The Trustee of the Scheme needs personal information about you to run the Scheme and pay benefits.  Similarly, other parties involved in running the Scheme will sometimes need to make decisions independently from the Trustee about how your personal information will be used.  In particular, this will involve the Scheme Actuary (currently Stuart Hailwood of Mercer).

In legal terms, the Trustee and the Scheme Actuary are both ‘Data Controllers’ and are separate and distinct from each other.

In this notice, you will see information about what the Trustee does with your personal information.

What personal information we have

The Trustee normally holds some or all of the following types of personal information:

• Your name, date of birth, age at retirement, national insurance number and bank account information (where benefits are in payment).
• Your gender (so that we know the gender composition of the Scheme – for example, for actuarial purposes to help us manage the Scheme);
• Contact details (including your address, phone number and email address).
• Benefit entitlement data and if your benefits from the Scheme derive from your employment, details of your employer when you were building up benefits in the Scheme, how long you worked for them and your salary from time to time.
• Whether you are married or in a civil partnership (or other data about personal relationships) and other information we might need to pay any benefits due on your death.
• Any information you have provided about who you would like to receive any benefits due on your death.
• If your benefits from the Scheme form part of a divorce settlement, details of that settlement.

The Trustee has a legal obligation to carry out due diligence checks in the event of a pension transfer request.   If you wish to transfer to an occupational pension scheme, we have to request evidence that demonstrates an “employment link”. This could include a letter from your employer confirming your employment, a schedule of contributions, payslips and bank statements (the bank account detail on your payslip might be different to the bank details the Trustee holds about you).  If you request a transfer to an overseas pension scheme, we have a legal obligation to check that you are a resident in the same country as that scheme. This evidence might include utility bills, TV subscriptions, insurance documents relating to your overseas home, address, bank account and credit card statements, evidence of local tax being paid and registration of address with local doctors.

The Trustee may sometimes use other information about you, including information it reasonably believes is required to meet our legislative or regulatory requirements.  This could include information about your health where it is relevant to, for example, early payment of benefits from the Scheme, or details about personal relationships to determine who should receive benefits on your death.  The Trustee might also, very rarely, have information about criminal convictions and offences, but only where it is relevant to the payment of Scheme benefits.  The Trustee might hold data about any vulnerabilities you’ve told us about and use that data to correspond with persons having power of attorney for you or other persons helping you with your affairs in other ways (e.g. friend or relative caring for or helping you).

Where we get personal information from

Some of the information the Trustee has comes directly from you.  In addition, the Scheme’s administrators may have obtained information from you and passed it to the Trustee.  The Trustee may then in turn pass information about you to the Scheme Actuary or may instruct the administrators to do so.  The Trustee is the source of the personal information which the Scheme Actuary has about you.

Sometimes the Trustee gets information from other sources: for example, from your Scheme employer (for information such as your salary and length of service); from another scheme if you have transferred benefits from that scheme; from government departments such as HMRC and DWP; and from publicly accessible sources (for example the electoral roll) if the Trustee has lost touch with you and are trying to find you. The Trustee may in turn pass this to the Scheme Actuary (as above).

If the Trustee asks you for other information in the future (for example, about your health), it will explain whether you have a choice about providing it and the consequences for you if you do not do so.

Why we hold personal information and how we share it

The Trustee must by law provide benefits in accordance with the Scheme’s governing documentation and must also meet other legal requirements in relation to the running of the Scheme.

The Trustee will use your personal information to comply with these legal obligations, to establish and defend its legal rights, and to prevent and detect crimes such as fraud.  The Trustee may need to share your personal information with other people for this reason, such as courts and law enforcement agencies.

The Trustee also has a legitimate interest in properly administering the Scheme.  This includes: paying benefits as they fall due; purchasing insurance contracts; communicating with you; and ensuring that correct levels of contributions are paid, benefits are correctly calculated and the expected standards of Scheme governance are met (including standards set out in Pensions Regulator guidance). We make sure that we balance these interests against your interests.

