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.