We are BP Pension Trustees Limited (referred to as the ‘Trustee’, ‘we’, ‘us’ or ‘our’ in this notice). We are the trustee of the BP Pension Fund (the ‘Fund’). As the Trustee of the Fund, we hold certain personal data about (i) you, as a Fund member or beneficiary, and (ii) where applicable, your dependants and beneficiaries. Personal data, is information from which you, as an individual, can be identified. Most of the information held about you and processed by or for us in running the Fund is personal data.
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 may collect and process some of or all the following categories of personal data about you:
and civil partnership status)
PAYE details and contracting out record)
relevant for the purposes of administering the Fund
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.
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 share or may share your personal data with the following categories of recipients in connection with the processing purposes set out under “How we use that information” above:
We do not normally send any personal data to a third party outside of the UK. If we do, we will ensure appropriate safeguards are in place in accordance with UK data protection law.
We must keep all personal data safe and only hold it for as long as necessary. To meet the requirements of both UK tax and pensions law, we must keep certain personal data (for example, details about the date a member joins the Fund, their name and address, and details of benefits paid) for a minimum of 6 years. However, given the long-term nature of pensions, we may keep your personal information for longer than this.
Depending on why the Trustee is processing your personal data, you will have certain rights in relation to that data. The type of rights you may have include:
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.
If you wish to:
please write to: BP Pension Fund, Chertsey Road, Sunbury-on-Thames TW16 7LN or contact us.
If you are not satisfied with our response to any query you raise with us, or you believe we are processing your personal data in a way that is inconsistent with the law, you can complain to the Information Commissioner’s Office at Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF.
You can also contact the Information Commissioner’s Office on 0303 123 1113 or via a contact form at www.ico.org.uk.
This notice was produced on 31 March 2022. It may be updated from time to time and you can see the latest version at any time at pensionline.bp.com. Alternatively, please let us know if you would prefer to receive a hard copy (see ‘Who to contact…’ above).