Sunday 22 July 2018
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Pensions Privacy Notice

What do we use the information for?

East Riding Pension Fund (“the Fund”) is responsible for the administration of the Local Government Pension Scheme (“the Scheme”). The service is carried out by East Riding of Yorkshire Council (“the administering authority”) on behalf of qualifying employers and the Scheme members.


The Fund holds information about individuals so that it can provide the services to members and other stakeholders, fulfilling its legal requirement to provide individuals with the following:

  • Basic information to members on the LGPS on joining or upon request by other parties 
  • Information to early leavers and those retiring from the LGPS
  • Information on request relating to transfers to and from the LGPS
  • Annual Benefit Statements 
  • Information about pensions in payment
  • Information regarding changes to the regulations that govern the LGPS

What information do we hold and use?

The Fund collects and processes the following types of personal data in order to provide the services:

  • Personal, for example name, date of birth, address, sex and marital status
  • Employment information, for example national insurance number, details of employer, salary details, employment dates, details of service breaks
  • Bank details, for example so that we can pay pension benefits
  • Limited health information to assess eligibility for certain scheme benefits

On what grounds do we use the information?

The Fund has a legal obligation and statutory duty to provide individuals with certain information under a number of regulations including:

  • The Occupational and Personal Pension Schemes (Disclosure of Information) Regulations 2013
  • The Pensions Act 2011(Transitional, Consequential and Supplementary Provisions) Regulations 2014 
  • The Occupational and Personal Pension Schemes (Disclosure of Information) Amendment Regulations 2015
  • The Local Government Pension Scheme (LGPS) Regulations 2013

How do we collect this information?

Most of the personal data we collect and process is provided by either your employer or you and this information is normally mandatory to fulfil the legal requirement.  Where any data collected is not mandatory and is provided to us on a voluntary basis we will inform you that you have a choice whether to provide this.

Who we share your information with?

The Fund procures the services of various providers to support its management and administration of the scheme. The following providers may have access to your information purely for the purposes of supporting our administration system; they will not use your information for any other purpose.

  • Civica Group Ltd

The Fund may share or disclose your information to any of the following recipients as may be necessary to administer the scheme in line with statutory obligations and/ or to comply with contractual obligations relating to it:

  • Service providers, professional advisers and auditors who in certain circumstances will also be “data controllers”. These organisations in respect of the Fund are as follows:

Type of service/adviser

Name

Reasons for sharing data

Scheme Actuary

Hymans Robertson

To calculate the value of the scheme’s assets and liabilities and to set employer contribution rates.

Scheme AVC Provider

Prudential

To facilitate the creation and maintenance of individual member’s AVC accounts.

Data Audit Consultant

KPMG

To provide an external audit of data quality and integrity to comply with legislation on the accuracy of member data.

Scheme Auditor

East Riding of Yorkshire Council

To facilitate the statutory duty of the auditing of the scheme’s Annual Report and Statement of Accounts and internal controls.

Overseas Payments Provider

Citibank

To transmit payments to scheme members with non-UK bank accounts.

LGPS National Insurance Database

South Yorkshire Pension Fund

To enable the Fund to identify if members have benefits in other LGPS schemes to ensure that appropriate benefits are paid.

DWP Tell Us Once Service

Department for Work and Pensions

To enable the Fund to be notified of the death of a scheme member.

Tracing Scheme members

Accurate Data Services

To assist the Fund to locate Scheme members.

Communication Solutions

Adare

East Riding of Yorkshire Council

To facilitate the print and delivery of outgoing mail and to co-ordinate the receipt of incoming mail.


  • Regulators, the government and law enforcement authorities. This also includes participating in the Cabinet Office’s National Fraud Initiative for the purposes of the prevention and detection of fraud against the Fund and organisations within the public sector and the Government Actuary’s Department for the calculation of the triennial assessment of the cost of the Local Government Pension Scheme on a national basis as per the Public Service Pensions Act 2013. By law we are also required in certain circumstances to share your information with government organisations such as Her Majesty’s Revenue and Customs and the Department of Work and Pensions so that they can monitor our performance and ensure that public funds are safeguarded.
  • Local and foreign courts, tribunals and arbitrators, other judicial committees of enactments of laws.
  • Persons in connection with any transfer of employment of a scheme member or members under TUPE which results in a transfer out of this scheme to another pension scheme.

How long do we store information and is it secure?

The Fund has a retention schedule in place to ensure that information is only held for as long as it is needed. For information on how long your information will be held visit www.eastriding.gov.uk/privacynotice.

What rights do you have?

Under GDPR individuals have the right to control the information held about them and how it is used.  The rights that you have depend upon the grounds upon which your information is collected.  All of the rights you could have are outlined on at www.eastriding.gov.uk/dataprotection.  For the purpose of administering the LGPS individuals will have the following rights:

The right of access

You are entitled to see the information we hold about you and can request a copy by emailing data.protection@eastriding.gcsx.gov.uk

The right to rectification

If you believe any information we hold about you to be incorrect, please email erpf@eastriding.gcsx.gov.uk and we will amend the information accordingly. 

The right to erasure/ right to be forgotten

The Fund, in providing statutory duties under the regulations has determined that it cannot permanently delete a member’s record.  

The right to restrict processing

Should you wish the Fund to limit how we use your data please email erpf@eastriding.gcsx.gov.uk with the reason for your request. 

The right to data portability

This is particularly relevant to members who may choose to transfer out of the Fund to another pension provider. The Fund will provide the information we hold about to your new pension provider in a format that they can use. The transfer would not take place without your consent. 

The right to object

In addition to the right to limit the use of your data, you also have a right to object to the use of your data for certain actions. 

The Fund may share your information with third parties, for example where we outsource our print to mail documents (payslips, P60’s, benefit statements). Under GDPR you can object to the Fund sharing your data with these third parties.

Should you exercise your right to object, it will not limit the information you receive from the Fund, as we may still be required by law to provide you with certain information. In cases such as this the Fund will take appropriate steps to ensure your request is complied with but that it also fulfils any legal obligation it has to provide you with information or supply services.

Where can I find out more?

If you want to know more about how the Council uses information, your rights or have a concern about the way we are collecting or using your personal data, we request that you raise your concern with us in the first instance; contact details are available on the general privacy information page. Alternatively, you can contact the Information Commissioner’s Office.