< Back
Southern Electric Group of the Electricity Supply Pension Scheme
Personal Information and What We Do With It
As the Group Trustee of the Scheme, we need personal information about you to run the Scheme, pay benefits and to match certain members with their pensions and send information about their pensions to Pensions Dashboards. Because we are, in legal terms, a ‘data controller’ in respect of this information, we need to tell you some things about the personal information we have about you and what your rights are in relation to it. Other parties involved in running the Scheme will sometimes need to make decisions jointly with the Trustee about how your personal information will be used for those purposes. These other parties include the Scheme Actuary (currently Russell Agius FIA of Aon).
In legal terms, the Trustee and the Group Actuary are ‘joint data controllers’ in respect of this information. This means that we need to tell you some things about the personal information we have about you and what your rights are in relation to it.
In this notice, you will see information about what the Trustee does with your personal information.
At the end of this notice is also a brief description of how the Scheme Actuary uses your personal data in order to support us in the running of the Scheme.
We describe who to contact if you wish to exercise your rights under data protection laws in relation to the joint use we make of your information.
Except where stated otherwise, ‘we’ means both the Trustee and the Scheme Actuary where they are acting as joint data controllers in relation to your personal information (as described above).
What Personal Information We Have
We hold some or all of the following types of personal information about you:
- Your name (and previous or alternate names), date of birth, national insurance number (and/or partial or “dummy national insurance number), bank account information (in some cases), and country of residence.
- Your sex/gender (we use this to understand how long you are likely to receive your pension for and as part of your addressee details if we write to you e.g. ‘Mr., Mrs., Ms.’)
- Contact details (including your address (or former address), phone number and email address).
- If your benefits from the Scheme derive from your employment, details of your employer when you were building up benefits in the Scheme, how long you worked for them and your salary from time to time.
- Whether you are married or in a civil partnership and other information we might need to pay any death benefits due in relation to you.
- Any information you have provided about who you would like to receive any benefits due on your death.
- If your benefits from the Scheme form part of a divorce settlement, details of that settlement.
- Electronic “pension identifiers” for pensions dashboards.
We may sometimes use other information about you. This could include information about your health where it is relevant to, for example, early payment of benefits from the Scheme, or details about personal relationships to determine who should receive benefits on your death. We might also, very rarely, have information about criminal convictions and offences where it is relevant to your entitlements under the Scheme.
We also have a legal obligation to carry out due diligence checks in the event of a pension transfer request, which may mean that we are obliged to ask you
for additional information. For instance:
• If you wish to transfer to an occupational pension scheme, we have to request evidence that demonstrates an “employment link”. This could include a letter from your employer confirming your employment, a schedule of contributions, payslips and bank statements (the bank account detail on your payslip might
be different from the bank details we hold for you).
• If you request a transfer to an overseas pension scheme, we are legally obliged to check that you are resident in the same country as that scheme.
This evidence might include utility bills, TV subscriptions, insurance documents relating to your overseas home, address, bank account and credit card statements, evidence of local tax being paid and registration of address with local doctors.
Where We Get Personal Information From
Some of the information we have comes directly from you. We may also get information (such as your salary and length of service) directly from your employer. In addition, SSE Pensions Team, who administers the Scheme on our behalf, may have obtained information from you and passed it to us.
Sometimes we get information from other sources: for example, another scheme if you have transferred benefits from that scheme; government departments such as HMRC and DWP; and publicly accessible sources (e.g. the electoral roll) if we have lost touch with you and we are trying to find you.
If we ask you for other information in the future (for example, about your health), we will explain whether you have a choice about providing it and the consequences for you if you do not do so.
Some of your personal information may be collected indirectly through the pensions dashboards ecosystem (including the identity service, the pension finder service, the consent and authorisation service). Where we obtain personal information from the dashboards ecosystem, or during the process of matching members with their Scheme benefits for dashboards purposes, we may retain that data to help demonstrate how and why we concluded that the person is a member entitled to receive information about their benefits on dashboards and to help us administer the Scheme.
