. We take all reasonable precautions to safeguard the confidentiality of your personal data. These include procedures and security features to prevent unauthorised access of your personal data, both internally and with any data processor we engage.
We retain all call recordings made to and from our administration team for a minimum period of six years. In limited circumstances, and where warranted by one or more of the Trustee’s legitimate purposes, we may retain a call recording for longer than this.
If you wish to exercise any of these rights, please contact us using the details set out in the next section. You should be aware that exercising some of these rights could affect the payment of your benefits, your participation in the Fund and our ability to answer questions about your benefits.
You can also contact the Information Commissioner’s Office on 0303 123 1113 or via a contact form at www.ico.org.uk.