The trustee’s commitment to your privacy
The trustee is committed to protecting and respecting your privacy and rights. This privacy statement (“statement“) gives you information about the trustee, how it will collect and use personal data about you, the circumstances in which it may share or otherwise use the personal data and to whom it may disclose this personal data.
The trustee is a data controller in respect of the personal data it collects about you for the purposes of data protection legislation (by which we mean the current UK Data Protection Act 1998 and the EU General Data Protection Regulation (EU Regulation 2016/679) (GDPR) which comes into effect on 25 May 2018). The trustee’s address is Trustee of the Merchant Navy Ratings Pension Fund, c/o Pi Consulting Trustee Services Limited (PTS), 2nd Floor Tuition House, 27-37 St George’s Road, London SW19 4EU.
In addition to the trustee, the Fund actuary is also a data controller. The Fund actuary is WTW and its privacy notice outlining how it uses personal data to provide actuarial services to the Fund can be found at willistowerswatson.com/personal-data.
Information the Trustee may collect from you
The trustee may collect and process personal data which you provide to it in connection with the Fund. This may include data about your age, date of birth, gender and marital status. Also included may be your length of employment with your employer and details of your dependents and other persons in your household, and your contact details (e.g. residential address, email address and telephone number).
In addition, it may collect, hold and use personal data about you that is of a sensitive nature (“sensitive personal data”), for example medical information about you.
Information the trustee may collect about you from your employer or third parties
The trustee may collect personal data about you from your employer 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 data 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 data
The trustee will process your personal data and the personal data of other persons (for example, your dependants) provided by you to us in connection with the administration of benefits of your pension and related benefit entitlements arising as a result of your employment with your employer.
Generally, the trustee will rely upon the “legitimate interests” ground as the legal basis for processing your personal data. This means that the trustee will process personal data for the legitimate interests of themselves or a third party to whom they may disclose personal data in accordance with this statement. The legitimate interests being the administration of the Fund (provided always that the legitimate interests are not overridden by the interests or fundamental rights or freedoms of Fund members (or others) which may require protection of personal data).
Where the trustee is required to process sensitive personal data, it will approach you or the relevant individuals for specific consent to the processing of such data.
Retention of personal data
The trustee will hold personal data of Fund members and their dependants for as long as may be necessary in order to administer benefit entitlements and for the purposes of maintaining records of steps the trustee has taken to comply with its obligations under the Fund. Inevitably, this means that personal data 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. The end date for holding personal data in respect of a particular beneficiary is expected to be 20 years from the date on which benefits cease to be payable to both that beneficiary and their survivor(s).
Disclosure of personal data
In the course of administering the Fund, the trustee will engage pensions administration service providers, tracing agencies, a scheme actuary, lawyers and accountants and similar external advisors to assist them. The trustee may disclose your personal data to these third parties in connection with services provided by the third parties to the trustee. At all times, the trustee will ensure that the personal data is processed in accordance with their instructions and in circumstances which require the recipient to observe industry standard security measures in respect of the personal data.
The trustee may also disclose your personal information to third parties in the following types of situations:
- in the event that they wish to enter a buy-out/buy-in of any of the benefits under the Fund, in which case they may disclose your personal data to the prospective counterparty to such a transaction
- if they are under a duty to disclose or share your personal data in order to comply with any legal obligation
International transfers of personal data
As required by data protection legislation, the trustee has strict security procedures regarding the storage and disclosure of personal data. The personal data that it collects about you may be transferred to, and stored at, or processed in one or more countries outside the European Economic Area (“EEA”) which has not yet been deemed by the European Commission to offer adequate data protection. It may also be processed by staff operating outside the EEA who work for the Trustee or for our third parties. In such cases, except where the relevant country has been determined by the relevant public authority to ensure an adequate level of data protection, the trustee will ensure that the transferred information is protected, for example by a data transfer agreement in the appropriate standard form approved for this purpose by the European Commission or (where applicable) relevant authority in the United Kingdom. If the trustee cannot ensure such an adequate level of data protection, your personal data will not be transferred outside the EEA.
If you wish to obtain a copy of these safeguards, please contact the Fund’s administrators, Mercer, at the address quoted at the end of this statement or contact them at contact.mercer.com/green requesting a copy of these safeguards.
Automated decision-making
We do not envisage that any decisions will be taken about you using automated means. If this position changes, we will notify you in writing.
Your rights under the EU General Data Protection Regulation
You have rights under the GDPR including:
- the right to access your personal data;
- the right to have your personal data rectified if it is inaccurate or incomplete
- the right to have your personal data deleted or removed if there is no reason for its continued storage and processing
- the right to object to your personal data being processed and to restrict the processing of your personal data in certain circumstances
- where you have provided your consent to the collection, processing and transfer of your personal data for a specific purpose, you have the right to withdraw your consent
You may address your requests to Mercer, please contact them at contact.mercer.com/green with details of your request.
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 we may make to this statement in the future will be notified to you and you are advised to regularly check and review the statement to ensure you understand how we may be processing your personal data. Any changes the trustee may make to this statement (which will, unless otherwise indicated, apply to any personal data 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. Where appropriate, it may also notify you of any changes made by email.
Contact
If you have any questions concerning this statement or the policies or procedures referred to above, please contact the Fund’s administrators, Mercer, at:
| Address: | Merchant Navy Ratings Pension Fund c/o Mercer Limited Maclaren House Talbot Road Stretford Manchester M32 0FP |
Where you are dissatisfied with any aspect of our handling of your personal data you have a right to lodge a complaint with the Information Commissioner’s Office. Their contact details are:
| Address: | Information Commissioner’s Office Wycliffe House Water Lane Wilmslow Cheshire SK9 5AF |
| Tel: | 0303 123 1113 or 01625 545 745 |
| Fax: | 01625 524 510 |
| Email: | casework@ico.org.uk |