In order to achieve this, the Trustee may share your personal information with various people, including: any new trustee directors; the Scheme employers; the Scheme administrators; the Scheme Actuary; the Trustee’s other professional advisers including the Pensions Manager; auditors; insurers; HMRC; the Pensions Ombudsman; the Pensions Regulator; the Information Commissioner; IT and data storage providers and other service providers such as tracking and tracing services or consultancy services used by the Trustee in relation to transactions regarding Scheme benefits.  If your benefits are transferred to another scheme, the Trustee will also need to provide the administrators of that scheme with information about you.

Benefits in the Scheme are secured via a combination of a bulk annuity policy with Phoenix Life Limited, trading as Standard Life, who reinsures the benefits with Prudential, and a bulk annuity policy with Pension Insurance Corporation. Their respective privacy notices can be accessed at the following links:

https://www.phoenixlife.co.uk/legal-and-policies/privacy-notice, https://www.prudential.com/links/privacy-policy, https://www.pensioncorporation.com/privacy-policy

When the Trustee needs to use information about your health, it may ask for your consent.  However, sometimes there may be reasons of public interest or law which enable the Trustee to use information about your health without consent and similarly the Trustee might use other very personal information such as details about personal relationships relevant to who should receive benefits on your death without needing to collect your consent.  The Trustee will process this information where that is necessary to run the Scheme in a sensible way.  If you have given a consent about your health information you can withdraw your consent at any time by contacting the Trustee using the contact details given below.  This may affect what the Trustee can do for you, unless it has another lawful reason for using your information. The Trustee may also share your personal information with someone else where you have given your consent – for example, where you transfer your benefits out of the Scheme.

The Scheme’s employers may also have a legitimate interest in contacting you about your benefits under the Scheme, and any additional options which may be available to you in relation to those benefits.  In such circumstances, the Trustee may share your personal information with the employers so that they can contact you for this purpose.

How the Scheme Actuary uses your personal information

The Scheme Actuary is currently Stuart Hailwood at Mercer, who is appointed by the Trustee to value the Scheme benefits and carry out other calculations in relation to your Scheme benefits.  He will use your personal information for this purpose and has a legitimate interest in doing so.  The Scheme Actuary will also use your personal information to comply with his own legal obligations, and may need to share your details with other people for legal reasons, such as courts and law enforcement agencies.  He may also share it with his own professional advisers, auditors and insurers, IT and data storage providers and other service providers.

The Scheme Actuary processes your Personal Information, separately from the Trustee, for the legitimate reasons above and for compliance with his own legal obligations as an advisor to the Scheme. For more details about this, see Annex A (below) where we have included the information Mercer has provided to the Trustee about Mercer and the Scheme Actuary’s processing activities as data controller.

Sometimes, your information may be used by the Trustee and the Scheme Actuary for statistical research, but only in a form that no longer identifies you personally. In some circumstances, the Scheme Actuary may be able to use information which the Trustee has provided on an anonymous basis.

Mercer’s privacy notice relating to actuarial services provided in the UK can be accessed at the following link:  https://www.uk.mercer.com/actuarial-services-privacy-notice.html

Your rights in relation to your personal information

You have rights in relation to the personal information we have about you.  You have the right to:

• make a request to have your personal information corrected if it is inaccurate, and completed if it is incomplete;
• in particular circumstances, restrict the processing of your information;
• in particular circumstances, ask to have your information erased;
• request access to your information and to obtain information about how we process it;
• in particular circumstances, move, copy or transfer your information;
• in particular circumstances, object to us processing your information;
• not be subject to automated decision-making including profiling where it produces legal or other significant effects on you.

You can exercise all of these rights free of charge except in some very limited circumstances, and we will explain these to you where they are relevant.

How to contact the other people we give your personal information to

Some of the people mentioned above just use your personal information in the way we tell them.  However, others (including the Scheme Actuary) may make their own decisions about the way they use this information to provide their services, perform their functions, or comply with their regulatory requirements. In such a case, they have responsibilities as data controllers in their own right.  This means that they are subject to the same legal obligations as us in relation to your information, and the rights you have in relation to your information apply to them, too.

