- What we do
As the administering authority of the fund, the Royal Borough of Greenwich holds certain information about you (personal data) which we use to administer the fund and to pay benefits from it.
We hold personal data about you in our capacity as data controller for the proper handling of all matters relating to the fund, including its administration and management.
This notice is for members and beneficiaries of the Royal Borough of Greenwich Local Government Pension Scheme (the fund), Equitable Life Additional Voluntary Contribution (AVC) scheme and Clerical Medical AVC scheme.
- Contact details
- Why we need your information and how we use it
We will use this data to deal with all matters relating to the fund, including its administration and management. This can include the processing of your personal data for all or any of the following purposes:
- to contact you
- to assess eligibility for, calculate and provide you (and, if you are a member of the fund, your beneficiaries upon your death) with benefits.
- to identify your potential or actual benefit options and, where relevant, implement those options
- to allow alternative ways of delivering your benefits, for example, through the use of insurance products and transfers to or mergers with other pension arrangements
- for statistical and financial modelling and reference purposes (for example, when we assess how much money is needed to provide members' benefits and how that money should be invested).
- to comply with our legal and regulatory obligations as the administering authority of the fund
- to address queries from members and other beneficiaries and to respond to any actual or potential disputes concerning the fund
- the management of the fund's liabilities, including the entering into of insurance arrangements and selection of fund investments
- in connection with the sale, merger or corporate reorganisation of or transfer of a business by the employers that participate in the Fund and their group companies.
- What type of information we collect
The types of personal data we hold and process about you can include:
- contact details, including name, address, telephone numbers and email address
- identifying details, including date of birth, national insurance number and employee and membership numbers
- information that is used to calculate and assess eligibility for benefits, for example, length of service or membership and salary information
- financial information relevant to the calculation or payment of benefits, for example, bank account and tax details
- information about your family, dependents or personal circumstances, for example, marital status and information relevant to the distribution and allocation of benefits payable on death
- information about your health, for example, to assess eligibility for benefits payable on ill health, or where your health is relevant to a claim for benefits following the death of a member of the fund
- information about a criminal conviction if this has resulted in you owing money to your employer or the Fund and the employer or Fund may be reimbursed from your benefits
We obtain some of this personal data directly from you. We may also obtain data (for example, salary information) from a variety of sources including:
- your current or past employer(s) or companies that succeeded them in business
- a member of the fund (where you are or could be a beneficiary as a consequence of that person's membership of the fund)
- public databases (such as the register of births, deaths and marriages)
- our advisers and government or regulatory bodies, including those in the list of organisations that we may share your personal data with set out below.
Where we obtain information concerning certain 'special categories' of particularly sensitive data, such as health information, extra protections apply under the data protection legislation. We will only process your personal data falling within one of the special categories with your consent, unless we can lawfully process this data for another reason permitted by that legislation.
You have the right to withdraw your consent to the processing at any time by notifying us in writing. However, if you do not give consent, or subsequently withdraw it, we may not be able to process the relevant information to make decisions based on it, including decisions regarding the payment of your benefits.
Where you have provided us with personal data about other individuals, such as family members, dependants or potential beneficiaries under the fund, please ensure that those individuals are aware of the information contained within this notice.
- Who we may share your information with
From time to time we will share your personal data with advisers and service providers so that they can help us carry out our duties, rights and discretions in relation to the fund.
Some of those organisations will simply process your personal data on our behalf and in accordance with our instructions. Other organisations will be responsible to you directly for their use of personal data that we share with them.
The data controllers may be obliged under the data protection legislation to provide you with additional information regarding the personal data they hold about you and how and why they process that data. Further information may be provided to you in a separate notice or may be obtained from the advisers and service providers direct.
