Protecting your data
TRW Pensions Trust Limited, as the Trustee of the Plan (the “Trustee” or “we” or “us”), collects and uses your personal information in order to administer the Plan and to pay benefits due to Plan members and other beneficiaries.
We are committed to protecting your personal information and processing it responsibly. This statement tells you more about when, from whom and why we collect your personal information and how we use it.
The Trustee is the data controller of the personal information to which this note relates; the Trustee can be contacted using the details in Section 10.
The types of personal information that we may collect and use include:
- Your full name, address and contact details
- Your date of birth
- Your sex/gender
- Your marital (or relationship) status
- Your benefit entitlement under the Plan
- Information about your health
- National Insurance Number and/or other evidence of identity
- Details of your salary and other forms of remuneration
- Details of your bank account
- Details of any nominees to be considered for benefits in the event of your death
Most of the personal information that we hold about you is provided by you when you join the Plan or when you contact the Trustee (or organisations appointed by the Trustee to help with the running of the Plan) about your benefits.
Other information about you may be provided by current and former employers participating in the Plan, other pension schemes and pension providers, independent financial advisers, medical practitioners, other advisers or service providers to the Trustee and Her Majesty's Revenue and Customs (HMRC).
The legal basis for us using your personal information is to enable us to comply with our legal obligations as trustee of the Plan, which include paying benefits to you and other beneficiaries in connection with your employment (or previous employment) with an employer participating in the Plan. We also have a legitimate interest in using your personal information to ensure the efficient administration of the Plan and to help us and the employers participating in the Plan review and manage financial matters relating to the Plan, together with our respective advisers.
In some limited circumstances, the Trustee will only collect and use certain special categories of personal information with your express consent (for example, medical and health information). We will make clear to you when your consent is needed.
If we are not provided with the personal information about you that we need, it may not be possible for us to provide some or all of the benefits otherwise payable in respect of you from the Plan.
Where the Trustee considers it necessary for the purposes explained in section 4 above, your personal information may be shared with selected third parties, such as the Trustee's actuarial and financial advisers and other professional services providers, including those who provide data processing, administration, storage, risk management and communication services to the Plan. The Trustee may also share personal information with regulatory authorities and medical advisers, insurers, additional voluntary contribution (AVC) providers, financial advisers, annuity brokers, employers participating in the Plan, HMRC, the Pensions Regulator and any other third parties with whom we are authorised or required by law to share personal information.
Some of the third parties with whom your personal information is shared may be located outside the European Economic Area (EEA) (for example, this may happen if computer servers used by our providers are located or backed up in a country outside the EEA).
Under data protection legislation, we can allow your personal information to be transferred outside the EEA if:
- the country to which your personal information is being transferred has been confirmed by the European Commission to provide adequate protection for personal information; or
- the entity that is holding your personal information has entered into a written contract which requires it to provide all protections to your personal information required by data protection legislation.
In the event that the UK is no longer part of the EEA, references in this section to the "EEA" should be taken to mean the EEA and the UK.
Further information about transfers of personal data outside the EEA can be obtained by contacting us at the address in Section 10.
We will also share personal information with the actuary to the Plan. The actuary to the Plan is a joint data controller with the Trustee when using personal information held in respect of you for the purposes of assessing, with the Trustee, financial matters affecting the Plan. The current actuary to the Plan is Richard Shackleton of Hymans Robertson LLP whose address is One London Wall, London, EC2Y 5EA.
The Trustee will keep your personal information in accordance with our data retention policy as it applies from time to time. We will need to keep personal information for as long as is reasonably necessary to determine members' entitlement to benefits from the Plan and to comply with our legal obligations in relation to the administration of the Plan.
Data protection legislation gives individuals the following rights in relation to personal information held about them:
- individuals can ask what personal information is held about them and be provided with a copy;
- if personal information held about an individual is incorrect, he or she can ask for it to be corrected;
- individuals can ask for personal information about them to be deleted or for processing of that personal information to cease in certain circumstances, for example, where that information is no longer needed;
- individuals can request that certain types of personal information held about them is sent to them, or another organisation, in a format that can be read by computer; and
- individuals can withdraw their consent to how their personal information is being processed, where that processing is based on their consent.
Exercising these rights is subject to certain restrictions under data protection legislation. For further information about these rights, you can write to us using the details in Section 10.
If you are unhappy at any stage with how the Trustee is using your personal information, you have the right to lodge a complaint with The Information Commissioner's Office.
This policy is subject to regular review and may be updated from time to time. We will tell you if we make any changes to how we use your personal information.
If you have any questions about how your personal information is used, including in relation to the arrangements we have in place with the Plan actuary, please feel free to contact us at the following address: ZF UK Pension Plan, ZF, Stratford Road, Shirley, Solihull, B90 4GW.