The Trustees respect your privacy and value the trust you place in us when you share your personal information with us. This notice sets out how we, as data controller, collect and use your personal information, why we use it, with whom we share it and the rights to which you may be entitled.
This notice will be changed from time to time, but if we change anything important about this notice (the information we collect, how we use it or why) we will highlight those changes to you.
The Trustees hold and process personal data about Scheme members and beneficiaries in order to run the Scheme. In doing so, we comply with relevant data protection legislation.
What we do with your data
As a data controller, the Trustees collect and process your personal data for the purposes of complying with our legal duties to administer the Scheme and for other legitimate purposes relating to the operation of the Scheme.
Whilst much of the data we hold has been provided by members themselves, we also hold and process data provided by the employers which participate in the Scheme, other schemes from which members have transferred, HMRC, the Department for Work and Pensions (DWP) and regulatory bodies and by tracing organisations. We also receive information from members about their proposed beneficiaries, who may be eligible to receive benefits on the member's death. We assume that you have the consent of those individuals to provide us with this information and that you will share this privacy notice with them. We will not provide a copy of this notice to those individuals, as to do so is likely to seriously impair our ability to properly pay the benefits due under the scheme. The data we hold is to calculate and pay the benefits the members are entitled to and this includes your name, address, salary, years of service with the scheme, date of birth, NI number and contact details.
We also hold some special categories or “sensitive” data about individuals for the purposes of administering the Scheme (for example in relation to ill-health or death benefits). We will in most circumstances process this data in the performance of our legal obligations in connection with employment, social security and social protection (as allowed by legislation). We may also, typically when considering claims under the Scheme’s Internal Dispute Resolution Procedure, process any sensitive data for the purposes of establishing, exercising or defending legal claims. If there are any occasions where we seek your explicit consent to process sensitive data then you can withdraw it at any time.
Who else processes your data?
We share your personal data with certain third parties involved in running the Scheme, for example, Mercer (the Scheme Administrator), David Eteen of Aon Hewitt Limited (the Scheme Actuary), Mayer Brown International LLP (legal advisors who will process personal data to comply with their professional duties as advisers to the Trustees) and EDF Energy, who hold personal data to comply with its legal obligations as the sponsoring employer of the Scheme. It has a legitimate interest in the Scheme being run in a cost-effective way and may have an interest in offering certain options to members. The Trustees will share information with the employer and its auditors and advisers for this purpose.
The employer, the Scheme administrator and other advisers will from time to time transfer data to other countries, including outside the European Economic Area. These transfers are and will only be made when certain protections that are approved by the European Commission are applied. These protections aim to ensure the security of your personal information, safeguard your privacy rights and give you remedies in the unlikely event of a security breach. Details are available on request from the Fund Secretary.
Storage of your personal data
Pension benefits are paid over a long period and your right to benefits under the Scheme is based on information which may go back many years. Our policy is therefore to retain information relating to you for 6 years after your membership of the Scheme ends and beyond that, for 6 years after the death of any surviving dependants to whom we have paid a benefit.
However, information will be held for longer where we consider it appropriate in order to ensure the Scheme pays the correct benefits and to deal with any queries relating to your benefits which may arise after that time.
Mercer will hold on to certain personal data for 15 years after the termination of their contract with us. This is to provide assistance with any disputes or queries and to meet legal and regulatory obligations.
You have the right to access your personal data and require that we rectify any errors in the data that we hold, or request that we erase your personal data. In some circumstances, you can also require that we restrict the way we process your personal data, object to its processing or request a copy of your personal data for the purposes of transmitting elsewhere. Where we have requested and obtained your consent to process particular information, you may withdraw that consent at any time. However if we do not hold all the data we need to administer your benefits, we may not be able to pay out the benefits you are entitled to.
If you have any questions about the way we deal with information about you, please contact the Fund Secretary:
Laura Le May – Fund Secretary
EDF Energy, Interchange
81-85 Station Road
Croydon CR0 2AJ
Telephone: 07809 593 900
The Scheme Actuary, David Eteen, and the company that he works for, Aon Hewitt Limited, are joint data controllers in respect to your personal data that is used to carry out actuarial functions. For further information please click here.
What if you have a complaint?
To make a complaint about how we’ve handled your information, contact us as set out above.
If you’re not satisfied with our response to your complaint or believe our processing of your information does not comply with data protection law, you can make a complaint to the Information Commissioner's Office. Its contact details are:
Address: Wycliffe House, Water Lane,
Wilmslow, Cheshire SK9 5AF
Telephone number: 0303 123 1113