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Who are we?
This is a data protection notice provided on behalf of the Trustee. We collect, hold and use personal information to help us run the Plan.
Contents of this notice
The Trustee is the data controller in respect of the personal information that we hold in relation to the Plan. Because we use your personal information, we have to provide you with certain information in order to comply with new data protection legislation set out in the General Data Protection Regulation (GDPR).
This notice contains information on:
We have set out additional information on how and why we process your personal information, your rights under the GDPR, and third parties with whom we share your personal information.
Where can I get more information?
We also provide printed versions (including large print versions) on request.
This notice explains how the Trustee processes your personal information. Please read this notice (and any other privacy information that we send to you) so that you are aware of how and why we are using your personal information.
We may change this notice from time to time. Please visit this webpage or contact us in order to receive the most up to date version of this notice.
What information do we collect and process?
We collect and process your personal information because you are or were a member, or are or were connected to a member of the Plan. We also collect personal information if you contact us in connection with your membership of the Plan.
We collect and process the following categories of personal information about you:
What sensitive personal information do we collect and process?
We usually only ask for sensitive personal information when it is required to help us make a decision in relation to your rights under the Plan. For example, we may request:
In addition, certain categories of sensitive personal information (e.g. race, ethnicity, religious beliefs and sexual orientation) may be revealed on formal documentation that we process in order to identify the recipients of benefits under the Plan (e.g. birth certificates, marriage certificates, driving licenses and passports). You may also decide to provide us with sensitive personal information voluntarily (e.g. when raising queries or making a complaint).
How do we collect your personal information?
When you joined the Plan, you and/or your employer provided personal details so that we could create your membership record.
This information is updated whilst you are a member of the Plan, even if you have since left service with any of the Plan's employers. Updated information may come from:
Why do we process your personal information?
We use this information to:
What are our legal grounds for processing your personal information?
In order to comply with our legal obligations
As the Trustee of the Plan, we are under legal obligations to process your personal information in order to comply with pensions and other relevant legislation, the Plan's rules, court rulings and Pensions Ombudsman decisions. For example:
It is necessary for us to process your personal information in order to comply with these legal obligations.
In order to fulfil our legitimate interests
Processing your personal information is also lawful if it is based on our 'legitimate interests'. The Trustees have a legitimate interest in running and managing the relevant Plan and managing the Plan's risks and liabilities. In addition, certain third parties may have legitimate interests which require the processing of your personal information by the Trustees (e.g. your employer may need information in order to comply with regulatory requirements).
In order to rely on this legal ground, we have:
What are our legal grounds for processing your sensitive personal information?
There are three legal grounds that allow us to process your sensitive personal information (sometimes referred to as special categories of personal data):
What would happen if we did not collect and process your personal information?
If we did not collect and process your personal information then:
How long do we keep your personal information for?
The Plan was set up to provide benefits over a very long time. The Trustee needs to maintain records in order to properly run the Plan, to determine who should receive what level of benefits and when they should receive them, and to respond to any disputes about an individual's rights under the Plan.
As a result, the Trustees will generally keep your personal information for a long period of time i.e until the wind up of the Plan or the death of the last beneficiary, in either case, plus 15 years (which is the longest period of time that someone can bring a claim against the Plan). Our service providers (and former service providers) may also have similar valid grounds to keep your personal information for such long periods.