Privacy Notice

Privacy

Who we are

Magnox Electric Group Pension Trustee Co Ltd is the trustee (the “Trustee”) of the Magnox Electric Group of the Electricity Supply Pension Scheme (the “Scheme”).  

As the Trustee of the Scheme, we hold certain personal information (known as “personal data”) about scheme members and, where applicable, their dependants and beneficiaries.  Most of the information held about you and processed by the Trustee in running the Scheme will be personal data (in other words, because we hold information from which you as an individual can be identified, any information we hold in respect of you will be subject to certain protections). 

For legal purposes, the Trustee is known as the “data controller”, as we decide the purposes for and the means by which the personal data we hold is processed.  

The Trustee’s actuarial advisers, currently Aon, and (in certain circumstances) its legal advisers, currently Sacker & Partners LLP, are also data controllers in relation to some of your personal data that the Trustee holds. A short form privacy notice from Aon is contained in the Appendix to this Notice. This contains a link to Aon’s full privacy notice.  A link to the Trustee’s legal advisers’ privacy notice can be found here - pension scheme members, beneficiaries and client’s employees.

What information we collect about you

Depending on the circumstances and the stage of your membership, we may hold some or all of the following information about you:

• your name, age, date of birth, gender;  
• your marital status;
• your address and other contact details (such as telephone number and email address);
• your national insurance number;
• information about your benefits under the Scheme, including pensions and death benefits, together with corresponding details of assets, investments and insurance;
• your pensionable service;
• relevant employment information, such as current and past salary information, pensionable pay, employment dates, length of service, and career history (where relevant);
• details of your bank account (to pay benefits);
• details about your dependants and/or beneficiaries (including their names and possibly details of their gender);
• details about your next of kin and emergency contact information;
• medical and other details about your health (to pay health related benefits);
• if you have used a pensions dashboard, an online platform where you can access information about all of your pension benefits, a “pensions identifier”, which is a string of characters used to identify your specific benefits under the Scheme; and
• details of any divorce sharing orders.

In order to properly administer the Scheme and to calculate and pay benefits, from time to time we may also need to hold other information about you.

How we gather your personal information

We gather personal information from several sources including the following:

• directly from you;
• from your current or former employer;
• from persons acting as personal representatives of a deceased person’s estate;
• from a public body such as HMRC;
• from public databases such as the Register of Births, Deaths and Marriages;
• from other pension schemes, where transfers into the Scheme have been made;
• from an independent financial adviser, solicitor or other person instructed by a person to provide us with information;
• from our advisers;
• from third parties used to trace members or beneficiaries with whom we have lost contact;
• with your consent, from a registered medical practitioner; and
• from other third parties including, for example, your next of kin or anyone else entitled to benefit from your membership of the Scheme.

How we use that information

The Trustee has a legitimate interest in holding and processing the above information about you as it is needed for us to properly administer the Scheme and to calculate and pay benefits.  We also process and keep the above information to allow us to comply with our obligations towards members under the Scheme governing documents, as well as under relevant legislation.  For example, the relevant legislation allows “special categories of personal data” to be processed in connection with employment, social security and social protection, and the Trustee may rely on this provision from time-to-time We also process and keep the above information to the extent required to comply with our duties in relation to individuals using pensions dashboards. This includes “matching”, where we use personal data that a user has provided to search our Scheme records to check whether that user is a member of the Scheme, and where we collect further personal data from that user in the event of a “possible match”.

Personal data relating to the Scheme is held on paper and on computer systems. As the “data controller”, the Trustee must process this information fairly and lawfully.

As part of running the Scheme, we may also need to hold and process particularly sensitive information about you and/or your dependants and beneficiaries (known as “special categories of personal data”).  Under data protection legislation, details relating to health, racial or ethnic origin, religious or other similar beliefs, sexual orientation and political affiliations are regarded as “special categories of personal data”.  Except where the legislation allows it, this information cannot be processed or passed to a third party without your explicit consent.

We will not process personal data for any purpose or purposes which we have not told you about.  However, there are exceptions to this.  For example, if it were obvious to an individual that personal information would be processed for the new purpose or if the new purpose was in fact compatible with the original purpose(s) for which the personal data was collected.

What else we might do with personal data

We may transfer, store, or process your personal data outside of the UK or the European Economic Area (“EEA”) (as applicable). Where this is the case, any transfer of Scheme personal data outside of the UK or EEA (as applicable) will comply with the requirements of data protection legislation.  Such transfers will generally be made relying on UK adequacy regulations.  Alternatively, they may be made using the UK’s International Data Transfer Agreement or, where relevant, using the UK Addendum to the European Commission’s standard contractual clauses, and where we consider that the protection for the data subject’s personal data would not be “materially lower” after the transfer.  You can find copies of the Agreement and Addendum here.

Who we share it 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 advisers to properly administer the Scheme, we share personal data with the following:

• your current, past or future employer, which may include group companies which are based outside the UK or EEA (as applicable). Where data is sent outside the UK or the EEA (as applicable), appropriate safeguards are put in place to ensure that your data is kept secure
• the employers’ payroll service providers
• the Scheme’s pensions manager and NRS Services
• the Scheme’s professional advisers, including the Scheme actuary, auditor, medical advisers, investment adviser and lawyers
• the third parties who are responsible for the day-to-day administration of the Scheme on behalf of the Trustee
• HM Revenue & Customs and other statutory bodies (such as the Pensions Ombudsman, the Pensions Regulator and the Department of Work and Pensions) or other third parties as required by law – the Trustee can be fined and subject to other action if it fails to provide certain information to these authorities 
• persons in connection with any investment changes, sale, merger, acquisition, disposal, reorganisation or similar change involving the Scheme (including any counterparties, potential or actual purchaser and their advisers)
• the advisers and printers who help us prepare various communications we send to you, such as the annual benefit statement and newsletters
• third parties that form part of the “dashboard ecosystem” that enables pensions dashboards services to work, as well as the Scheme’s Integrated Service Provider (ISP), which provides a service allowing pensions information from the Scheme to be connected to the dashboard ecosystem
• our appointed insurance company or companies for the purposes of life insurance and additional voluntary contributions and investments such as annuity purchases
• depending upon how we pay pensions, the personal data we have to supply in order to effect a BACS transfer (the Bankers' Automated Clearing Service) or CHAPS (the Clearing House Automated Payment System] in the UK and/or a payment via Western Union the administrators’ banking providers when pensions are being paid overseas
• tracing agencies when we have lost contact with members or beneficiaries and mortality screening services
• the trustee’s website service provider
• external IT support companies