First Actuarial’s Privacy Notice for pension scheme members
This notice applies to members of pension schemes to which First Actuarial is providing Investment Advice, Actuarial Services and/or Scheme Actuary Services.
Purpose of this notice
As a member of a pension scheme your personal data is used by a number of organisations.
The trustees of your pension scheme will explain in their privacy notice how your personal data is used. In many cases, the privacy notice given to you by your pension scheme’s trustees will also explain how the Scheme Actuary and First Actuarial use your personal data in helping the trustees to run your scheme.
This privacy notice is issued by First Actuarial. If the Scheme Actuary for your pension scheme works for First Actuarial, it also covers the Scheme Actuary. If your Scheme Actuary works for another firm, this notice does not cover your Scheme Actuary.
This privacy notice gives you information on how we collect and process information regarding your membership of your pension scheme.
It is important that you read this notice together with any other privacy notice we or the trustees may provide, so that you are fully aware of how and why we are using your data. This privacy notice supplements any other notices we have issued.
We may update this privacy notice from time to time.
The Scheme Actuary and First Actuarial will act as joint data controllers for your personal data. We may also be joint data controllers with the trustees of your scheme, depending upon the type of work we are doing at the time.
The trustees of the scheme will let you know the name of the Scheme Actuary.
What personal data do we hold and how do we use it?
The information we hold on you may include:
- details of your employment history, including salary information
- personal information including name, maiden name, date of birth, National Insurance number and contact details
- records of any benefits you have transferred into the scheme from other pension arrangements
- records of any additional contributions you or the employer, on your behalf, have paid into the scheme
- information on benefits you will receive from the scheme
- other more specific information if required for the scheme you are a member of.
We only hold your personal data because we need it to help the trustees run the scheme and comply with pension scheme regulations. Actuarial work involves giving the trustees advice about things like:
- how much money the scheme needs to provide all the benefits promised to scheme members (this an “actuarial valuation”)
- financial and risk modelling about the scheme to help the trustees decide on what investments to hold
- reporting to the Pensions Regulator, HMRC and other authorities as required by law or guidance
- calculating transfer values for scheme members who want to move their benefits to another pension arrangement
- helping to advise the trustees about making changes to the scheme benefits or decisions to do with insuring members’ benefits
- advising the trustees about the actuarial factors used in running the scheme, such as deciding how to change a pension into a tax-free lump sum when a member retires.
Why do we hold this information?
The lawful reason we hold this data is because we have a legitimate interest in providing actuarial advice and valuations to the trustees of your pension scheme.
Where did we get information about you?
The personal data we hold about you was given to us by the trustees of your pension scheme.
Who do we share your information with?
We may share your personal data with other parties if this is necessary for the running of the scheme. Where we do share information with these parties we remain in control of the data and we will ensure that suitable data protection agreements are in place.
We may transfer your data to separate third parties. These parties are:
- official organisations to whom we have a legal obligation to provide information. This includes the Pensions Regulator and HMRC
- insurance companies, for example, if the trustees ask us to buy an annuity on your behalf.
We only share information about you where it is necessary to enable us to advise the trustees of the scheme. We do not share information about you for any other reason.
First Actuarial will not transfer data outside of the European Union unless authorised by the trustees of the scheme or you have agreed to such a transfer.
How long do we keep your data?
We will keep information about you while we provide services to the trustees of the scheme. If the trustees no longer require our services we will keep a copy of the data for a minimum of one year and a maximum of seven years. We will always store your data securely, as required by data protection laws.
You may ask for a copy of the information we hold on you. You may make this request by contacting us.
If, at any point, you believe the information we hold on you is wrong, you can ask us to correct it.
In some circumstances, you may also have a right to ask us to restrict the processing of your personal data, to object to processing or to transfer or erase your personal data. You can obtain further information about these rights from the Information Commissioner’s Office at: www.ico.org.uk or via their telephone helpline (0303 123 1113).
If you wish to raise a complaint on how your personal data is handled, you may want to contact the trustees of the scheme, as they appointed us and are in overall charge of the scheme.
You may also raise a complaint on how we handle your personal data by contacting us. If you are not satisfied with our response or believe the way we are processing your personal data is not in accordance with the law you can complain to the Information Commissioner’s Office.
Keep information up to date
It is important that the information we hold about you is accurate and current. If you are aware that the information we hold is incorrect please let us know.
If you need to update your information (for example due to a change of address) this should normally be done by contacting the scheme trustees or their administrators.
You may contact us for further details on how we use your personal information, or with any other questions about this privacy notice, including any requests to exercise your rights.Data Protection
First Actuarial LLP