National Grid UK Pension Scheme Trustee Limited is the trustee (‘the Trustee’) of the National Grid UK Pension Scheme (‘the Scheme’) and is responsible for administering the Scheme.
The Trustee is committed to respecting your privacy and to complying with applicable data protection and privacy laws. You can visit: https://gas.nationalgridpensions.com/ (‘the website’) without disclosing any personally identifiable information about yourself.
As the Trustee of the Scheme, we gather, hold and use certain personal information (known as ‘personal data’) about scheme members and, where applicable, their dependants and beneficiaries. Put simply, we do this mainly so that we can properly administer the Scheme and ensure that benefits are calculated correctly and paid to the right person.
Most of the information held about you and processed by the Trustee in running the Scheme will be personal data (in other words, it is information from which you as an individual can be identified).
We wish to help you make informed decisions, so please take a few moments to read the sections below and learn how we may use your personal data. This notice should be read in conjunction with the Terms and Conditions of use for the website of which it forms part.
What personal data we collect about you
For legal purposes, the Trustee is deemed to be the ‘data controller’ in respect of your personal data as the Trustee decides the purposes for, and how, your personal data is processed. The Trustee has both a legal obligation and a legitimate interest to process data relating to you for the purposes of administering and operating the Scheme, and paying benefits.
We typically collect personal data when you use services, make customer enquiries, register for information or other services, or when you respond to communications from us (such as questionnaires or surveys). We may also gather personal data from other sources, if necessary. For example, from a public body, such as HMRC, or from your current or former Scheme employer.
Access to the My Online Pension area of the Scheme is via a secure logon. To facilitate this logon, certain personal data is held in our database so that we can identify you when you logon.
Depending on the circumstances and the stage of your membership, we may hold some or all of the following information about you:
- your name, age and date of birth
- your gender
- your address and other contact details, such as telephone number and email address
- your marital status (including the gender of your spouse or civil partner)
- relevant employment information (including current and past salary information and employment dates)
- your national insurance number
- details about your pension benefits under the Scheme
- details of your bank account (to pay benefits)
- details about your dependants and/or beneficiaries (including names and possible details of their gender, and possible information about your relationship status)
- medical and other details about your health
- other personal information about you, which we may need, from time to time, for the purposes of administering the Scheme.
How Your Data Is Processed (‘Purposes’)
The Trustee has a legitimate interest in holding and processing the above information about you as it is needed for us to properly administer the Scheme, and to calculate and pay benefits. We also keep the above information so that we can comply with our obligations towards members under the Scheme governing documents, as well as under relevant legislation.
Personal data relating to the Scheme is held on paper and on computer systems. As the ‘data controller’, the Trustee must safeguard this information and process it fairly and lawfully.
As part of running the Scheme, we may also need to hold and process particularly sensitive information about you and/or your dependants and beneficiaries (known as ‘sensitive personal data’). Under the legislation, details relating to health, racial or ethnic origin, religious or other similar beliefs, sexual orientation and political affiliations are regarded as ‘sensitive personal data’. Except where the legislation allows it, this information cannot be processed or passed to a third party without your explicit consent.
Other Data Controllers
As well as the Trustee, there are other data controllers who hold and process personal data about Scheme members and their beneficiaries in connection with the Scheme. These organisations are data controllers in their own right because they determine the purposes for which personal data is processed, and how it is processed, as part of providing services for the Scheme. For example, the Scheme Actuary, auditors and medical advisers.
The Trustees will share necessary personal data with these organisations so that they can provide services to the Scheme.
Every data controller is subject to data protection law and must process personal data fairly and lawfully. As well as this, the contractual terms between the Trustee and each service provider will ensure that the provider complies with applicable data protection requirements.
The Scheme Actuary is appointed by the Trustee to provide calculation and advisory services in relation to the Scheme. The Actuary uses personal data about you, and other members and beneficiaries of the Scheme, to provide these services. For example, to calculate benefits and advise on the funding of each section of the Scheme. As well as this, other actuarial services may be provided to the Scheme from time to time.
