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Data Privacy Statement
Trustee’s commitment to your privacy
The Trustee of the Prudential Staff Pension Scheme is committed to protecting and respecting your privacy and rights. This Privacy Statement (Statement) gives you information about the Trustee, how the Trustee will collect and use personal information about you, the circumstances in which the Trustee may share or otherwise use the personal information and to whom the Trustee may disclose this personal information.
The Trustee is the data controller in respect of the personal information that is collected about you for the purposes of data protection legislation (by which we mean the current UK Data Protection Act 2018 and the EU General Data Protection Regulation (EU Regulation 2016/679) as it forms part of the laws of England and Wales (UK GDPR).
The Trustee’s address is:
Prudential Staff Pension Scheme, 10 Fenchurch Avenue, London, EC3M 5AG
Information the Trustee may collect from you
The Trustee may collect and process personal information which you provide in connection with the Scheme. This may include information about your age, date of birth, gender and marital status. Also included may be your length of employment with the Company and details of your Dependants and other persons in your household, and your contact details (e.g. residential address, email address and telephone number).
In addition, the Trustee may collect, hold and use the following categories of personal information about you that are of a sensitive nature (Sensitive Personal Data):
- Racial or ethnic origin;
- Physical or mental health or condition or sexual orientation;
- Religious or similar beliefs;
- The commission or alleged commission by you of any offence; or
- Any proceedings for any offence committed or alleged to have been committed by you and the disposal of such proceedings or the sentence of any court in such proceedings.
To check what personal information the Trustee holds about you, visit the secure area of the Scheme website.
Information the Trustee may collect about you from the Company or third parties
The Trustee may collect personal information about you from the Company or third parties. This may include information relating to your employment, your salary and your benefits, to the extent relevant to your pension and related arrangements. Periodically, the Trustee may collect personal information relating to you from third parties such as former employers or regulatory authorities.
Purposes for which and the basis upon which the Trustee will process your personal information
The Trustee will process your personal information and the personal information of other persons (e.g. your Dependants) provided by you to the Trustee in connection with the administration of pension and related benefit entitlements arising as a result of your employment with the Company.
Generally, the Trustee will rely upon the “legitimate interests” ground as the legal basis for processing your personal information. This means that the Trustee will process personal information for the legitimate interests of itself or a third party to whom the Trustee may disclose personal information in accordance with this Statement. The legitimate interests being the administration of the Scheme (provided always that the legitimate interests are not overridden by the interests or fundamental rights or freedoms of Scheme members (or others) which may require the protection of personal information).
Where the Trustee is required to process Sensitive Personal Data they will approach you or the relevant individuals for specific consent to the processing of such information.
Retention of personal information
The Trustee will hold personal information of Scheme members and their Dependants for as long as may be necessary in order to fulfil the purposes for which it was collected.
- The Trustee may indirectly learn about your racial or ethnic origin from documents you submit to prove your identity. Documentation to provide your identity will be stored until such time as the Trustee can confirm that no further liabilities are payable from the Scheme as a result of your membership;
- The Trustee may indirectly learn about your personal life from the Dependants you advise on an Expression of Wish Form. Only the current Form is kept and again this will be stored until such time as the Trustee can confirm that no further liabilities are payable from the Scheme as a result of your membership; and
- For Deferred members only: The Trustee may request details of your medical history to support an application for early payment of pension on the grounds of ill health. This information will be confidentially destroyed once the Scheme’s Medical Adviser has confirmed if you are eligible for early retirement on the grounds of ill health.
Personal information is collected to administer benefit entitlements and for the purposes of maintaining records of steps the Trustee has taken to comply with its obligations under the Scheme. Inevitably, this means that personal information may be retained by the Trustee for extremely long periods of time, including after entitlement to receive benefits by an individual and/or their beneficiaries has ceased.
Should you require details of the retention periods for the different aspects of your personal information, please contact the Pensions Manager, at the address shown in the contact section below.
In determining the appropriate retention period, the Trustee will take into consideration statutory requirements and industry guidelines, the nature and sensitivity of the personal information, the purposes for which it was collected, how the information is stored and the potential risk from unauthorised use or disclosure of personal information.
Disclosure of personal information
In the course of administering the Scheme, the Trustee will use the services of the Scheme’s Administrator, Legal, Actuarial, Communications, Medical Advisers, the Auditor, tracing agencies, insurers, reinsurers and other similar external service providers or advisers.
The Trustee may disclose your personal information to these third parties in connection with services provided by the third parties to the Trustee. The Trustee may also share some of your personal information with the Company. At all times, the Trustee will ensure that the personal information is processed in accordance with its instructions and in circumstances which require the recipient to observe industry standard security measures in respect of the personal information.