These organisations include the fund's data processors:
- administrator - currently the Royal Borough of Greenwich
- accountants - currently Royal Borough of Greenwich
- communications adviser - currently the Royal Borough of Greenwich
- tracing bureaus for mortality screening and locating members - currently Atmos
- overseas payments provider to transmit payments to scheme member with non-UK accounts - currently Equiniti
- printing companies - currently in-house Royal Borough of Greenwich printing and design service
- pensions software provider - currently Aquila Heywood
- suppliers of IT, document production and distribution services - currently the Royal Borough of Greenwich.
These organisations also include the fund's data controllers:
- actuarial consultant - currently Barnett Waddingham
- investment adviser - currently Hymans Robertson
- additional Voluntary Contribution providers - currently Equitable Life and Clerical Medical
- legal adviser - currently the Royal Borough of Greenwich
- fund actuary - currently Barnett Waddingham
- statutory auditor - currently Grant Thornton
- external auditor - currently Grant Thornton
- internal auditor - the Royal Borough of Greenwich
- occupational health provider - currently Health Management
- LGPS National Insurance database - South Yorkshire Pensions Authority
- administering authorities of other Local Government Pension Scheme (LGPS) funds (or their agents, such as third party administrators) where you have been a member of another LGPS fund and the information is needed to determine the benefits to which you or your dependents are entitled
- Department for Work and Pensions
- Government Actuary's Department
- Cabinet Office - for the purposes of the National Fraud Initiative
- Her Majesty's Revenue and Customs (HMRC)
- Courts of England and Wales - for the purpose of processing pension sharing orders on divorce.
In each case we will only do this to the extent that we consider the information is reasonably required for these purposes.
In addition, where we make fund investments or seek to provide benefits for fund members in other ways, such as through the use of insurance, then we may need to share personal data with providers of investments, insurers and other pension scheme operators. In each case we will only do this to the extent that we consider the information is reasonably required for these purposes.
From time to time we may provide some of your data to your employer and their relevant subsidiaries (and potential purchasers of their businesses) and advisers for the purposes of enabling your employer to understand its liabilities to the scheme. Your employer would generally be a controller of the personal data shared with it in those circumstances. For example, where your employment is engaged in providing services subject to an outsourcing arrangement, we may provide information about your pension benefits to your employer and to potential bidders for that contract when it ends or is renewed.
Where requested or if we consider that it is reasonably required, we may also provide your data to government bodies and dispute resolution and law enforcement organisations, including those listed above, the Pensions Regulator, the Pensions Ombudsman and HMRC. They may then use the data to carry out their legal functions.
The organisations referred to above may use the personal data to perform their functions in relation to the fund as well as for statistical and financial modelling (such as calculating expected average benefit costs and mortality rates) and planning, business administration and regulatory purposes. They may also pass the data to other third parties (for example, insurers may pass personal data to other insurance companies for the purpose of obtaining reinsurance), to the extent they consider the information is reasonably required for a legitimate purpose.
In some cases recipients of your personal data may be outside the UK. This means your personal data may be transferred outside the European Economic Area (EEA) to a jurisdiction that may not offer an equivalent level of protection as is required by EEA countries. If this occurs, we are obliged to verify that appropriate safeguards are implemented with a view to protecting your data in accordance with applicable laws. Contact us if you want more information about the safeguards that are currently in place
We do not use your personal data for marketing purposes and will not share this data with anyone for the purpose of marketing to you or any beneficiary.
- How long we keep your information
We will only keep your personal data for as long as we need to in order to fulfil the purpose(s) for which it was collected and for so long afterwards as we consider may be required to deal with any questions or complaints that we may receive about our administration of the fund, unless we elect to retain your data for a longer period to comply with our legal and regulatory obligations.
In practice, this means that your personal data will be retained for such period as you (or any beneficiary who receives benefits after your death) are entitled to benefits from the fund and for a period of 15 years after those benefits stop being paid.
For the same reason, your personal data may also need to be retained where you have received a transfer, or refund, from the fund in respect of your benefit entitlement.
- PDF document
- Your rights
- Version date
- June 2019