- Privacy notice
Last updated: 23/04/2021
The following privacy notice is for the members and beneficiaries of the Warwickshire Pension Fund (the Fund). It has been prepared by Warwickshire County Council in its capacity as the administering authority of the Fund. This notice is designed to inform you about the personal information we hold about you, how we use it, your rights in relation to it and the safeguards that are in place to protect it. This notice should be read in addition to the council’s overall Customer Privacy Notice and Staff Privacy Notice.
- Purpose for processing
As the Administering Authority of the Fund, we will hold personal information about you in order to be able to deal with all matters relating to the Fund, including its administration and management. This includes
- Contacting you
- Assessing your eligibility for benefits
- Calculating and providing you (and, if you are a member of the Fund, your beneficiaries upon your death) with benefits
- Identifying your potential or actual benefit options and, where relevant, implementing those options.
- Allowing alternative ways of delivering your benefits – e.g., using insurance products and transfers to, or mergers with, other pension arrangements
- For statistical and financial modelling
- For reference purposes – e.g., when we assess how much money is needed to provide members' benefits and how that money should be invested
- Complying with our legal and regulatory obligations as the administering authority of the Fund
- Addressing queries from members and other beneficiaries and to respond to any actual or potential disputes concerning the Fund
- Managing the Fund's liabilities, including the entering into of insurance arrangements and selection of Fund investments
- Processing in connection with the sale, merger or corporate reorganisation of, or transfer of, a business by the employers that participate in the Fund and their group companies.
- Personal information collected and lawful basis
The types of personal data we hold and process about you can include:
- Contact details, including name, address, telephone numbers and email address.
- Identification details, including date of birth, national insurance number and employee and membership numbers.
- Information that is used to calculate and assess eligibility for benefits, for example, length of service or membership and salary information.
- Financial information relevant to the calculation or payment of benefits, for example, bank account and tax details.
- Information about your family, dependents or personal circumstances, for example, marital status and information relevant to the distribution and allocation of benefits payable on death.
- Information about your health, for example, to assess eligibility for benefits payable on ill health, or where your health is relevant to a claim for benefits following the death of a member of the Fund.
- Information about a criminal conviction if this has resulted in you owing money to your employer or the Fund and the employer or Fund may be reimbursed from your benefits.
Our lawful bases for processing your personal information will be one or more of the following:
- Contract for the supply of services
- Compliance with a legal obligation - Local Government Pension Scheme Regulations 2013 (SI 2013/2356)
- Tasks carried out in the public interest or in the exercise of official authority
Where we obtain personal information concerning certain "special categories" of particularly sensitive information, such as health, extra protections apply under the data protection legislation. Our lawful basis for processing such information will be one or more of the following:
- Explicit consent
- Necessary for carrying out obligations under employment
- Necessary for assessing the working capacity of an employee
- Substantial public interest
We obtain this personal information:
- Directly from you
- From your current or past employer(s) or companies that succeeded them in business – e.g., salary information
- From a member of the Fund (where you are or could be a beneficiary of the Fund as a consequence of that person's membership of the Fund)
- From a variety of other sources including:
- Public databases, e.g., Register of Births, Deaths and Marriages
- Our advisers and government or regulatory bodies – incl. those in the below list of organisations we may share your personal data with.
Where you have provided us with personal information about other individuals, such as family members, dependents or potential beneficiaries under the Fund, please ensure that those individuals are aware of the information contained within this notice.
- Who we may share your information with
From time to time, we will share your personal information with advisers and service providers so that they can help us carry out our duties, rights and discretions in relation to the Fund.
Organisations we share with:
- Tracing bureaus, e.g., for locating members
- Overseas payments providers = to transmit payments to scheme members with non-UK accounts
- Printing companies
- Pensions software provider
- Suppliers of IT, document production and distribution services
- Actuarial consultant
- Investment adviser
- Additional Voluntary Contribution providers
- Legal adviser
- Fund Actuary
- External auditor
- LGPS National Insurance database (South Yorkshire Pensions Authority)
- The Department for Work and Pensions
- The Government Actuary's Department
- The Cabinet Office = for the purposes of the National Fraud Initiative
- The Pensions Regulator
- The Pensions Ombudsman
- The Courts of England and Wales = for the purpose of processing pension sharing orders on divorce
- Dispute resolution organisations
- Law enforcement bodies
- Administering authorities of other LGPS funds (or their agents, such as third-party administrators) where you have been a member of another LGPS fund, and the information is needed to determine the benefits to which you or your dependents are entitled.
In addition, where we make Fund investments or seek to provide benefits for Fund members in other ways, such as through the use of insurance, then we may need to share personal data with providers of investments, insurers and other pension scheme operators as appropriate.
From time to time, we may provide some of your data to your employer and their relevant subsidiaries (and potential purchasers of their businesses) and their advisers for the purposes of enabling your employer to understand its liabilities to the Scheme.
The organisations referred to in the paragraphs above may use the personal data to perform their functions in relation to the Fund as well as for statistical and financial modelling (such as calculating expected average benefit costs and mortality rates) and planning, business administration and regulatory purposes. They may also pass the data to other third parties (for example, insurers may pass personal data to other insurance companies for the purpose of obtaining reinsurance), to the extent they consider the information is reasonably required for a legitimate purpose.
In some cases recipients of your personal data may be outside the UK.
We do not use your personal data for marketing purposes and will not share this data with anyone for the purpose of marketing to you or any beneficiary.
Information will only ever be shared when it is strictly necessary to help us provide effective services and you may have the right to refuse. We will not pass it onto any other parties unless required to do so by law or in all reasonable circumstances the disclosure is fair and warranted for the purposes of processing or subject to a legal data protection exemption. Sometimes the law may require us to pass your details on to a third party, for example, to prevent crime.
- How long we will hold your information
We will only keep your personal data for as long as we need to in order to fulfil the purpose(s) for which it was collected and for so long afterwards as we consider may be required to deal with any questions or complaints that we may receive about our administration of the Fund, and/or to comply with our legal and regulatory obligations.
We sometimes receive requests to “trace” pension benefits. On this basis, in most cases we consider it reasonable to retain your personal data relating to pension benefits for your entire life. In practice, this means that your personal data will be retained for such period as you (or any beneficiary who receives benefits after your death) are entitled to benefits from the Fund. For the same reason, your personal data may also need to be retained where you have received a transfer, or refund, from the Fund in respect of your benefit entitlement.
- Your information rights
Find out how to access your personal information.
You may be entitled to rectification, restriction, objection, and erasure of your personal information depending on our legal basis to process your information (identified in the Purpose of Processing above). To exercise these Information Rights please contact us via
Warwickshire Pension Fund
Warwickshire County Council
See our overall privacy notice for further contact details and if you have a complaint about your information rights.
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