Privacy – General Data Protection Regulation (GDPR) – 25/5/2018

Privacy notices

Privacy Notices

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:

Devon LGPS Pension Fund– Peninsula Pensions act as the ‘Data Controller’ –       Short version Privacy Notice / Full version Privacy Notice

Somerset LGPS Pension Fund – Peninsula Pensions act as the ‘Data Processor’ –  Short version Privacy Notice / Full version Privacy Notice

Gloucestershire Firefighter Pension Schemes  – Peninsula Pensions act as the ‘Data Processor’ – Gloucestershire Fire & Rescue Service are the ‘Data Controller’

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:

  • The Occupational and Personal Pension Schemes (Disclosure of Information) Regulations 2013
  • The Pensions Act 2011 (Transitional, Consequential and Supplementary Provisions) Regulations 2014
  • The Occupational and Personal Pension Schemes (Disclosure of Information) Amendment Regulations 2015
  • The Public Service Pensions Act 2013
  • The Pensions Act 2004

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:

  • Basic information to members on the relevant pension scheme on joining or upon request by other parties
  • Information to early leavers and those retiring from the pension schemes
  • Information on request relating to transfer to and from the pension schemes
  • Issue Annual Benefit Statements to Active members, Deferred Pensioner members and Pension Credit members of the schemes no later than 31 August each year
  • Information regarding changes to the Regulations that govern the schemes that may affect the calculation of a member’s benefits.

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.

Who we may share your information with

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 ActuaryBarnett WaddinghamTo 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*PrudentialTo facilitate the creation and maintenance of individual LGPS member’s AVC accounts
Scheme AuditorTo 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 DatabaseTo enable us to identify if their members have benefits in other LGPS schemes to ensure that appropriate benefits are paid.
DWP Tell Us Once ServiceDepartment for Work and PensionsTo 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

 

HeywoodTo provide software management support in the delivery of our electronic pension case management, benefit calculation system, and pensioner payroll.
Independent Investment AdvisorsTo 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.

Who may have access to your personal information?

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.

Retention periods

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.