The General Data Protection Regulation (GDPR) requires organisations to be more transparent and accountable to individuals about how it manages and controls their data. The Privacy Notices, set out how Peninsula Pensions manages its members’ data, including who it shares data with and for what purpose it might be used.
The pension schemes that we administer and Privacy Notices are on links below:
Avon & Somerset Police Pension Schemes – Peninsula Pensions act as the ‘Data Processor’ – Avon & Somerset Police are the ‘Data Controller’
DATA CONTROLLER: Determines the purposes for which and the manner in which personal data is processed, in order to run the scheme
DATA PROCESSOR: Processes the data on behalf of the data controller
We hold personal information about individuals so that it can provide the pension services to members and employers.
Peninsula Pensions has a legal obligation and a statutory duty to provide individuals with certain information under a number of regulations, including:
All schemes administered:
Local Government Pension Scheme – The LGPS Regulations 2013
Firefighter Pension Schemes – The Firefighter Pension Scheme Regulations 1992 /2006 / 2015
Police Pension Schemes – The Police Pension Scheme Regulations 1987 / 2006 / 2015
Under these Regulations, we have a legal requirement to provide scheme members with the following:
We may if choose to, pass certain details to a third party, if that third party is carrying out an administrative function of the scheme, for example, information requested by the Home Office / CLG Department.
By law, we are also required in certain circumstances to share members’ information with government organisations such as Her Majesty’s Revenue and Customs and the Department for Work and Pensions so that they ensure that public funds are safeguarded. Information may also be shared in the prevention and detection of fraud.
Peninsula Pensions may share or disclose personal information with any of the following bodies or organisations as may be necessary to administer the scheme in line with statutory obligations and/or to comply with contractual obligations relating to it. In certain circumstances, these bodies may also be data controllers in their own right.
|Type of Service/Advisor||Name of Body/organisation||Reasons for sharing the personal data|
|LGPS Scheme Actuary||Barnett Waddingham||To calculate the value of the LGPS Funds assets and liabilities based on its membership profile and to set employer contribution rates based on that information.|
|Scheme AVC Provider*||Prudential||To facilitate the creation and maintenance of individual LGPS member’s AVC accounts|
|Scheme Auditor||To facilitate the statutory duty of auditing the LGPS Funds Annual Report and Statement of Accounts and to check internal controls for all schemes|
|LGPS National Insurance Database||To enable us to identify if their members have benefits in other LGPS schemes to ensure that appropriate benefits are paid.|
|DWP Tell Us Once Service||Department for Work and Pensions||To enable us to be notified of the death of a scheme member|
|Regulators, the government, law enforcement bodies including local and foreign courts, tribunals and arbitrators.|
National Fraud Initiative
Government Actuary Department
The Pensions Regulator
The Scheme Advisory Board
|To comply with scheme administrators statutory duty in the management and administration of benefits, this includes participation in the Cabinet Office’s National Fraud Initiative for the purposes of the prevention and detection of fraud against the Fund and organisations within the public sector and the Government Actuary’s department for the calculation of the triennial assessment of the cost of the Local Government Pension Scheme on a national basis as per the Public Service Pensions Act 2013.|
Peninsula Pensions software provider for its pension administration and pension payroll system
|Heywood||To provide software management support in the delivery of our electronic pension case management, benefit calculation system, and pensioner payroll.|
|Independent Investment Advisors||To support the LGPS Funds in determining its investment strategy based on its liabilities as determined by its membership profile.|
*The LGPS funds are required by law to have an additional voluntary contributions provider (AVC). Devon and Somerset LGPS Funds partner with Prudential to provide AVC options to its members. Through that arrangement, Prudential may have access to members’ contact details in order to provide information and options in relation to AVCs. Members will always be notified and permission sought where their information is shared with Prudential.
We procure the services of a number of suppliers who support the various electronic systems and software for Peninsula Pensions. Those suppliers may have access to the personal data held by us for the purposes of supporting the IT infrastructure only, they will not have access to the information for any other purpose.
Under GDPR individuals have the right to have the information held about them deleted or removed from databases maintained by us.
Peninsula Pension, in providing statutory duties under the regulations has determined that it will only permanently delete a member’s record after 7 years have passed since a member’s pension liability ceasing. In certain circumstances as outlined in the Privacy Notices, we may keep minimal data beyond this period.
For members that still have pension benefits held within the scheme, member details and documentation are required to be retained whilst this remains the case, to enable us to comply with statutory and legal obligations.