Pensions Dashboards
The government has created a framework for pensions dashboards, designed to help people access information about their pensions online in one place. As part of this, we are required by law to match certain members (who search on dashboards) with their pensions under the Scheme. We must also provide certain pensions information to the dashboards ecosystem (including the identity service, the pension finder service, the consent and authorisation service) so that it can be displayed when certain members ask to see it on a dashboard.
These activities may involve sharing member data with entities within the dashboards ecosystem, noncommercial dashboards and commercial dashboards and with the provider(s)/the integrated service provider(s)/administrator we appoint to help us in connecting to dashboards, matching people with their pensions and complying with our other dashboards duties. As part of these dashboards duties, we may also need to report information (which could potentially include personal information) to other bodies including the
Money and Pensions Service, the Pensions Regulator and the Financial Conduct Authority.
Our Legal Basis for Using Your Personal Information, Including How We Share It
The Trustee must by law provide benefits in accordance with the Scheme’s governing documentation and must also meet other legal requirements in relation to the running of the Scheme.
We will use your personal information to comply with these legal obligations, to establish and defend our legal rights, and to prevent and detect crimes such as fraud. We may need to share your personal information with other people for this reason, such as courts and law enforcement agencies.
Pensions dashboards regulations impose a legal obligation on us to match certain members with their pensions and provide information on their pension benefits. Testing data and getting ready for pensions dashboards compliance can also be part of our legal obligations.
We also have a legitimate interest in properly administering the Scheme. This includes: paying benefits as they fall due; purchasing insurance contracts; communicating with you, testing data and getting ready for pensions dashboards compliance can also be part of our legitimate interests; and ensuring that correct levels of contributions are paid, benefits are correctly calculated and the expected standards of Scheme governance are met (including standards set
out in Pensions Regulator guidance).
In order to achieve this, we may share your personal information with various people as necessary, including: any new trustee directors; employers; the SSE Pensions Team as administrator; the Scheme Actuary; our professional advisers; auditors; lawyers; insurers; HMRC; AVC providers the Pensions Ombudsman; the Pensions Regulator, the Information Commission, IT and data storage providers; print and design companies and other service providers, such as
printers who help us prepare communications which we send to members, and tracking and tracing services and integrated service providers (relevant to pensions dashboards compliance, as described above), pensions dashboards ecosystem (as described above), non-commercial dashboards and commercial dashboards.
If your benefits are transferred to another scheme, we will also need to provide the administrators of that scheme with information about you. When we need to use information about your health (or other very personal information), we may ask for your consent. However, sometimes there may be reasons of public interest or law which enable us to use this information about your health (or other very personal information, such as details about personal relationships relevant to who should receive benefits on your death) without consent, and we will do so where that is necessary for us to run the Scheme in a sensible way. You can withdraw your consent at any time by contacting us using the contact details given below.
This may affect what we can do for you, unless we have another lawful reason for using your information. For example, if you apply for ill health early retirement and consent to us processing your health data for that, but then you withdraw that consent, we will usually be unable to consider your application. If you withdraw consent after our processing, this will not retrospectively affect the processing that has already happened.
Sometimes we need to use your personal data, including special categories of personal data, in order to establish, exercise or defend legal claims. We may also share your personal information with someone else where you have given your consent – for example, where you transfer your benefits out of the Scheme.
The Scheme’s employers may also have a legitimate interest in contacting you about your benefits under the Scheme, and any additional options which may be
available to you in relation to those benefits. In such circumstances, we may share your personal information with the employers so that they can contact you for that purpose.
Sometimes, your information may be used for statistical research, (e.g. to monitor the mortality experience of the Scheme) but only in a form that does not personally identify you.
