Privacy

ESPS members and beneficiaries, including RBP 

The Trustee wants to tell you about how the UK GDPR affects you as a member of the Uniper Group of the Electricity Supply Pension Scheme (the Uniper Group).

The UK GDPR defines how we, and other organisations, are allowed to collect, use and store the Uniper Group members’ and beneficiaries' personal information (including information about potential beneficiaries, such as family members). It not only covers anything that identifies you directly, but pieces of data that can be put together to paint a picture of who you are.

The UK GDPR means we have to make sure that we collect, use and store data so that it complies with the new high standards.

The following is how the Trustee will use information about you

The Trustee of the Uniper Group is the data controller in respect of your personal information for the purposes of applicable data protection legislation.

We, the Trustee of the Uniper Group, will use your personal details to assess, deal with and pay any benefits you may be entitled to under the rules of the Uniper Group, and to provide you with information about such benefits (including, if applicable, via a Pensions Dashboard).

As part of the service we provide, we may share your information with other organisations for the purposes of identifying accurate information as to your whereabouts or for the purpose of paying any benefits that you may be entitled to, where you have requested that we share your information or as otherwise described below.

Purpose of using information and types of data processed

• personal details
• family, lifestyle and social circumstances
• financial details
• employment and education details
• goods or services provided
•  benefit entitlements or records of benefits provided

We may also need to process sensitive classes of information, such as physical or mental health details, in order to administer ill-health retirement payments and applications. Any sensitive personal data will be processed (including shared with any other party) only with your consent. 

This information may be obtained from your employer, ex-employers, government agencies, service providers or from yourself. 

We will only collect and use your personal information where:

• there is a legal obligation for us to do so;
• it is necessary to protect your interests and/or it is in the legitimate interests of the Trustee to use your information in that way; or
• you have given us your consent to do so.

The purposes for which we will collect and use your personal information include fulfilling our role in dealing with, assessing eligibility for, and paying any benefits you may be entitled to. We will not use your data for our legitimate interests if they are overridden by your interests, rights or freedoms.

 You do not have to provide the information requested from you, but there may be a delay in the payment of your benefits if that information is not provided.

If we are processing your data on the basis of your consent, you can withdraw your consent at any time by contacting Broadstone (details shown under ‘Further information’). The withdrawal of consent will not affect the processing of personal data carried out before consent was withdrawn.

Who the information may be shared with

From time to time, we may need to share your information with other organisations. Where this is necessary, we are required to comply with all aspects of relevant data protection legislation.

Your information will be shared with Broadstone in order for them to provide pension administration services in line with the reasons/purposes outlined earlier.

The types of other organisations we may need to share some of your information with are:

• claimants, beneficiaries, assignees and payeespension schemes with which the person whose personal information we are processing has an association
• trade and business associates and professional advisers
• healthcare, social and welfare organisations
• financial organisations and advisers
• central and local government
• service providers
• ombudsmen and regulatory authorities
• suppliers
• family, associates or representatives of the person whose personal data we are processing
• tracing agencies
• insurers

Your data is also shared with the Scheme Actuary, Aon, who provide pensions advisory and calculation services to the Trustee of the Uniper Group.

If you use a Pensions Dashboard to locate and view information about your UK pensions, your data will be shared with the dashboard provider, but this information will only be visible to you (and any advisor you authorise to access such dashboard).

Further information regarding their privacy policy is detailed at the end of this notice

Retention of data

One of the key principles of the relevant data protection legislation, including the UK GDPR, is that the personal data we store and process shall be adequate, relevant and limited to what is necessary for the purpose it was originally collected. Our standard policy is for information or data to be kept for only as long as necessary. It is then disposed of in a managed and secure way.

However, as pensions are a long-term saving vehicle, it may be necessary to retain your personal data for the remainder of your life and any dependants’ lives in order to pay you the benefits you are entitled to, along with any dependants’ benefits payable.

Our core systems, data, and administration services are all carried out and stored within the UK

Completing forms on behalf of a child

If you are completing forms on behalf of a child, we may also hold and use your personal information, which will be dealt with on the same basis as set out above. 

Your rights

You will have a number of rights under data protection legislation. These include the right to:

• see the information we hold about you;
• request personal data to be amended if it is inaccurate or incomplete;
• request the deletion or removal of personal data where there is no compelling reason for its continued use;
• block or restrict the processing of your personal data in certain circumstances; and
• object to the processing of your personal data in certain circumstances

There is also a right under the UK GDPR to receive your personal data (in a structured, commonly used and machine-readable format) and to transfer your data to another service provider or data controller. This right applies where your data is being processed on the basis of your consent or in line with a contract to which you are party. Please note that for the majority of members, this is not applicable as we rely on our legitimate business interest to collect and process your data rather than individual consent or contracts.

Further information

If you wish to exercise any of your rights or have concerns about the processing of your personal data, or on behalf of the child in whose name a claim is made, or wish to raise any issues in relation to data protection, including in relation to the use of it by the Trustee or Broadstone, please contact the Trustee through Muse Advisory at the following address.

Muse Advisory Ltd:     
KD Tower, Suite 10
The Cotterells
Hemel Hempstead
HP1 1FW

T: 020 3740 0111
[email protected]

If you are unhappy with how your personal information is being handled, you also have the right to make a complaint to the Trustee, by contacting Muse Advisory, via the contact details above. Please ensure you specify that your complaint relates to Data Protection and set out all relevant details in relation to your complaint, so that the Trustee can properly consider it. If you remain unhappy with how we have answered your complaint, you can make a complaint to the Information Commissioner’s Office (ICO), an independent body set up to uphold information rights, which will investigate your complaint. Please go to the ICO's website: Make a complaint about how an organisation has used your personal information | ICO. Please note that you can only make a complaint to the ICO if you have first complained to the Trustee.

In addition to the above, the Trustee also uses an external company as their Scheme Actuary and to provide pensions advisory services. They have asked the Trustee to provide the information given below in relation to their involvement.

Aon Solutions UK Limited (and, where appointed, the Scheme 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 make-up 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 online at https://aon.com/unitedkingdom/retirementinvestment/retirement-investment-services-privacy-statement.jsp, or you can request a copy by contacting us, including reference to the scheme name, at: Data Protection Officer, Aon Solutions UK Limited (Retirement and Investment UK), PO Box 730, Redhill, RH1 9FH

Reviewed: July 2026