Privacy policy - Retirement Benefits Plan

This Privacy Policy was last updated on 11 June 2018.

Privacy Policy

The Trustees of the St Dunstan’s Retirement Benefits Plan (1973) respect the privacy of our scheme members. This policy explains how and why we collect, manage, use and protect your personal data. It also makes clear how you control your personal information. It should be read in conjunction with the appropriate Blind Veterans UK employee and Xafinity (Scheme Actuary) privacy policies.

Our Privacy Promise

We take our duties when processing your personal data very seriously. We promise that we will tell you what data we are collecting and why.   We will make every reasonable effort to collect, process, store and share your data safely and securely. We will also make sure that our trusted partners do the same.  We also promise that we will be open and clear with you about our use of your personal information and that you will be able to control your personal information with ease.    

Your data

In order to provide the pension scheme benefits to you or your beneficiaries, we need to collect and keep a little data about you, like your name, date of birth, contact details, banking details and, when appropriate, health details. Some of this information we may need to share with our trusted partners, such as scheme administrators and professional advisors. This is to provide you with the support and services you require from us.

We use your data to provide your pension

We use the information you provide to fulfill our legitimate interests and obligations to provide your pension and manage its benefits as required by you or the law.    

You are in control

If you would like to make any changes to the way we are processing your data, if you believe it is inaccurate or incomplete, or you have any concerns regarding how it is being processed you can discuss this with us.  You can contact us using the details in Section 9 of this policy “How to Contact Us”.  If you prefer, or wish to make a complaint, you can e-mail our Data Protection Officer whose details are also in Section 9.

Changes to this Policy

We may change this document from time to time to reflect the latest views of what we do with your information and legal and regulatory changes. Please check back frequently.  You will be able to see changes have been made by the date it was last updated.

Our Privacy Policy in detail

This policy is split into 9 sections, which can be accessed below. This policy explains:

  • 1. Who we are

    Our Privacy Policy applies to personal data collected and used by St Dunstan’s Retirement Benefits Plan (1973).  Under data protection law and regulation, we are a ‘data Controller’ and are registered as such with the Information Commissioner’s Office (Registration Reference Number: A8289097).

    The Plan and its Trust was established by St Dunstan’s (now Blind Veterans UK) as the Principal Employer to manage, administer and pay the appropriate scheme benefits to members and nominated beneficiaries.

    References to “the plan”, “the scheme”, “Trust”, “Trustees”, “our’, ‘us’, and "we" means St Dunstan’s Retirement Benefits Plan (1973). 

    For the purposes of the scheme we are Joint Controllers with Blind Veterans UK sharing responsibility for determining the purposes and means of the processing of personal data.  Xafinity are a data Processor as our scheme administrator and, as they are also the scheme Actuary, they are also a data Controller in their own right in that function.  You should refer to their privacy policies to understand how they process and treat your personal information.  Links to these policies are in Section 9 “How to Contact Us’.

     

  • 2. What personal data we collect and why

    What we need to collect

    The term ‘personal information (or data)’ means information that relates to you or another individual that means you can be identified, either directly or in combination with other information that we may hold.  We need personal information about our scheme members to allow us to provide you with your appropriate pension and benefits. 

    As a member of the scheme, we will process personal data about you in order to set up, administer, maintain, calculate and pay your pension while also meeting our legal obligations and pursuing our legitimate interests as your pension plan trust.  This information may include:

    • Postal address, telephone number, email address.
    • Date and place of birth.
    • Your national insurance number.
    • Career, unpaid leave, retirement details, membership status (in-service deferred, deferred or pensioner), details of last change in status.
    • Banking, salary, pension payment, AVC contributions, tax details and Guaranteed Minimum Pension entitlement.
    • Spouse and nominated beneficiary details.
    • Health details.

    We will be very clear with you that we wish to collect such information, our reason for collecting such information and we will only do so when we have a lawful basis for processing the information. 

    Data protection law and regulation recognises certain information as ‘special category’ data and as being particularly sensitive.  This includes:  racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, genetic data, certain biometric data, data concerning health or a person's sex life or sexual orientation.  Sometimes we may need to collect or may indirectly obtain such data.  This is most likely to be health details (e.g. in the case of ill health early retirement), where we need to consider discretionary benefits or appropriate pension payments.