How to Contact the Other People We Give Your Personal Information to
Some of the people we mention above just use your personal information in the way we tell them. However, others may make their own decisions about the way they use this information to perform their services or functions, or to comply with regulatory responsibilities as data controllers in their own right. In this case, they are subject to the same legal obligations as us in relation to this information, and the rights you have in relation to your information apply to them too.
If you want any more information from the Pensions Team or any of these recipients or to exercise any rights in relation to the information they hold, please contact us and we will put them in touch with you.
How Long We Keep Your Personal Information For
We need to keep some of your personal information long enough to make sure that we can satisfy our legal obligations in relation to the Scheme and pay any benefits due to or in respect of you.
We keep your information for long enough to ensure that, if a query arises in the future about your benefits; we have enough information to deal with it where we
have a legal obligation to do so (including if your data originated from the pensions dashboards ecosystem and if you were matched up with the Scheme through that). To meet this aim, the majority of the personal information that we hold will be kept for a period of 75 years from the end of the Scheme year in which the last payment from the Scheme is made to or in respect of you.
However, some information may be kept for a longer or shorter period depending on how long we sensibly think we need it to deal with queries (from you or your beneficiaries/other persons who might ask us if they are entitled to payments), complaints (from you or them), and our legal obligations mentioned above.
Data from the pensions dashboards ecosystem is kept for the life of the member record, if we do find a match (i.e. if you are a member of the Scheme).
If we don’t find a match (i.e. if you are not a member of the Scheme), we will have the Scheme administrator delete the data from the dashboard straightaway.
If we find a potential match, we will keep the data from the dashboard for 30 days in a hash/token form (which helps with security of it) so that we have more time to determine whether there’s a match or not. We will delete it after 30 days if there is no match, or keep it for the life of the member record if we do find a match.
Your Rights in Relation to Your Personal Information
You have rights in relation to the personal information we have about you. You have the right to:
- make a request to have your personal information corrected if it is inaccurate, and completed if it is incomplete;
- in particular circumstances, restrict the processing of your information;
- in particular circumstances, ask to have your information erased;
- request access to your information and to obtain information about how we process it;
- in particular circumstances, move, copy or transfer your information;
- in particular circumstances, object to us processing your information; and
- make a complaint to us if you think there has been an infringement of data protection laws.
You can exercise all of these rights free of charge except in some very limited circumstances, and we will explain these to you where they are relevant.
The Pensions Team’s contact details for exercising these rights are set out below and they can supply more information about these rights to you on request.
Keeping Your Information Safe
When we pass your information to a third party, we seek to ensure that they have appropriate security measures in place to keep your information safe and to comply with general principles in relation to data protection.
Some of the people we share your information with may process it overseas. This means that your personal information may on occasion be transferred outside the UK. Some countries already provide adequate legal protection for your personal information, but in other countries, additional steps will need to be taken to protect it.
You can contact us for more information about the safeguards we use to ensure that your personal information is adequately protected in these circumstances (including how to obtain copies of this information).
Queries and Further Information
If you want more information about what we do with your information and what your rights are, the Trustee can be contacted at:
Pensions Team
SSE plc
200 Dunkeld Road
Perth
PH1 3AQ
Email: pensions-se@sse.com
Telephone: 0345 071 9622
If you have concerns about the way we handle your personal data, you can contact the Information Commissioner’s Office or raise a complaint at www.ico.org.uk/concerns, or call its helpline on 0303 123 1113.
Privacy Notice from the Scheme Actuary
Aon (and, where appointed, the Group 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 we 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 makeup 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.
We may pass your personal information to third parties such as financial advisors and benefits providers, insurers, our 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.
More detail about Aon’s use of your personal information is set out in our full Privacy Notice. We recommend that you review this notice which is available at https://www.aon.com/unitedkingdom/retirement-investment/retirement-investment-services-privacy-statement.jsp , or you can request a copy by contacting contact us, including reference to the scheme name, at:
Data Protection Officer
Aon Hewitt Limited (Retirement and Investment UK)
PO Box 730
Redhill
RH1 9FH