Privacy Notice

We are committed to protecting your personal data and the personal data we process about other people connected to you. This Privacy Notice sets out the basis on which we process the personal data we hold in connection with your membership of the Scheme and which relates to you or to any individual connected to you, e.g. your dependants.

1. Introduction and terms we use in this notice

91热爆 Pension Trust Limited is the sole Trustee of the 91热爆 Pension Scheme (the Scheme). When we refer to “we” or “our” we are referring to 91热爆 Pension Trust Limited, a private company limited by guarantee established in England and Wales with company number 02218202 and registered address at Broadcasting House, London, W1A 1AA.

For the purposes of the UK General Data Protection Regulation (the “UK GDPR”), the Data Protection Act 2018 (“DPA 2018”) and any other applicable data protection laws, we are the data controller regarding any personal data that you have provided to us. We are legally obliged to use your information in line with all applicable laws concerning the protection of personal data. These laws are referred to collectively in this Privacy Notice as the “data protection laws”.

This Privacy Notice explains the following:

what personal data we hold about you and your dependants;
where we obtain that personal data;
how we use this information;
who we share your personal data with;
how long we keep that personal data; and
your rights in respect of personal data we hold.

2. Personal data we hold about you and your dependants

Our main objective is to ensure that all beneficiaries receive the benefits to which they are entitled under the Rules of the Scheme.

The personal data we hold includes:

Your core personal information and contact details;
Employment information necessary to calculate the benefits due from the Scheme;
Financial information necessary to pay the benefits due;
Information about other pension arrangements you may have;
Dependants鈥� information;
Documentary information in connection with your pension together with recordings of calls to our pension service line;
Information about how you use our website and myPension Online;
Information from publicly available sources like the Register of Births, Deaths and Marriages;
Information about your health if you apply to have your pension paid early on the grounds of ill-health;
Other information which you provide to us, or which we require, to allow us to administer the Scheme.

The personal data we process includes:

Core personal information, i.e. title, first names, surname, date of birth, address, contact telephone numbers and email addresses, national insurance number, sex, marital status;
Employment information related to your Scheme membership, i.e. salary, pension contributions (including Additional Voluntary Contributions), start and end dates of employment, dates and types of any absence and working hours whilst an active member of the Scheme;
Financial information such as your bank account, tax status information, Scheme pension entitlement, PAYE information;
Information about other pension arrangements you may have, for example if you considering transferring your Scheme pension to another arrangement;
Dependants’ information, i.e. the personal details of spouses, civil partners, nominated dependants and nominated beneficiaries including the nature of the relationship between you and your dependants/beneficiaries;
Documentary information including copies of certificates, identity documents and correspondence sent to or received from you or other parties in connection with your pension together with recordings of calls to our pension service line;
Information about how you use our website and myPension Online;
Information from publicly available sources like the Register of Births, Deaths and Marriages;
Information about your health if you apply to have your pension paid early on the grounds of ill-health and consent to us obtaining such information;
Other information which you provide to us, or which we require, to allow us to administer the Scheme.

3. Where we obtain personal data

The personal data we process comes from a number of different sources.

Much it will come from you or a third party acting on your behalf, for example when you or your financial adviser contact us. The 91热爆 (or another participating employer) will provide us with information about your employment that we need to calculate the benefits you may be entitled to.

We may also receive personal data from service providers such as tracing agencies, from publicly accessible databases and from the device you use to access our website.

Personal data that comes from you or third parties

We may receive the personal data set out above whenever you access or register for myPension Online, or when we are contacted by you or a third party acting on your behalf. Such third parties may include your financial adviser, personal representative, or another pension arrangement to or from which your pension benefits are being transferred or have been transferred in the past.

We also receive personal data from third parties such as the 91热爆 and other employers that participate in the Scheme. This can include the Employment information listed above.

We work closely with a number of third parties, including service providers (e.g. address tracing, existence checking and identity verification agencies), analytics providers, and regulatory authorities or government departments, and may receive information about you from them which may include information obtained from publicly accessible databases like the Register of Births, Deaths and Marriages. This may include your latest address, confirmation that you have verified your identity, tax information (including PAYE details and contracting out record) and information received from web browsers and devices.

Personal data received from web browsers and devices

We operate two online services:

The member self-service portal, myPension Online, which we manage; and
Our website, bbc.co.uk/mypension, which is managed by the 91热爆 although we are responsible for the content. To find out more about the 91热爆 and how it will use data it collects when you use the bbc.co.uk/mypension website, e.g. your device’s IP address, please see the .

We store information about how you use myPension Online and the device(s) you use to access the service. This includes unique online identifiers such as IP addresses, which are numbers that can uniquely identify a specific computer or other network device on the internet.

A cookie is a small amount of data, which often includes a unique identifier that is sent to your computer, tablet or mobile phone (all referred to here as a “device”) web browser from a website’s computer and is stored on your device’s hard drive. Each website can send its own cookie to your web browser if your browser’s preferences allow it. myPension Online does not use cookies. Our website bbc.co.uk/mypension is part of the 91热爆’s website and whilst we do not use cookies the 91热爆 may do. Please refer to the 91热爆’s Privacy Policy for details of the 91热爆’s cookie policy.

