Trustee Privacy Notice

Who we are

We are BP Pension Trustees Limited (the ‘Trustee’). We are the trustee of the BP Pension Fund (the ‘Fund’).

As the Trustee of the Fund, we hold certain personal information (known as ‘personal data’) about you, as a Fund member, and, where applicable, your dependants and beneficiaries. Most of the information held about you and processed by us in running the Fund is personal data. Given that we hold information from which you as an individual can be identified, any information held about you is subject to certain protections.

For legal purposes, we are the ‘data controller’. This means we decide the purposes for and the means by which the personal data we hold about you is processed.

We have an internal legal agreement with BP Pensions Limited (the ‘Administrator’). For legal purposes, the Administrator is our main ‘data processor’. This agreement with the Administrator sets out our respective responsibilities and obligations for compliance with data protection legislation.

What information we collect about you

Depending on the circumstances and the stage of your membership, we may hold some or all of the following information about you:

  • Your name
  • Your date of birth
  • Your gender
  • Your marital status
  • Your address and other contact details (such as telephone number and email address)
  • Your national insurance number
  • Details of your bank account (to pay benefits)
  • Relevant employment information (including current and past salary information and employment dates)
  • Details of your pension benefits
  • Medical and other details about your health
  • Details of your dependants and beneficiaries (including their names and possibly details of their gender and relationship with you, e.g. child/spouse).
In order to properly administer the Fund and to calculate and pay benefits, we may also need to hold other information about you from time to time.

 

How we use that information

As Trustee, we have a legitimate interest in holding and processing the above information about you. The information is needed for us to properly administer the Fund and to calculate and pay benefits to you or your beneficiaries. We also keep the above information to allow us to comply with our obligations towards members under the Fund’s governing documents, as well as under relevant legislation. Your personal data is generally collected directly from you or from your employer.

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.

As part of running the Fund, we may also need to hold and process particularly sensitive information about you and your dependants and beneficiaries (known as ‘sensitive personal data’). Under the legislation, 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.

Who we share it with

We are not allowed to disclose personal data about you to other parties except where:

  • It is required for contractual or legal reasons or other specifically identified purposes
  • You have given your consent
However, because we need help from various advisers and service providers to properly administer the Fund, we share personal data with the following.

  • Your current, past or future employer which may include group companies which are based outside the European Economic Area (EEA). Where data is sent outside the EEA, appropriate safeguards are put in place to ensure that your data is kept secure
  • The Fund’s professional advisers, including the scheme actuary, auditor, medical advisers, and lawyers
  • The Administrator who is responsible for the day-to-day administration of the Fund on our behalf
  • HM Revenue & Customs and other statutory bodies (such as The Pensions Ombudsman and The Pensions Regulator) – we can be fined and subject to other action if we fail to provide certain information to these authorities
  • The advisers and printers who help us prepare the various communications we send to you
  • Our appointed insurance company or companies for the purposes of life insurance, member contributions and additional voluntary contributions
  • Depending upon how we pay pensions, organisations such as National Westminster Bank plc, to whom the Administrator sends Fund Personal Data in order to effect an electronic payment in the UK, and/or a payment via Citibank NA when pensions are being paid overseas
  • The mortality tracing service used by the Administrator
  • Other third parties where disclosure of information is required by law, such as a law court, spouse (in relation to divorce proceedings), solicitor acting on behalf of a spouse, police authority, Department for Work and Pensions fraud investigator, trustee in bankruptcy (or Scottish equivalent), or insolvency practitioner
  • Other third parties whose services we may require from time to time.

 

How long we keep personal data for

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.

Your rights

  • Right of access – you have the right to see personal data that is held about you and a right to have a copy provided to you, or someone else on your behalf, in a digital format.
  • Right to rectification – if, at any point, you believe that the personal data we hold about you is either inaccurate or wrong, you can ask to have it corrected.
  • Right to restrict processing – you can require us to limit the processing of your personal data in certain circumstances, for example, while a complaint about its accuracy is being resolved.
  • Right to object to processing – as we are relying on legitimate interests as a reason for processing, you can object to your personal data being processed, although we can override this objection in certain circumstances.
  • Right to withdraw consent – where you have given us your consent to processing your personal data, you can withdraw that consent at any time by notifying us (see ‘Who to contact’ below). However, withdrawing your consent will not affect the processing of any personal data which took place before withdrawal and it may be possible for us to continue processing your personal data where this is justified.
  • Right to be forgotten – you can request that your personal data is deleted altogether, although we can override this request in certain circumstances.

You should be aware that taking any of the above steps could affect the payment of your benefits, your participation in the Fund, and our ability to answer questions about your benefits.

Information will generally be provided to you free of charge. However, we may charge a reasonable fee in certain circumstances.

Who to contact about your personal data

If you wish to:

  • exercise any of the rights mentioned above
  • request a hard copy of the notice
  • make a complaint about how we have handled your data

please write to: BP UK Pensions and Benefits, Chertsey Road, Sunbury-on-Thames TW16 7LN or contact us.

Making a complaint to the Information Commissioner’s Office

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 on 0303 123 1113 or via a contact form at www.ico.org.uk.

Updates to this notice

This notice is the latest version as at May 2018. It may be updated from time to time and you can see the latest version at any time at www.pensionline.bp.com. Alternatively, please let us know if you would prefer to receive a hard copy (see ‘Who to contact about your personal data’ above).