The General Data Protection Regulations (GDPR) is a new law which is designed to strengthen data protection for individuals within the European Union, including the UK. It will come into effect from 25 May 2018 and its main objective is to give you better control of your personal data, as well as simplify the regulatory environment for international business.
The Trustee of the NDMPS 1939 Pension Scheme (the data controller who decides why and how the data is used) holds certain personal data about you, our Plan members and, where we need to, your dependants and beneficiaries. Personal data is information that uniquely identifies you.
The Trustee is committed to respecting your rights under data protection laws and we are providing this notice to help you understand how we collect and use your information. We take the privacy of your personal information very seriously.
How we use this personal information
The Trustee has a legitimate interest in holding and processing information about you in order to properly administer the Plan and to calculate and pay your benefits. The Trustee also holds and processes this information to comply with its obligations under the Trust Deed and Rules of the Plan and government legislation. Your personal data is held on paper and on computer systems.
The Trustee or NMPS pension administration team may use your personal information, including your email address, to contact you directly in order to provide relevant information or to deal with your queries.
Information we hold about you
We aim only to collect and hold the information about you which is necessary for the running of the Plan. This will include information we have collected in the past as well as new information we obtain. The types of personal information we may collect and hold could include, for example:
- Your name and postal address
- Date of birth
- Gender
- Marital status
- Telephone number
- National Insurance number
- Financial information including salary information relevant to your benefits in the Plan
- Bank account details
- Email address
- Details about your pension benefits
and other necessary information collected on joining the Plan or during your membership. Information is generally collected from you or your employer, but may also be collected from other sources if relevant, including other pension schemes and pension providers, medical practitioners, other advisers with whom the Trustee communicates in relation to the administration of the Plan, and HMRC.
Some of the data that you disclose to the Trustee may be sensitive data. For example, you may disclose information relating to your health or sexual orientation to allow the Trustee to pay certain benefits. We are usually required by law to obtain your consent to collect and hold this type of sensitive data or to pass it to a third party. Where we hold sensitive personal data about you already, we believe we are holding this with your consent.
Who we share your personal information with
We are not allowed to disclose personal data about you to other parties except:
- When required for contractual or legal reasons or other specifically identified purposes; or
- Where you have given your consent
However, as the Trustee needs help from various entities to properly administer the Plan, your information may be disclosed for processing to:
- Notts Miners pension administration team, and any employer that participates in the Plan (eg the HR and Payroll departments)
- The Plan’s professional advisers, including the actuary*, auditor, medical advisers, investment adviser and lawyers and other third parties who assist with the day-to-day administration of the Plan, such as tracing agencies
- The advisers and printers who help us prepare various communications we send to you, such as benefit statements
- Auditors or contractors or other advisers auditing any of our business processes
- Insurance companies for the purposes of life insurance, additional voluntary contributions and investing DC section contributions
- Banks and other payment systems
- Regulators and Government bodies (including HMRC and the Pensions Regulator – the Trustee can be fined and subject to other action if it fails to provide information to these authorities).
Some of these entities may transfer data to other countries, including countries outside the EEA. Where this is the case, we put in place safeguards in line with the GDPR recommendations.
How long we keep your personal information
We must keep all personal information safe and only hold it as long as is necessary. To comply with the law we must keep certain personal data for a minimum of 6 years. But, given the nature of pension schemes, the Trustee expects it to be necessary to keep this information for the duration of the Plan.
However, we do review what personal data we are holding in relation to the Plan, and how long we need to hold it, in accordance with our data retention policies.
Your rights to your personal information
Part of our role in keeping your information safe is to let you know about your rights in relation to your information. You can write to us at any time to obtain a copy of your information and to have any inaccuracies corrected. Where appropriate, you may have your personal information erased, rectified, transferred, amended or completed; and where you have given your consent to us processing your data, you can withdraw that consent.
You should be aware that taking any of the above steps could impact on the payment of your benefits, your participation in the Plan, and/or our ability to answer questions relating to your benefits.
Please also note that the Trustee can take steps to override a member’s request to object to processing, to withdraw consent or to delete personal data, if this will impact the payment of your benefits. We may charge a small fee to cover the administration costs involved in providing you with a copy of your information.
If you wish to exercise your rights in relation to your information, or want more information on the content of this statement, please submit a written application to the Pensions Manager, Berry Hill Lane, Mansfield, Nottinghamshire NG18 4JR. If you are not satisfied with our response to any query you raise with us, or you believe we are processing your personal data in a way which is inconsistent with the law, you can complain to the Information Commissioner’s Office.
Updates to this notice
This notice is up-to-date as at 12 August 2019.