Your web browser or device may also provide us with information about your device, such as a device identifier and IP address. We use information provided by your browser/device to understand the webpage that directed you to myPension Online and to prevent and detect fraud.

If you have any concerns about the information which might be accessed from or stored on your device, you should review your web browser/device settings.

Our website and myPension Online may contain links to websites owned and operated by third parties. These third party websites have their own privacy policies (sometimes called Fair Processing Notices), and may use cookies, and we therefore urge you to review them. They will govern the use of personal data you submit when visiting these websites, which may also be collected by cookies. We do not accept any responsibility or liability for the privacy practices of such third party websites and your use of such websites is at your own risk.

Special category personal data

Sometimes we may ask you to provide special category personal data. Examples include when you tell us about your relationship status which indirectly may tell us about your sexual orientation, or if you apply for your pension to be paid on the grounds of ill-health when we will need information about your health.

When we ask for such personal data we will provide further details about why we need it, how we will use it and the legal basis for processing it we are relying upon. Normally this will be you giving your explicit consent (and/or, where applicable, that of your dependants). You can withdraw your consent for us to hold and process additional or special category personal data at any time by contacting us. If you do, our ability to administer your benefits may be restricted which could mean the benefits payable to you or your dependants are affected. We will explain this to you at the time. We may also rely on provisions set out in legislation permitting the processing of special categories of personal data where obtaining explicit consent is not reasonably practicable, or may cut across our duty to ensure the proper administration of the Scheme.

4. How we use the personal data we hold and our legal basis for doing so

We use the personal data we hold to administer the Scheme, in line with our obligations under the Trust Deed and Rules, to ensure members and their dependants receive the benefits they are entitled to. This includes:

Calculating your benefits, including online calculations that you may request;
Identifying what benefits are, or might be, payable to you or, in the event of your death, any beneficiaries;
Dealing with any queries or disputes you may have about your benefits;
Communicating with you by electronic means, including online, by post or by other means to keep you updated on matters related to the Scheme and your benefits, or in response to a communication from you;
Providing you with information about your benefits and options available to you;
Complying with any legal and regulatory obligations for which the provision or processing of your personal data is required; and
Calculating and managing the Scheme liabilities.

We also use the personal data we hold

to monitor and improve our service offering to you, for example to help us understand how members are using the myPension Online service;
when we undertake activities from time to time to help us manage the liabilities of the Scheme. Such activities may require (where relevant) disclosures to insurers, advisors and/or administrators in relation to these activities;
for “service administration purposes”, which means that we may contact you for reasons related to the service, activity or online content you have accessed or provided (e.g. to provide you with password reminders, to notify you of changes to the services or content, to notify you of updates to our Privacy Notice, or to let you know if your myPension Online account has become dormant and to ask if you would like to use it again before we close it);
to monitor the traffic on our website, e.g. to identify the location of users, to block disruptive use, to establish the number of visits from different countries;
to provide a more relevant, tailored service. For instance, we may provide you with an online facility for you to put your pension into payment;
for fraud prevention and detection;
to comply with our legal obligations; and
to disclose information in aggregate (so that no individuals are identified) for strategic development purposes.

The lawful basis for the processing of your personal data will depend on the purposes for which we process your information. In most cases we have a legitimate interest to ensure the proper administration and management of the Scheme.

Sometimes, we need to process your personal data to comply with our legal obligations, for example when we provide information about pensions in payment to HM Revenue and Customs.

We may send you emails or letters or contact you on Scheme platforms to inform you about additional services provided by the 91热爆 or selected third parties that we think you may be interested in, including but not limited to:

Independent financial advice funded by the 91热爆
Volunteer Visiting Scheme
91热爆 Financial Assistance Fund
Grace Wyndham Goldie Trust Fund
91热爆 Pensioners’ Association
Personal Accident Insurance for pensioners
Membership of the 91热爆 Club in London

You can find out more about these services on our website bbc.co.uk/mypension.

We may also invite you to give feedback on the Scheme’s services (participation is always voluntary) to help us improve our service to you.

We may personalise message content based upon any information you have provided to us and your use of Scheme platforms.

If you would prefer that we did not contact you about these services and/or ask you for feedback on our services please contact us. You can change your mind at any time.

Where the Scheme proposes using your personal data for any other uses we will update this privacy notice.

5. Who we share your personal data with

We do not sell, rent or lease your personal data. Where you have authorised us to do so, we will share personal data about you with third parties, for example your financial adviser.

Sometimes we use third parties to process your personal data on our behalf, for example the 91热爆 provides certain services to us in relation to the administration of the Scheme under the terms of the Administration Agreement. We require third party data processors to comply strictly with our instructions and we require that they do not use your personal data for their own business purposes, unless you have explicitly consented to the use of your personal data in this way.

In other cases we may share your personal data with third parties who act as separate data controllers in respect of that data, or who act with us as joint data controllers.