    If you provide, either at our request or voluntarily, any sensitive personal information, you explicitly agree that we may collect and use it in order to provide our services in accordance with this Privacy Policy.

    The accuracy of your personal information is really important to us.  If you wish to update or correct any information we hold, please contact us using the contact details in Section 9 of this policy. 

    Why we need it

    We need your personal information in order to perform functions such as:

    • Administer and manage your pension. Whether you are a deferred member or pensioner we need to calculate retirement benefits, the value of pensions and AVCs, other benefits and entitlements, transfers and payment details.  We also need to calculate the value of the pension fund, and fulfill legal, audit and actuarial obligations. 
    • Communicate with you. To know how you prefer to be contacted and to make adjustments as you specify.  To provide you with specific services, updates and information.  To assist with technical problems related to our services.
    • To improve our services and administration. To ensure the most efficient and appropriate use of the resources we have. 
  • 3. How we collect your personal data

    We collect information about you in a variety of ways.  We may collect information you provide directly to us as well as information indirectly available from other sources, such as HMRC or tracking agents.  

    Direct from you

    You will give us personal data directly yourself: during the pension application process and subsequently when managing or amending your pension requirements; if you communicate with us or ask us to consider specific individual entitlements or adjustments.  

    Indirectly from other sources

    We may obtain your personal data indirectly when you give permission to others to share it or it is publicly available, such as from:

    • Third party organisations or Individuals. We may obtain information from third parties if you have agreed that they can approach us or we can approach them, for example a legal representative or health care agency.  We may also obtain information about you from official sources as part of enabling your pension services, such as HMRC for tax purposes or for the purpose of paying appropriate pensions using the scheme’s Actuary’s data.  
    • Publicly available sources. Public information may include information from places such as Companies House, the electoral register.  Additionally, the Post Office’s National Change of Address database allows us to keep your information up to date.
  • 4. The lawful basis for processing

    Data protection law and regulation require us to have a lawful basis for processing your personal information.  These include:

    • Where you have given explicit consent to do so for notified purpose(s). This may include when we require special category health details to consider benefit entitlements or when considering a transfer in or out of the scheme.  Where we need your consent, it will be clearly identifiable as a consent for a specific purpose.
    • To comply with a legal obligation. For example, where we are ordered to do so by a court or regulatory authority or we are legally required to process information such as tax records, pension payments and actuarial services.
    • In performance of a contract. To fulfil the requirements of the contract such as payment of Additional Voluntary Contributions (AVCs) to a contracted 3rd party provider. 
    • Where we as a pension scheme have a legitimate interest. Where we have a legitimate interest, we must ensure that we are not harming any of your interests or rights and only use it in a manner that you would reasonably expect us to.  For example, we need to administer and manage your pension scheme; be able to contact and communicate with you for pension purposes; certify your current status and details.

    Where we process special category personal information (such as health) we will ensure we do so in accordance with at least one of the additional conditions required such as having your explicit consent or carrying out our obligations as a pension provider.

  • 5. Sharing and Protecting your information

    How we keep your personal data safe

    We ensure that there are reasonable and appropriate technical and organisational controls in place to protect your personal details against unauthorised or unlawful processing and against accidental loss, destruction or damage.  We use Blind Veterans UK systems as our Joint Controller. Their computers, online systems and network are protected and routinely monitored. We and they have policies and procedures in place which Trustees and staff are expected to comply with and for which they receive training.  For more information refer to the Blind Veterans UK ‘Employee’ privacy policy.

    Who has access to your personal data

    We undertake regular reviews of who has access to information that we hold to ensure that your information is accessible only by the necessary and appropriately trained trustees and staff and trusted third parties.  Where we share your data with a third-party processor, such as Xafinity as scheme administrator, our auditors, AVC providers, legal advisors, we require that they have appropriate technical and organisational measures in place to protect your information.  However, we may be compelled by law to disclose your personal data to a third-party, such as law enforcement agencies, courts or government bodies (e.g. HMRC) and have limited control over how it is protected by that party.

    Occasions, other than by law, when we may share your data include:

    • If you have agreed that we may do so.
    • When we use external service providers to process personal data on our behalf, for example, providing pension administration, tracing and actuarial services.
    • If we believe that we need to protect the rights, property or personal safety of the scheme or Blind Veterans UK and their personnel, scheme members and for other lawful purposes.
    • We may disclose aggregate statistics about our pension to describe our scheme and for audit purposes, but these statistics won’t include any personally identifying information without explicit consent.
    • If we or Blind Veterans UK (as Principal Employer) merge with another organisation to form a new entity, information may be transferred to the new entity.

