As the Trustees of the National Trust Retirement and Death Benefits Scheme (the "Scheme"), we collect personal data about you so we can administer your pension benefits and ensure the smooth running of the Scheme. Consequently, the Trustees are deemed to be the “Data Controller” in respect of your personal data. New laws are coming into force in May 2018 which will apply to how we do this. We want to take this opportunity to update you on how we collect, use and process your data. There is nothing that you need to do in relation to this notice, it is for your information and so that you know what we are doing to safeguard your data and to make sure we process your data in accordance with law.
Why we collect personal data
There are two main reasons why we collect, store and use your data (this is called "processing"):
- The primary reason is to allow us to operate the Scheme. This includes working out your level of benefits (and those payable to your beneficiaries) and for calculating and managing the funding position of the Scheme. If we did not have this data we would not be able to administer the Scheme effectively. This means we process your data for the purposes of our "legitimate interests".
- The other reason we process your data is to comply with our legal obligations, for example to keep and maintain records about you and to fulfil our obligations to HMRC.
The type of personal data we process
The type of personal data we may process could include, for example, your name and address, date of birth, gender, salary / pension details, National Insurance details, bank details, your email address, and other information collected through communication with yourself, your employer and your advisers.
Occasionally, some of the data that you disclose to the Trustees may be sensitive personal data. For example, the Trustees may require you to provide them with information relating to your health. In the event that you are providing the Trustees with any sensitive personal data you will be asked to complete a consent form. This will enable the Trustees to process your sensitive personal data for the purposes set out in the form.
We may get this data from you or from your employer/previous employer and it may be collected on our behalf by another party (such as one of our advisers below).
The Trustees (and our advisers) may monitor, record, store and use any telephone, email or other communication with you in order to maintain a record of any instructions given to us, for training purposes, for crime prevention and to improve the quality of our customer service.
How your information is processed
Your personal data will be processed for the purposes of operating the Scheme, including:
- Calculation of any benefits which you (or your beneficiaries) are entitled to receive from the Scheme under different scenarios (e.g. on leaving, retirement, death, ill-health, etc.)
- Provision of data to third parties which will allow them to fulfil their legal / commercial requirements (e.g. complete actuarial valuations / calculations, audit the Scheme, etc.)
- Allow us to be able to communicate with you and other members of the Scheme
- Meet our legal / regulatory requirements
- General management (including liability management exercises) of the Scheme
Who will have access to your personal information?
To ensure the smooth running of the Scheme we may pass your personal data to third parties, including our professional advisers, insurers, service providers where we believe it is in the legitimate interests of the Scheme and to regulatory bodies where legally required to do so. The National Trust, as an Employer, also assists the Trustees in administering the pension scheme (including the payment of pensions). Therefore, some employees at the National Trust (and their suppliers) also have access to your personal data, on a controlled basis.
Where possible, we will anonymise your data before it is shared with other parties.
Some of the parties we share your data with can determine how they process your data as they have a legitimate interest in doing so to provide us with advice (they are also called "data controllers"). These parties are currently our actuarial and consultancy advisers Aon Hewitt Limited (including our individual Plan Actuary see appendix), our auditors Crowe Clark Whitehill and our legal advisers Herbert Smith Freehills LLP. These parties are subject to the same legal data protection requirements as us.
We confirm that we do not share your personal data with anyone for marketing purposes.
Security of Information
We take the security of your personal information very seriously. We, our preferred providers and the National Trust, have put in place appropriate technical and contractual measures to prevent the unauthorised access, improper use or disclosure, unauthorised modifications or unlawful destruction or accidental loss of your personal data once under our control. This includes regular training on data security issues and ensuring appropriate safeguards are in place to manage personal data appropriately (both inside and outside the European Economic Area).
Access to Information
As a member of the Scheme, you are entitled to know what personal information we hold that relates to you, the purpose for which we hold it and the identity of any person to whom it has been disclosed. You can write to us at any time to obtain a copy of this information and to have it corrected or removed if you think it is inaccurate. You may also have the right to object to our processing of your data and ask us to stop, or restrict, doing so. However, these rights may be limited due to the nature of a pension scheme.
Retention of your personal data
We will keep your data while you are a member of the Scheme and while benefits are paid to you and your dependants. We expect to keep your data for the life of the Scheme itself, and at least a further 6 years thereafter. In particular, we will keep your data if we believe that the law or relevant authorities require us to do so, or that it is still reasonably required for the purposes of the Plan.
In any case, we will keep your data for the minimum period required by law. This is 6 years from the end of the plan year in which you leave the Plan, or stop receiving benefits from it (or your beneficiaries stop receiving benefits from it).
Keeping up to date
We may use your contact information to keep you updated about your pension benefits and the activities of the Scheme. We will not disclose your personal information to any other party or for any other reason, other than as set out above, without your prior consent.
If you have any queries in relation to the above or wish to find out more about how to access your personal data, please contact:
Secretary to the Trustees
National Trust Retirement and Death Benefits Scheme
c/o National Trust
Heelis, Kemble Drive
We hope that this will not be the case, but if you do have any concerns with how we have handled your personal data, please contact[the Secretary to the Trustees or you have the option of raising a complaint to the Information Commissioner's Office https://ico.org.uk/.
Appendix A: Aon Hewitt’s Privacy Notice
Aon Hewitt Limited (and, where appointed, the Scheme Actuary - together "Aon") has been appointed to provide pensions advisory and calculation services that relate to your membership of the pension scheme. In doing so Aon will use personal information about you, such as your name and contact details, information about your pension contributions, age of retirement, and in some limited circumstances information about your health (where this impacts your retirement age) in order to be able to provide these services.
The purposes for which Aon use personal information will include management of the pension scheme and your membership within it, funding the pension scheme (i.e. helping to ensure that the funds within the pension scheme are sufficient to cover the members who are party to it), liability management (that is to say providing advice on the different ways benefits could be determined, and drawn, from the pension scheme), scheme actuary duties (which include assessing individuals who are members of the pension scheme and assessing how the make-up of the membership may affect the amounts payable and when they become payable so as to manage the pension scheme appropriately), regulatory compliance, process and service improvement and benchmarking.
Aon may pass your personal information to third parties such as financial advisors and benefits providers, insurers, their affiliates and service providers and to certain regulatory bodies where legally required to do so. Depending on the circumstances, this may involve a transfer of data outside the UK and the European Economic Area to countries that have less robust data protection laws. Any such transfer will be made with appropriate safeguards in place and in accordance with law.
More detail about Aon’s use of your personal information is set out in their full Privacy Notice. It is recommended that you review this notice which is available online at the following: http://www.aon.com/unitedkingdom/products-and-services/human-capital-consulting/aon-hewitt-actuarial-services-privacy-statement.jsp, or you can request a copy by contacting Aon directly, including reference to the National Trust Retirement and Death Benefits Scheme, at:
Data Protection Officer
Aon Hewitt Limited (Retirement and Investment UK)
PO Box 730