The Trustee may also disclose your personal information to third parties in the following types of situations:
- In the event that the Trustee wishes to effect an insurance policy, or a buy-out/ buy-in of any of the benefits under the Scheme, in which case it may disclose your personal information to the prospective insurer or counterparty (and its prospective reinsurer(s)) to such a transaction and to service providers or advisers instructed in connection with such a transaction; or
- If the Trustee is under a duty to disclose or share your personal information in order to comply with any legal obligation.
International transfers of personal information
As required by data protection legislation, the Trustee has strict security procedures regarding the storage and disclosure of personal information. The personal information that is collected about you may be transferred to, and stored at, or processed in one or more countries outside the UK which have not yet been deemed by the UK Government to offer adequate data protection. It may also be processed by staff operating outside the UK who work for the Trustee or for the Trustee’s third parties. In such cases, the Trustee will take steps to ensure an adequate level of data protection in the country of the recipient as required under the UK GDPR and as described above under retention of personal information. If the Trustee decides that personal information does need to be transferred to a country outside the UK which does not offer adequate protection, the Trustee will notify you in writing and ensure that appropriate technical and organisational measures are put in place so that such processing meets the requirements of the data protection legislation. We may safeguard such transfers through the use of Standard Contractual Clauses or International Data Transfer Agreements which have been approved for this purpose in accordance with Article 46(2)(c) or (d) of the UK GDPR. If you wish to obtain a copy of these Standard Contractual Clauses, please contact the Pensions Manager, at the address shown below.
If there were circumstances where the Trustee could not ensure such an adequate level of data protection, your personal information will not be transferred outside the UK.
The Scheme’s advisers and service providers (including insurers and reinsurers) may hold and process your personal information when providing services to the Scheme. A list of these advisers and service providers (including insurers and reinsurers) and links to their Privacy Statements can be found on the Scheme’s website or obtained by writing to the Pensions Manager.
Automated decision making
The Trustee does not envisage that any decisions will take place about using your personal information using automated means. In the event that this position changes, the Trustee will notify you in writing.
You have rights under the UK GDPR including:
- The right to access your personal information;
- The right to have your personal information rectified if it is inaccurate or incomplete;
- The right to have your personal information deleted or removed if there is no reason for its continued storage and processing;
- The right to object to your personal information being processed and to restrict the processing of your personal information in certain circumstances;
- The right to request the transfer of your personal information to another party; and
- Where you have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent.
Any such requests should be sent to the Pensions Manager, in the contact section below.
Changes to this Statement
The Trustee reserves the right to change this Statement and any other relevant policies or procedures at any time without notice to you. Any changes the Trustee may make to this Statement in the future will be notified to you and posted on the Scheme’s website and you are advised to regularly check and review the Statement to ensure you understand how the Trustee may be processing your personal information. Any changes the Trustee may make to this Statement (which will, unless otherwise indicated, apply to any personal information already obtained by the Trustee before the changes were made) will be effective from the date on which those changes have been notified to you or posted on the Scheme’s website. Where appropriate, the Trustee may also notify you of any changes by email.
If you have any questions concerning this Statement or the policies or procedures referred to within it, please contact the Pensions Manager, at the address below.
Write to: Prudential Staff Pension Scheme, 10 Fenchurch Avenue, London, EC3M 5AG
If you are dissatisfied with any aspect of the Scheme’s handling of your personal information, you have a right to lodge a complaint with the Information Commissioner’s Office. Their contact details are:
Telephone: 0303 123 1113
Fax: 01625 524 510
Write to: Information Commissioner’s Office Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF
For general enquiries, including matters relating to accessing MyPension, the secure area of the Scheme website, please contact the Administration Team:
Telephone: 01245 673515 (UK callers) (44) 1245 673515 (Overseas callers)
Write to: Prudential Staff Pension Scheme, XPS Administration, Priory Place, New London Road, Chelmsford CM2 0PP
As noted above, the Scheme’s advisers hold and process your personal information when providing services to the Scheme. A list of these advisers and links to their Privacy Statements can be found below:
Willis Towers Watson – Actuarial adviser
Definitions used in this Statement
The Trustee of the Prudential Staff Pension Scheme is Prudential Staff Pensions Limited.
Company means The Prudential Assurance Company Limited or any associated company / employer that offers you membership of the Scheme through your contract of employment.
Whilst we make every effort to ensure that this site is kept up to date, please note that the information available may be incomplete, out of date or incorrect. It is therefore essential that you verify any information with us before taking any action in reliance upon it. It is a condition of us allowing free access to the material on this site that the Company and the Trustee will not be liable for any action you take in reliance on the information on this site. You should always refer to current, printed documents which are available from the Administrators shown on the ‘Contact’ section of the site.