    We will never rent, share, swap or sell your personal information to other organisations for their own purposes or to make money out of your data.

    Where we store your information

    The information that you provide to us will be held in Blind Veterans UK systems, which are located in their premises or those of a trusted third-party who processes information on their behalf.  You should refer to their privacy policy for further information.

    We may need to use the services or provide access and processing to service providers and other organisations located outside of the European Economic Area (EEA). This may mean your data is transferred, processed and stored outside of the EEA. However, we will put in place appropriate safeguards to protect your data and rights, such as asking for your explicit consent, using appropriate contractual clauses and / or Privacy Shield (for the US) with our third-party supplier and / or by using encryption. With the appropriate safeguards in place, by submitting your personal information, you agree to this transfer, storing or processing at a location outside the EEA. In cases when we use external websites provided by other organisations such as Twitter or Facebook, then we would ask you to consult their privacy policies too.

  • 6. Retaining your information

    We hold your information for only as long as is necessary to fulfill the purposes for which the data was collected and our legitimate interests or in order to comply with legal or regulatory obligations, rules and requirements.

    On your death, we will retain information in order to continue to administer appropriate benefits to any nominated beneficiaries and to meet any legal or regulatory requirements or to protect our legitimate interests and for legal purposes, for example in the event of a dispute.

     

  • 7. Your details on the internet and website

    Although the Plan has no website of its own, if you use the Blind Veterans UK website, for example to access this privacy policy, you should read their privacy policy to understand what personal information they may gather about you by doing so using such technologies such as cookies.

  • 8. What are your rights?

    The new General Data Protection Regulations (GDPR) come into force 25 May 2018 and gives everyone a number of very important rights.  In abbreviated form these are:

    • The right to be informed. Transparency over how we use your personal information.  This Privacy Policy falls under this right.
    • The right of access. Request information that we hold about you.
    • The right of rectification. Update or amend the information we hold about you if it is incomplete or inaccurate.
    • The right to erase or ‘right to be forgotten'. Ask us to remove your personal information from our records where there is no compelling reason for its continued processing.
    • The right to restrict processing. Ask us to supress the processing of your information.
    • The right to data portability. Obtain and reuse your personal data for your own purposes.
    • The right to object. Object to the processing of your information for certain purposes (such as marketing, research, statistics or our legitimate interests).
    • Rights in relation to automated decision making and profiling.

    If you would like to know more about your rights under the data protection law see the Information Commissioner’s Office (ICO) website which also explains how to contact them.

    Remember, you can exercise your rights in relation to your personal information at any time by contacting us using the details set out in the ‘How to contact us’ section of this policy.

    If you are not satisfied with our response or believe we are not processing your personal data in accordance with the law and your rights, you can complain directly to the Information Commissioner’s Office.

     

  • 9. How to contact us

    If you wish to raise any comments or questions regarding this Privacy Policy or you would like to discuss how we process your information you are very welcome to do so. You can contact:

    • Post: Payroll & Pension Administration Office, St Dunstan’s Retirement Benefits Scheme (1973), Blind Veterans UK, Greenways, Ovingdean, Brighton, BN2 7BS. 
    • Phone: 01273 391442
    • Emailpayroll@blindveterans.org.uk

    If you wish to enquire further about your rights, ask for information to be provided, or to raise a complaint, please contact our Data Protection Officer. 

    • Post: Data Protection Officer, Blind Veterans UK, 12-14 Harcourt Street, London, W1H 4HD
    • Emaildpo@blindveterans.org.uk

    Other scheme related Controller details

    Our Joint Controller, Blind Veterans UK, can be contacted via the Data Protection Officer details above and their privacy policy can be found at: blindveterans.org.uk/about-us/privacy-policy (select the ‘Employee’ version from their website to see their policy as a data controller. The St Dunstan’s Retirement Benefits Plan (1973) version is this, our own, policy).

    The scheme Actuary’s (Xafinity) privacy policy is at the following link, which includes details of how to contact them if required:  xpsgroup.com/legal-regulatory/your-privacy.