Privacy notice for the Schroders retirement benefit scheme (“the Scheme”)
The Trustee of the Scheme holds and processes personal data about Scheme members and beneficiaries in order to run the Scheme. In doing so, we comply with all relevant data protection legislation.
What we do with your data
As a data controller, the Trustee collects and processes your personal data:
- for the purposes of complying with legal duties to administer the Scheme, including the calculation and payment of benefits to or in respect of all members;
- for other business or administrative purposes relating to the operation of the Scheme e.g. funding, benefit design, investment, liability management, issuing communications, responding to enquiries etc., where it is in our legitimate interests to do so;
- where you have given explicit consent for the Trustee to do so, which you may withdraw at any time; and
- where it is necessary for the performance of contractual obligations to which you are a party, or at your request prior to entering a contract.
Whilst much of the data we hold has been provided by members themselves, we also hold and process data provided by the employer, HMRC, regulatory bodies and by tracing organisations. We also receive information from members about their proposed beneficiaries, who may be eligible to receive benefits on the member’s death. We will not provide a copy of this notice to those individuals as to do so is likely to seriously impair our ability to properly pay the benefits due under the scheme.
The data we hold is to enable the calculation and payment of the benefits the members are entitled to, and this may include your name, address, salary, years of service with the Scheme, pension contributions, age of retirement, date of birth, National Insurance number, gender, marital status, employment history, bank details and contact details.
We also hold some special categories or “sensitive” data about members and their beneficiaries for the purposes of administering the Scheme (for example in relation to ill-health or death benefits). Where we collect this type of information about you, we will process it for the purpose of complying with our own legal obligations to administer the Scheme and/or because it is necessary in our legitimate interests to do so.
Who else processes your data?
We share your personal data with certain third parties involved in running the Scheme, for example, the Administrator (currently Mercer), Scheme Actuary (currently Jonathan Wicks at Aon) and Legal Adviser (currently Allen & Overy). In some circumstances we are joint controllers with these third parties.
We and they may also be required to share personal data with HMRC and other regulatory bodies.
Schroders plc (including the relevant employing entities within the group) holds your data to comply with its legal obligations as the sponsoring employer of the Scheme. It has a legitimate interest in the Scheme being run in a cost effective way and may have an interest in offering certain options to members. The Trustee may share information with Schroders plc and its auditors and advisers for this purpose.
Third parties involved in running the Scheme may from time to time transfer data to other third parties such as their affiliates, some of which are in other countries, including outside the United Kingdom or European Economic Area. Where such transfers are made, the parties involved will ensure adequate safeguards are in place and that all relevant data protection legislation is complied with.
Storage of your personal data
Pension benefits are paid over a long period and your right to benefits under the Scheme is based on information which may go back many years. Our policy is therefore to retain information relating to you until after your membership of the Scheme ends.
Once your membership ends, we may decide to delete some of the data held in relation to you, depending on the circumstances. However, information may be held for as long as we consider appropriate in order to ensure the Scheme pays the correct benefits and to deal with any queries relating to your benefits which may arise after that time.
Third party advisers will hold on to some or all of your personal data in accordance with their retention policy after the termination of their appointment to the Scheme. This is to protect themselves against any subsequent legal claims. In those circumstances, the adviser will be the data controller of your personal data and will be responsible for compliance with all data protection requirements.
Your rights
You have the right to access your personal data and require that we rectify any errors in the data that we hold, or request that we erase your personal data. In some circumstances, you can also require that we restrict the way we process your personal data, object to its processing or request a copy of your personal data for the purposes of transmitting elsewhere. You also have a right to complain to your local data protection authority, or to a court of law, if your data protection rights are violated.
If you would like to exercise any of the rights described above, please let us know using the contact details in the section below or by emailing Peter Strudwick at peter.strudwick@schroders.com. However, please note that if we do not hold all the data we need to administer your benefits, we may not be able to pay out the benefits you are entitled to.
Contact details
If you have any questions about this, or require further information about how your personal data is held and used, please contact:
Schroder Pension Trustee Limited
c/o Company Secretariat
1 London Wall Place
London EC2Y 5AU
What if you have a complaint?
To make a complaint about how we’ve handled your information, contact us as set out above.
If you’re not satisfied with our response to your complaint or believe our processing of your information does not comply with data protection law, you can make a complaint to the Information Commissioner's Office. Its contact details are:
Address: Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF
Telephone number: 0303 123 1113 or 01625 545 745
Updates to how your data is held
This Privacy Notice will be uploaded to the Scheme administration online portal (“Oneview”) and will be updated as required. The latest version of the Privacy Notice and other information about the Scheme can be found on OneView.