GDPR Privacy Notice

Information on the General Data Protection Regulation (GDPR), which was originally introduced on 25 May 2018. Following BREXIT the GDPR is retained in domestic law as the UK GDPR, but the UK has the independence to keep the framework under review. The ‘UK GDPR’ sits alongside an amended version of the DPA 2018. It covers both ESPS and UPP members, as follows:

ESPS members

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

The GDPR, which came into force on 25^th May 2018, was introduced by the European Union (EU) as a way of making data protection rules more consistent across all member states.

The new law applied in all EU countries, not just in the UK, and continues to apply in the UK post-Brexit. The UK GDPR defines how we, and other organisations, are allowed to collect, use and store the Uniper Group members’ personal information. 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 Trustees will use information about you to comply with the new UK GDPR 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. 
  
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. We will handle your data in compliance with all relevant data protection legislation, including the UK General Data Protection Regulation (UK GDPR). The Trustee of the Uniper Group is the data controller in respect of your personal information for the purposes of applicable data protection legislation. 

Purpose of using information
We process information or data for the reasons/ purposes above. This information may include:

• personal details
• family, lifestyle and social circumstances
• financial details
• employment and education details
• goods or services 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.

This information may be obtained from your employer, ex-employer, 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 for our legitimate business interests; or
• you have given us your consent to do so.

Our legitimate business interests 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 business 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 Railpen (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 Railpen 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 payees
• pension 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

Your data is also shared with the Scheme Actuary, Aon, who provide pensions advisory and calculation services to the Trustee of the Uniper Group. 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 dependant’s 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 this claim is made, or wish to raise any issues in relation to data protection, including in relation to the use of it by the Trustees or Railpen, please contact Railpen

Railpen: 
2 Rye Hill Office Park 
Birmingham Road 
Coventry 
CV5 9AB

Tel: 02476 472 544 
Email: enquiries@railpen.com
 
If you are unhappy with how your personal information is being handled, you also have the right to make a complaint to the Information Commissioner’s Office, an independent body set up to uphold information rights, which will investigate your complaint.
 
In addition to the above, the Trustee also uses an external Company as their Scheme Actuary and to provide pensions advisory services and they have asked the Trustee to provide the information, right, 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/retirement-investment/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

As members’ benefits are held by Fidelity, members should log on to Plan Viewer and look for the “Fidelity International / Policy condition 8.1 – Data Protection” statement.

Updated 1^st September 2023