The Trustee 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 Trustee hold and process personal data about members of the Group and beneficiaries in order to run the Group. In doing so, we comply with relevant data protection legislation.
What we do with your data
As a data controller, the Trustee collect and process your personal data for the purposes of complying with our legal duties to administer the Group and for other legitimate purposes relating to the operation of the Group. This means that the Trustee will generally rely upon the “legal obligations” and “legitimate interests” grounds provided in the applicable law as the legal bases for processing your personal data. Occasionally, the Trustee might also seek your consent for processing some of your personal data, for example, your sensitive data.
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 Group, other schemes from which members have transferred, HMRC, the Department for Work and Pensions (DWP), 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 Group. The personal data we hold about you is used to calculate and pay the benefits you (or your beneficiaries) 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 Group (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 Group’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 such consent at any time.
Who else processes your data?
We share your personal data with certain third parties involved in running the Group, for example, Mercer (the Administrator), David Eteen of Aon Solutions UK Limited (the Scheme Actuary), Fieldfisher LLP (legal advisors) who will process personal data to comply with their professional duties as advisers to the Trustee and EDF, who holds personal data to comply with its legal obligations as the sponsoring employer of the Group. EDF has a legitimate interest in the Group being run in a cost-effective way and may have an interest in offering certain options to members. The Trustee will share information with EDF and its auditors and advisers for this purpose. We may also share your personal data with providers and trustees of other pension schemes to prepare for, and give effect to, any transfer of members and to facilitate the provision of benefits for transferring members under any such other pension scheme. We will rely upon “legitimate interests” as the legal basis for sharing such personal data with the other pension scheme providers.
We may disclose your personal data to other third parties (such as HMRC, DWP or the Pensions Ombudsman), for example, if we are under a duty to disclose or share your personal data with them in order to comply with a legal obligation.
EDF, the Administrator and other advisers will from time to time transfer data to countries outside the UK. These transfers are and will only be made to countries which the UK Government has deemed to offer adequate data protection or when certain contractual protections that are approved in accordance with the applicable data protection law 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.
Storage of your personal data
Pension benefits are paid over a long period and your right to benefits under the Group 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 Group 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 Group 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 the data to another organisation, or to you. 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 that we require to administer your benefits, we may not be able to pay out the benefits you are entitled to.
To exercise your rights in relation to the personal data we hold about you, please contact us using the details below.
If you have any queries in relation to your pension scheme membership, please contact the pension scheme administrators, Mercer, on:
Telephone: 0344 209 6594
Online: Contact Mercer
If you have any questions about the way we deal with information about you or to exercise any of your rights under the data protection legislation, please contact the Fund Secretary:
Laura Le May – Fund Secretary
90 Whitfield Street,
London W1T 4EZ
Telephone: 07809 593 900
The Scheme Actuary, David Eteen, and the company that he works for, Aon, are joint data controllers in respect of 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
Website: Information Commissioner's Office - Concerns