If you would like more information from the Scheme Actuary or to exercise rights against the Scheme Actuary, please contact the Trustee via pensions@lseg.com, in the first instance.

If you want any more information from any other third party who receives your personal information from us, or to exercise any rights against the information they hold, please contact the Trustee via the Scheme administrator using the contact details at the end of this notice.

How long we keep your personal information for

We need to keep your personal information long enough to make sure that we can satisfy our legal obligations in relation to the Scheme and pay any benefits due to or in respect of you.

We keep your information for sufficient time to ensure that, if a query arises in the future about your benefits, we have enough information to deal with it where we have a legal obligation to do so.  To meet this requirement the personal information that we hold will be kept for a period of 75 years from the end of the Scheme year in which a transfer out occurs or the last payment of any benefits is made to or in respect of you.

We need to keep information for this long so that we can deal with any future queries or complaints. These may arise from you or your beneficiaries, or any other persons.

Keeping your information safe

When we pass your information to a third party, we seek to ensure that they have appropriate security measures in place to keep your information safe and to comply with general principles in relation to data protection.

Some of the people we share your information with may process it overseas.  This means that your personal information may on occasion be transferred outside the UK.  Some countries already provide adequate legal protection for your personal information, but in other countries, additional steps will need to be taken to protect it.

You can contact us for more information about the safeguards we use to ensure that your personal information is adequately protected in these circumstances (including how to obtain copies of this information).

Queries and further information

If you have any queries, please contact the Trustee via the Scheme administrators using the details below:

If you have concerns about the way we handle your personal information, you can contact the Information Commissioner’s Office or raise a complaint at www.ico.org.uk/concerns, or call its helpline on 0303 123 1113.

Annex A – Information from Mercer / the Scheme Actuary

Mercer and the Scheme Actuary’s processing activities as data controller

1. Mercer and Scheme Actuary collect and Process the following categories of Personal Data (including special categories of data) as data controllers: Details such as a member’s name, date of birth, gender, address, email address, telephone number, employer name, employment and pensionable service periods, salary, nature and details of current and historic pension arrangements, pension amounts, pension contributions, employee benefits, marital status, beneficiary details, bank details, national insurance number, medical records and/or ill-health status in relation to current, former and potential members of Client’s pension scheme; beneficiaries of current, former and potential members of Client’s pension scheme; and representatives of the Client.
2. Depending on the scope of its engagement, Mercer (and the Scheme Actuary) will Process Personal Data to provide actuarial services, to comply with its statutory and regulatory obligations, to maintain accounts and records and to conduct analysis in order to improve its products and services.
3. Except where Mercer (and the Scheme Actuary) must rely on Client obtaining Data Subjects’ consent to the Processing, the legal grounds Mercer (and the Scheme Actuary) relies on in order to undertake such Processing are the “legitimate interests” ground or “necessary for performance of a contract” ground.
4. Mercer and the Scheme Actuary shall retain Personal Data that it Processes in accordance with its document retention and deletion policies and as required by law or in order to defend any actual or possible legal claims.
5. Mercer is an affiliate of Marsh & McLennan Companies, Inc. “MMC”, and “MMC Group” shall mean the corporate group of MMC.  MMC has adopted processor binding corporate rules in the form of the Processor standard (the “Standard”) in order to provide adequate safeguards for transfers of Personal Data from certain MMC Group Affiliates to certain non-EEA MMC Group Affiliates.  The Standard will be made available at https://www.uk.mercer.com//data-protection.html.
6. The transfer of Personal Data outside of the UK or a country recognised by the Information Commissioner as providing an adequate level of protection for personal data, shall be covered by a framework recognised by the relevant authorities or courts as providing an adequate level of protection for Personal Data, including but not limited to binding corporate rules and Standard Contractual Clauses.