The Trustees hold certain personal data about you, as Scheme members, and your dependants and beneficiaries (if any). Personal data is information that can be used to identify you as an individual.
The Trustees are “data controllers” and we are committed to respecting your rights under data protection laws. We are providing this notice to help you understand how the Trustees collect and use your information.
Data Protection – How we use information about you
We, the Trustees of the BOCM PAULS Pension Scheme (“the Scheme”) will use your personal details to assess, deal with and pay any benefits you may be entitled to under the rules of the Scheme. As part of the service we provide we may share your information with other organisations for the purposes of identifying accurate information as to your whereabouts or for the purpose of paying any benefits that you may be entitled to. We will handle your data in compliance with all relevant data protection legislation The
Trustees are data controller in respect of your personal information for the purposes of applicable data protection legislation.
Purpose
We process your data for the reasons/purposes above. This data may include:
personal details
family, lifestyle and social circumstances
financial details
employment and education details
goods or services provided
We may also need to process sensitive classes of data, such as physical or mental health details, in order to administer ill-health retirement payments and applications.
This information may be obtained from your employer, ex-employer, government agencies, service providers or from yourself.
We will only collect and use your personal data where:
there is a legal obligation for us to do so;
it is for our legitimate business interests; or
you have given us your consent to do so.
Our legitimate business interests include fulfilling our role in dealing with, assessing eligibility for and paying any benefits you may be entitled to. We will not use your data for our legitimate business interests if they are overridden by your interests,
rights or freedoms.
If we are processing your data on the basis of your consent you can withdraw your consent at any time by contacting Railpen (details shown below). The withdrawal of consent will not affect the processing of personal data carried out before consent was withdrawn.
Who the information may be shared with
From time to time we may need to share your data with other organisations. This includes Railpen Limited in order to deal with and pay any benefits you may be entitled to under the rules of the Scheme. Where this is necessary we will comply with all aspects
of data protection legislation.
The types of organisations we may need to share some of your data with are:
claimants, beneficiaries, assignees and payees;
pension schemes with which the person whose personal information we are processing has an association;
trade and business associates and professional advisers;
healthcare, social and welfare organisations;
financial organisations and advisers;
central and local government;
service providers;
ombudsmen and regulatory authorities;
suppliers;
family, associates or representatives of the person whose personal data we are processing;
tracing agencies.
If you qualify for free financial counselling we will give your information to carefully selected organisation(s) with which we have arranged to provide this service. We or they may contact you by mail or telephone. If you do not wish to take advantage of this
service, please notify the Data Protection Officer in writing who will forward an acknowledgement to you within 7 days.
Retention of data
One of the key principles of the relevant data protection legislation, including the GDPR, is that the personal data we store and process shall be adequate, relevant and limited to what is necessary for the purpose it was originally collected. Our standard policy is for data to be kept for only as long as necessary. It is then disposed of in a managed and secure way. However, as pensions are a long term saving vehicle it may be necessary to retain your personal data for the remainder of your life and any dependants’
lives in order to pay you the benefits you are entitled to along with any dependant’s benefits payable.
Completing forms on behalf of a child
If you are completing forms on behalf of a child we may also hold and use your personal data, which will be dealt with on the same basis as set out above.
Your rights
You have a number of rights under data protection legislation. These include the right to:
see the information we hold about you;
request personal data to be amended if it is inaccurate or incomplete;
request the deletion or removal of personal data where there is no compelling reason for its continued use;
to block or restrict the processing of your personal data in certain circumstances; and
object to the processing of your personal data in certain circumstances.
There is also a right under the legislation to receive your personal data (in a structured, commonly used and machine-readable format) and to transfer your data to another service provider or data controller. This right applies where your data is being processed
on the basis of your consent or in line with a contract to which you are party.
Further information
If you wish to exercise any of your rights or have concerns about the processing of your personal data or, on behalf of the child in whose name this claim is made, or wish to raise any issues in relation to data protection, including in relation to the use of it by the Trustees or Railpen, please contact the Trustees at:
Address:
Trustees of the BOCM PAULS Pension Scheme
C/o Railpen
PO Box 377
Darlington
DL3 6XY
Telephone: 01325 342801
Email: BOCMPAULS@railpen.com
If you are unhappy with how your personal information is being handled you also have the right to make a complaint to the Information Commissioner’s Office, an independent body set up to uphold information rights, which will investigate your complaint.