Privacy policy

This notice is for members and beneficiaries of the Cheshire Pension Fund (“the Fund”).  It has been prepared by Cheshire West and Chester Council (“the Administering Authority”, or “we”) in its capacity as the Administering Authority of the Fund.

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Why we are providing this notice to you

As the Administering Authority of the Fund, we hold certain information about you (“personal data”) which we use to administer the Fund and to pay benefits from it.  This privacy notice is designed to give you information about the data we hold about you, how we use it, your rights in relation to it and the safeguards that are in place to protect it.

 

The Administering Authority holds personal data about you and your dependents / family members in its capacity as data controller for the proper handling of all matters relating to the Fund, including its administration and management.  This includes the need to process your data, to contact you or your dependents / family members, to calculate, secure and pay your benefits, for statistical and financial modelling and for reference purposes (for example, when we assess how much money is needed to provide members’ benefits and how that money should be invested), and to manage liabilities and administer the Fund generally.  Further information about how we use your personal data is provided below.

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The legal basis for our use of your personal data will generally be one or more of the following:

1. We need to process your personal data to satisfy our legal obligations as the Administering Authority of the Fund; and/or

2. We need to process your personal data to carry out a task in the public interest or in the exercise of official authority in our capacity as a public body; and/or

3. We need to process your personal data for the legitimate interests of administering and managing the Fund and liabilities under it, calculating, securing and paying benefits and performing our obligations and exercising any rights, duties and discretions the Administering Authority has in relation to the Fund; and/or

4. We need to process your personal data to meet our contractual obligations to you in relation to the Fund (for example, under an agreement that you will pay additional voluntary contributions to the Fund), or to take steps, at your request, before entering into a contract.
    

What personal data we hold, and how we obtain it

The types of personal data we hold and process about you can include:

• Contact details, including name, address, telephone numbers and email address;

• Identifying 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; and

• 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.

 

We obtain some of this personal data directly from you.  We may also obtain data (for example, salary information) from your current or past employer(s) or companies that succeeded them in business, 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) and from a variety of other sources, including public databases (such as the Register of Births, Deaths and Marriages), our advisers and government or regulatory bodies, including those in the list of organisations that we may share your personal data with set out below.

 

Where we obtain information concerning certain “special categories” of particularly sensitive data, such as health information, extra protections apply under the Data Protection legislation. 

 

We will only process your personal data falling within one of the special categories with your consent, unless we can lawfully process this data for another reason permitted by that legislation.  You have the right to withdraw your consent to the processing at any time by notifying the Administering Authority in writing.  However, if you do not give consent, or subsequently withdraw it, the Administering Authority may not be able to process the relevant information to make decisions based on it, including decisions regarding the payment of your benefits.

 

Where you have provided us with personal data about other individuals, such as family members, dependants or potential beneficiaries under the Fund, please ensure that those individuals are aware of the information contained within this notice.
 

How we will use your personal data

We will use this data to deal with all matters relating to the Fund, including its administration and management.  This can include the processing of your personal data for all or any of the following purposes:

 

• to contact you and/or your dependents / family members;

• to assess eligibility for, calculate and provide you (and, if you are a member of the Fund, your beneficiaries upon your death) with benefits;

• to identify your potential or actual benefit options and, where relevant, implement those options;

• to allow alternative ways of delivering your benefits, for example, through the use of insurance products and transfers to or mergers with other pension arrangements;

• for statistical and financial modelling and reference purposes (for example, when we assess how much money is needed to provide members’ benefits and how that money should be invested);

• to comply with our legal and regulatory obligations as the Administering Authority of the Fund;

• to address queries from members and other beneficiaries and to respond to any actual or potential disputes concerning the Fund;

• the management of the Fund’s liabilities, including the entering into of insurance arrangements and selection of Fund investments;

• 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;

• in conjunction with our User Acceptance Testing environments in order to ensure compliance and accuracy of the calculation and regulatory scheme rules used by our Pensions Software to successfully administer and provide precise benefits for our members; and

• to make you aware of any regulatory changes or consultations which could impact you pension benefits.
   

Organisations that we may share your personal data with

From time to time we will share your personal data with advisers and service providers so that they can help us carry out our duties, rights and discretions in relation to the Fund.  Some of those organisations will simply process your personal data on our behalf and in accordance with our instructions.  Other organisations will be responsible to you directly for their use of personal data that we share with them.  The data controllers may be obliged under the Data Protection legislation to provide you with additional information regarding the personal data they hold about you and how and why they process that data.  Further information may be provided to you in a separate notice or may be obtained from the advisers and service providers direct, for example via their websites.

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These organisations include: