The LRSFA is an occupational pension scheme registered with HMRC. This privacy notice sets out how as the Trustee of the LRSFA we collect and process personal information about members and their survivors. It also explains how we use and protect this information and your rights in relation to it.
Personal information is information, or a combination of pieces of information, that could allow you to be identified.
1. PERSONAL INFORMATION WE HOLD
We hold or will collect personal information about you from a variety of sources, including information from you directly, information provided by the Lloyd's Register group employers and information we obtain from other sources, including public databases.
Without this information we would be unable to calculate and pay your LRSFA benefits.
1.1 The categories of personal information that we may hold or collect about you include:
(a) personal details (e.g. name, date of birth, bank details and national insurance number);
(b) contact details (e.g. address, phone number and email address);
(c) details necessary to calculate and pay benefits (eg, your employment history and salary);
(d) details about whom you would like us to consider paying benefits to following your death;
(e) your choice of contribution rate; and
(f) any choice of fund for your contributions to be paid into.
1.2 What information may we collect from other sources (such as Lloyd's Register)?
We may collect information from other sources, including:
(a) personal details (for example, your name, date of birth);
(b) your contact details (for example, your address, phone number and email address):
(c) information necessary to calculate and pay your contributions or benefits (for example, your employment history and salary); and
(d) information from HMRC (for example your tax code).
2. HOW WE USE YOUR PERSONAL INFORMATION AND THE BASIS ON WHICH WE USE IT
2.1 We have a legitimate interest to use personal information to administer the LRSFA efficiently and to fulfill our obligations. The ways we use the information include:
(a) communicating with you and calculating and paying benefits;
(b) making trustee decisions – such as whether to agree to early retirement, ill health retirement or how to distribute benefits after your death;
(c) identifying you as a member and your survivors;
(d) making sure benefits are paid correctly.
2.2 We encourage you to update your information if it changes or if you think the personal information we hold about you is out of date.
3. INFORMATION SHARING
3.1 We need to share personal information with:
(a) the LRSFA's administrators and our advisers (such as the Scheme Actuary) so that they can perform their functions, as well as any sub-contractors appointed by them;
(b) Her Majesty's Revenue and Customs (HMRC) and other Government organisations, including potentially the Pensions Regulator and the Pension Protection Fund; and
(c) the LRSFA's bank.
3.2 We may also be asked to provide some of your personal information to Lloyd's Register employer group companies to help them to make decisions relevant to their role as sponsoring employers, but we will only do so to the extent necessary for these purposes.
4. SECURITY AND STORAGE
We have in place measures to protect the security of your personal information and keep it confidential. We review these measures regularly to make sure they remain appropriate.
When sharing your personal information with our administrators or another third party we will make sure that they also have measures in place to protect it and keep it confidential and agree to use the personal information only for the purposes we set out.
We decide how long to keep your personal information after our relationship with you and your survivors has ended by taking account of our obligations and regulators' guidance. We may also keep information to investigate queries.
5. YOUR RIGHTS
You have rights regarding your personal information, including the right in certain circumstances to access, correct, delete or transfer your personal information or to restrict or object to our use of it. We may need extra information from you to deal with any request.
6. INTERNATIONAL DATA TRANSFER
Your personal information may be transferred to, stored, and processed in countries outside of the UK, and in some cases this may be to a country that is not recognised under European Union law as providing the same level of protection that would be provided within the European Union. Where your personal information is to be transferred outside the UK (for example by the administrator) we will always make sure that there are appropriate safeguards in place in accordance with all of the applicable legal requirements in order to ensure your personal information is protected. For more information on any safeguards in place, please contact us.
7. CHANGES TO THIS POLICY
We may update this privacy notice from time to time. You will be able to see when we last updated the notice because we will include a revision date. Updates are effective from the date on which they are notified to members.
8. HOW TO CONTACT US
Lloyd's Register Superannuation Trustees Limited is the "data controller" responsible for the collection and processing of personal information.
If you have questions or concerns about this policy please contact the LRSFA's telephone information line on 020 7423 2807, or alternatively please send an email to firstname.lastname@example.org
If you believe that we have not resolved your concerns, you can complain to the Information Commissioner's Office at www.ico.org.uk or write to them at their postal address: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.
9. OTHER DATA CONTROLLERS
David Jones of Lane Clark & Peacock LLP as the Scheme Actuary is also a data controller in relation to your personal information.
A privacy notice setting out how Lane Clark & Peacock LLP will use and protect your personal information can be found at here. If you would like a hard copy of that notice, please contact us.
Other web sites
Our website may contain links to other websites which are outside our control and are not covered by this privacy statement.
You have the right to access personal data that is held about you. To obtain a copy of the personal information we hold about you please write to the address given below.
The Data Protection Officer,
71 Fenchurch Street,
London EC3M 4BS,
T: +44 (0)20 7423 1724