Summary privacy notice

Privacy notice (summary)

For the members and beneficiaries of West Yorkshire Pension Fund (WYPF), Lincolnshire Pension Fund (LPF), London Borough of Hounslow Pension Fund (LBH), London Borough of Barnet Pension Fund (LBB) and Fire and Rescue third-party pension administration clients.

This privacy notice explains how and for what purpose(s) Bradford MDC (the "Administering Authority for West Yorkshire Pension Fund", or "we") uses personal data about for members and beneficiaries (referred to as “you”) of West Yorkshire Pension Fund (the "Fund") and the listed shared service partners above. As the Administering Authority of the Fund we hold certain information about you and from which you can be identified ("personal data") which we need to administer the Fund.

In this privacy notice, we have summarised some of the key ways in which we collect and use personal data in accordance with our requirements under data protection legislation. Further information can be found in the Full Privacy Notice at the following link:

https://www.wypf.org.uk/privacy-policy/

What personal data do we hold?

The types of data we hold and process will typically include:

Contact details, including name, address, telephone numbers and email address.
Identifying details, including date of birth and national insurance number
Information relating to your benefits, including length of service or membership and salary.
Other information in relation to your membership or to enable the calculation or payment of benefits, for example bank account 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.
Information about a criminal conviction if this has resulted in you owing money to your employer or your Fund and the employer or Fund may be reimbursed from your benefits.

Information about any previous membership of other public service pension schemes and other LGPS administering authorities, including your date leaving and whether the previous scheme/authority assessed your eligibility for underpin protection.

We obtain some of this personal data directly from you. We may also obtain data from your employer (for example, salary information) and from other sources including public databases and the advisers and service providers that we may share your personal data which are listed in the Full Privacy Notice.

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.

What will we do with your personal data?

We will use this personal data to administer the Fund and to calculate and provide you (and, if you are a member of the Fund, your beneficiaries if you die) with benefits. We will also use this personal data 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), and to comply with our legal obligations. For more details about the purposes for which we process your personal data, please see the Full Privacy Notice https://www.wypf.org.uk/privacy-policy/.

From time to time, we will share your personal data with third parties, including our contractors, advisors, government bodies and dispute resolution and law enforcement agencies and insurers to comply with our obligations under data protection legislation, and in connection with the provision of services that help us carry out our duties, rights and discretions in relation to the Fund and administration services. These organisations are listed in the Full Privacy Notice.

We may also process your personal data to assess and, if appropriate, action a request you make to transfer your benefits out of your Fund.

In some cases recipients of your personal data may be outside the UK. If this occurs, we will make sure that additional safeguards are in place to protect your data in accordance with applicable data protection laws. Please use the contact details below if you want more information in connection with this.

What is the legal basis for our use of your personal data?

The lawful basis for our use of your personal data will usually be that we need to process your personal data to satisfy our legal obligations as the Administering Authority of the Fund or the hared service administrator. However, where that lawful basis does not apply then the lawful basis for our use of your personal data will be one or more of the following:

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
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 or shared service partner has in relation to the Funds; and/or
because we need to process your personal data to meet our contractual obligations in relation to the Fund or shared service partners (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.

Please note that where we indicate that our processing of your personal data is necessary for us to comply with a legal obligation, or for us to take steps, at your request, to potentially enter into an employment contract with you, or to perform it, and you choose not to provide the relevant personal data to us, we may not be able to enter into or continue our contract with you.

How long will we hold your data?

We will only keep your personal data for as long as we need it to administer the Fund (and shared service) and to deal with any questions or complaints that we may receive about this, unless the law requires us to keep it for a longer period. In practice, this means that your personal data may be retained for the greater of:

such period as the Member (or any beneficiary who receives benefits after the Member's death) are entitled to benefits from the Fund and for a period of 15 years after those benefits stop being paid; or
100 years from the member's date of birth; or
100 years from the date of birth of any beneficiary who received benefits from the Fund after the member's death.

More detailed information about our data retention policies can be found on our website at https://www.wypf.org.uk/corporate/shared-service/about-the-shared-service/.

Your rights

You have a right to access and obtain a copy of the personal data that we hold about you and to ask us to correct or complete your personal data if there are any errors or it is out of date or incomplete. In very limited circumstances, you may also have a right to ask us to restrict the processing of your personal data or to transfer or (in extremely limited circumstances, such as where your personal data is no longer needed for the purpose for which it is being processed) erase your personal data. You should note that we are not obliged to erase your personal data if we need to process it for the purposes of administering the Fund.

In certain circumstances you have the right to object to the processing of your personal data; for example you have the right to object to processing of your personal data which is based on the public interest or legitimate interests identified in the section above headed "What is the legal basis for our use of your personal data?", or where the processing is for direct marketing purposes.

You can obtain further information about your rights from the Information Commissioner's Office at: www.ico.org.uk or via its telephone helpline (0303 123 1113).

If you wish to exercise any of these rights, please contact the Fund Administrator below. You also have the right to lodge a complaint in relation to this summary notice, the Full Privacy Notice or our processing activities with the Information Commissioner's Office, which you can do through the website above or their telephone helpline.

One of the reasons we collect and hold your personal data is to administer your benefits from the Fund and shared service partners. If you do not provide the information we request, or ask that the personal data we already hold is deleted or that the processing of the personal data be restricted, this may affect our ability to administer your benefits, including the payment of benefits. In some cases it could mean that we are unable to put your pension into payment or have to stop your pension (if already in payment).

Contacting us

Please contact the administrator WYPF for further information. Full contact details are available at our website https://www.wypf.org.uk/contact-us/.

Data Protection Officer

You may also contact our data protection officer Yunus Gajra at the above address for further information.