Who we are
TfL Trustee Company Limited is the trustee (“the Trustee”) of the TfL Pension Fund (“the Fund”).
As the Trustee of the Fund, we hold certain personal information (known as “personal data”) about members and, where applicable, their dependants and beneficiaries. Most of the information held about you and processed by the Trustee in running the Fund will be personal data.
- For legal purposes, the Trustee is known as the “data controller”, as we decide the purposes for and the means by which the personal data we hold is processed.
What information we collect about you
Depending on the circumstances and the stage of your membership, we may hold some or all of the following information about you:
- your name and date of birth
- your address
- your national insurance number
- details of your bank account (to pay benefits)
- details about your dependants and/or beneficiaries
- medical and other details about your health.
How we use that information
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 Fund and to calculate and pay benefits. We also keep the above information in order to allow us to comply with our obligations towards members under the Fund governing documents, as well as under relevant legislation.
Personal data relating to the Fund is held on paper and on computer systems. As the “data controller”, the Trustee must process this information fairly and lawfully.
As part of running the Fund, 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.
We are not allowed to disclose personal data about you to other parties except:
- when required for contractual or legal reasons or other specifically identified purposes; or
- where you have given your consent.
- However, as the Trustee needs help from various advisers to properly administer the Fund, we share personal data with the following:
- your current, past or future employer
- the Trustee’s professional advisers, including the Fund actuary, auditor, medical advisers, investment adviser and lawyers
- the third parties who are responsible for the day-to-day administration of the Fund on behalf of the Trustee (including the Fund Office)
- HM Revenue & Customs and other statutory bodies (such as the Pensions Ombudsman and the Pensions Regulator) – the Trustee can be fined and subject to other action if it fails to provide certain information to these authorities
- the advisers and printers who help us prepare various communications we send to you, such as the annual benefit statement
- our appointed insurance company or companies for the purposes of life insurance and additional voluntary contributions
- depending upon how we pay pensions, the personal data we have to supply 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 Western Union the administrators’ banking providers when pensions are being paid overseas
- mortality tracing agencies
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 a minimum of 6 years. But, given the nature of pension schemes, the Trustee may be required to keep some of your personal data for the rest of your life.
- Right of Access – 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
- Right to Rectification – if at any point you believe that the personal data we hold about you is inaccurate/wrong, you can ask to have it corrected
- Right to Restrict processing – 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
- Right to object to processing – as we are relying on legitimate interests as a reason for processing, you can object to your personal data being processed, although the Trustee can override this objection in certain circumstances.
- Withdrawing consent – where you have given us 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.
- Right to be forgotten – you can request that your personal data is deleted altogether, although the Trustee can override this request 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 Fund, and/or our ability to answer questions relating to your benefits.
The Trustee may charge a small fee to cover the administration costs involved in providing you with a copy of your personal data.
Who to contact about your personal data
If you wish to:
- see your personal data or to exercise any of the rights mentioned above
- request a hard copy of the notice
- make a complaint about how we have handled your personal data
- please contact the Head of Pensions at 4th Floor, Wing over Station, 55 Broadway, London SW1H 0BD.
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.
Updates to this notice
This notice is the latest version as at 31 March 2018. This notice will be updated from time to time and you can see the current version at any time on the Fund website at www.tfl.gov.uk/pensions . Alternatively, if you would prefer to receive a hard copy of the notice, please let us know (see “Who to contact” above).
This Scheme Actuary has a separate obligation to provide information to you about how your personal information is used in the provision of actuarial services – you can see this at www.willistowerswatson.com/personal-data