Actuarial services for the Scheme are currently provided by Willis Towers Watson and you can find its privacy statement at www.willistowerswatson.com/personal-data
The Trustee appoints auditors to provide audit services to the Scheme, and an auditor will need to process certain personal data to provide these services.
Audit services are currently provided to the Scheme by:
- Price Waterhouse Coopers (PwC) and you can find its privacy statement at https://www.pwc.co.uk/who-we-are/privacy-statement.html
- Deloitte and you can find its privacy statement at https://www2.deloitte.com/uk/en/legal/privacy.html
Club Vita LLP – Demographic analysis
The trustees will pass your data to Club Vita, a longevity comparison club for pension schemes, in order to receive analysis on longevity and other demographic patterns which it will then consider when developing the assumptions used in projecting benefit payments into the future. Club Vita will continue to use the data that it gathers from all contributing pension schemes to further develop its knowledge and understanding of the demographic patterns amongst pension scheme members, sharing these insights in reports shared with pension schemes and other interested parties. Please be assured that Club Vita’s reports are fully anonymised and neither the Scheme nor individual members can be identified from those reports.
The Trustee appoints medical advisers to provide medical assessment services. For example, in relation to a member who applies to retire early on the grounds of ill-health.
In order to provide these services, the medical adviser will receive personal from the Trustee and from relevant members directly, and will hold and use this personal data for medical assessment purposes.
Some of this personal data will be sensitive personal data because it is information about a person’s health and, therefore, that member will need to provide their explicit consent for that information to be processed. The Trustee and HML will seek a member’s consent in relevant circumstances.
The current medical advisers for the Scheme are Health Management (HML) and to request a copy of its privacy notice, please contact HML by emailing email@example.com, calling 0845 504 1000 or writing to HML at Ash House, The Broyle, Ringmer, East Sussex, BN8 5NN.
Cross Border Transfers (within and outside of the EEA)
Since National Grid operates globally, it may be necessary to transfer your personal data to other companies within National Grid which are located in other countries, including those both inside and outside of the EEA.
For the avoidance of doubt, the European Economic Area (EEA) currently comprises the Member states of the European Union plus Norway, Iceland and Liechtenstein. All countries within the EEA, including the UK, are bound by the General Data Protection Regulation and therefore have similar standards for the protection of personal data.
However, sometimes your personal data may need to be transferred outside of the EEA. Such transfers may happen, for example, where our servers or our advisers and service providers have IT systems located in jurisdictions outside of the EEA, or where you use our services and products while visiting countries outside of the EEA.
Where any of your personal data is transferred outside the EEA, we will take steps to ensure that it receives an adequate level of protection. For example, we may seek to enter into, or require third parties to enter into, data transfer agreements or will ensure that third parties are certified under appropriate data protection schemes.
You have a right to request a copy of any data transfer agreement under which we transfer your personal data, or to otherwise have access to the safeguards which we use. Any data transfer agreement made available to you may need to be redacted for reasons of commercial sensitivity.
Who we share your information with?
The Trustee needs to share personal data with various service providers and third parties in order to help properly administer the Scheme or, where relevant, because certain third parties have a justifiable interest in receiving personal data.
The Trustee is also under an obligation to share personal data with certain regulatory authorities, such as HMRC and other statutory bodies (e.g. the Pensions Ombudsman and the Pensions Regulator). The Trustee can be fined and subject to other action if we fail to provide certain information to these authorities.
The Trustee may, from time to time, share Scheme personal data with the following:
- the Scheme administrator, National Grid UK Pensions Operations (UKPO) who are responsible for the day-to-day administration of the Scheme on our behalf, together with other relevant employees of the sponsoring employers who provide support to the Scheme
- the Trustee Team Partnership
- National Grid UK Pension Scheme Trustee Executive Limited
- National Grid Holdings One plc, National Grid UK Ltd, National Grid Gas plc, NGUKPS Trustee Executive Ltd, Xoserve Ltd, Cadent Gas Ltd, Lattice Group Ltd and any other sponsoring employer of the Scheme
- the Scheme’s professional advisers, including the Scheme Actuary, auditors, medical advisers, investment advisers and lawyers
- the advisers, designers, and printers who help us prepare various communications we send to members, such as the annual benefit statements
- depending upon how we pay pensions, organisations to whom we send personal data in order to effect a BACS transfer (the Bankers' Automated Clearing Service) or CHAPS (the Clearing House Automated Payment System) in the UK, and/or a payment via CitiDirect, the Scheme administrators’ banking providers, when pensions are being paid overseas
- beneficiary or mortality tracing agencies
- pensioner associations, such as the Retired Employee Associations (REAs)
- the Scheme’s website host providers
- the Scheme’s medical adviser
- our appointed insurance company or companies that we may use to insure benefits
- such other third parties whose services we may require from time to time.
Any processing performed by the National Grid Plc, UK Pensions Operations, service providers or other third parties will be governed by a data processing agreement in the form required by law, preserving any and all of your statutory data protection rights.
How long we keep personal data for
We must keep all personal data safe and only hold it for as long as necessary. To meet the requirements of both UK tax and pensions law, we must keep certain personal data (for example, details about the date a member joins the Scheme, their name and address, and details of benefits paid) for a minimum of six years. But, given the nature of pension schemes, the Trustee may be required to keep some of your personal information at least for the rest of your life and for an appropriate period afterwards.
However, we review the personal data held in relation to the Scheme on a regular basis in accordance with the Scheme’s data retention policy. If we conclude that certain personal data is no longer needed, that personal data will generally be destroyed.
Your rights in relation to your information
You have the right to see personal data that is held about you and a right to have a copy provided to you, or someone else on your behalf, in a machine readable (namely, digital) format
- if at any point you believe that the personal data we hold about you is inaccurate, you can ask to have it corrected
- you can require the Trustee to restrict the processing of your personal data in certain circumstances, for example, whilst a complaint about its accuracy is being resolved
- you can object to your personal data being processed, although the Trustee can override this objection in specific instances
- where you have given the Trustee your consent to processing your personal data, you can withdraw that consent at any time by notifying us (see ‘who to contact’ below). However, withdrawing your consent will not affect the processing of any personal data which took place beforehand and it may be possible for the Trustee to continue processing your personal data where this is justified.
- you can request that your personal data is deleted altogether, although the Trustee can override this requirement in certain circumstances.
You should be aware that taking any of the above steps could impact on the payment of your benefits, your participation in the Scheme, and/or our ability to answer questions relating to your benefits.
Information will generally be provided to you free of charge, although the Trustee can charge a reasonable fee in certain circumstances. We will require proof of your identity before providing you with details of any personal information we may hold about you.
Who to contact about personal data
If you wish to:
- see your personal data or to exercise any of the rights mentioned above;
- request a hardcopy of this notice; or make a complaint about how we have handled your personal data;
please contact: UK Pensions Operations, PO Box 3604, Wokingham RG40 9JA.
Tel: 08457 585247 if calling externally or 7780 8990 if calling internally.
Please quote your name and address.
Making a complaint to the Information Commissioner’s Office
If you are not satisfied with our response to any query you raise with us, or you believe we are processing your personal data in a way which is inconsistent with the law, you can complain to the Information Commissioner’s Office whose helpline number is: 0303 123 1113.
Privacy Support and updates
This notice is the latest version as at May 2018. We reserve the right to amend or modify this Privacy Notice at any time and in response to changes in applicable data protection and privacy legislation. You can see the current version of this notice at any time on the Trustee’s website at https://gas.nationalgridpensions.com/.
Alternatively, if you would prefer to receive a hardcopy of the notice please contact UK Pensions Operations. In the event the Purposes for processing change, then we will notify you as soon as practicable and seek your consent where such notification relates to a new additional purpose for processing.
UK Pensions Operations, PO Box 3604, Wokingham RG40 9JA
Or by email to: firstname.lastname@example.org