Before we share your personal data with third parties who act as separate data controllers in respect of that information, we will seek contractual agreement with the third party that it will not use your personal data for other purposes and that it will process your personal data in accordance with the relevant data protection rules including not retaining it for longer than necessary.

An example of this is where we share data with insurers providing policies to insure the Scheme against certain events. This includes Zurich Assurance Ltd and The Canada Life Assurance Company who process the personal data (postcode, date of birth, gender, marital status, indicator of ill-health early retirement, accrued pension benefits and spouse/civil partner information) of members in receipt of a pension in order to provide insurance against increased longevity. More information about how they process personal data and your rights in respect of that processing can be found at www.zurich.co.uk/en/services/privacy/fair-processing-notice#longevity and www.canadalifere.com/data-privacy-notice.html.

In addition, we may share certain personal data with third parties who act as joint data controllers in respect of that information. An example of this is the trustees of the 91热爆 Life Plan Group Life Scheme, who act as joint data controllers in relation to the processing of members’ expression of wish forms. In accordance with the data protection laws, we have entered into an agreement with the 91热爆 Life Plan Group Life Scheme trustees recording the allocation of responsibilities between us as joint controllers. Broadly, each of us will remain responsible for:

providing information to our respective members about how we process personal data;
responding to any requests we receive from our respective members seeking to exercise their rights under the data protection laws;
responding to any complaints or enquiries we receive from third parties around the processing of personal data; and
reporting personal data breaches.

We may share your personal data with the 91热爆 and other participating employers, for example, to verify your employment details including your pensionable salary and pension contributions. We also share information with the employers so they can understand, monitor and evaluate their liabilities to the Scheme.
We will share your information with any third party to whom we may need to disclose personal data in order to comply with our legal, regulatory and statutory obligations. This may be as part of a legal process, e.g. in response to a court order or law enforcement agency’s request or to investigate, prevent, or take action regarding illegal activities, suspected fraud, or situations involving potential threats to the physical safety, property or rights of any person.

As the Trustee Board needs help from various advisers to properly administer the Scheme, we share personal data with the Scheme’s professional advisers, including, but not limited to, the Scheme actuary, auditor, medical advisers, investment adviser, investment providers and lawyers. Where any such adviser processes data outside the UK we ensure that they confirm contractually that appropriate safeguards are put in place to ensure that personal data is kept secure.
The Scheme Actuary is an employee of WTW. The Scheme Actuary and WTW act as data controllers when they provide actuarial services to the Scheme. WTW’s privacy notice is available on their website, wtwco.com.

Third parties we may share your personal data with

Third party	Reason for sharing
Santander, Aviva, Fidelity	Additional Voluntary Contribution providers
91热爆, Equiniti	Pension administration, technical and hosting services
HMRC, DWP	Tax and contracting out information
91热爆 (and other participating employers)	Sponsoring employer
WTW	Actuarial services
LexisNexis, Target	Existence checking and address tracing
Target, mypensionID	Identity verification services
Sacker & Partners LLP	Solicitors
APS	Print and bulk mailing services
Zurich Assurance Ltd Canada Life Assurance Company AIG Life Ltd Legal & General	Insurance arrangements to help us manage Scheme liabilities and risk
Trustees of the 91热爆 Life Plan Group Life Scheme	To share member’s expression of wish in respect of death benefit lump sums that may be payable from the 91热爆 Life Plan Group Life Scheme
Registered practitioner appointed by the 91热爆	To provide medical advice in respect of incapacity pension applications
Sage	Accounting services
Finastra, HSBC, Citibank	Banking and payment service providers
The Pensions Regulator, The Pensions Ombudsman	Regulatory requirements and dealing with complaints
Deloitte LLP	Independent Auditors
Anywhere365	Helpline service provider
The Maltings	Archive paper storage
Wordshop	Accessible communications service provider

Plus any other service providers who process personal data on behalf of the Trustee from time to time and / or third parties with whom the Trustee is required to transfer data by law or regulatory requirements.

International transfers

Wherever possible we will ensure your data is processed within the UK. However, should it be necessary to transfer your personal data outside the UK, we will ensure appropriate legal protection is in place to protect your data.

6. How long we keep your personal data

Pension benefits are paid over a long period and your right to benefits under the Scheme is based on information that may go back many years. We therefore normally need to retain and process your personal data for a long time. Specifically

a) The period required to comply with our legal or regulatory obligations, and

b) The period envisaged within our Data Retention Policy.

We determine the period envisaged within the Data Retention Policy with regard to the Scheme鈥檚 operational and legal requirements, such as facilitating the payment of benefits to your or your beneficiaries, calculating and managing the liabilities of the Scheme, resolving disputes, and enforcing our agreements. Even after you are no longer entitled to any benefits, e.g. because you have transferred your benefits to another pension arrangement, we will retain information about you for a reasonable period, e.g. to provide evidence that you are no longer entitled to any benefits from the Scheme.

7. Your rights

Under the data protection laws you have the right to request a copy of the personal data the Scheme holds about you, to have any inaccuracies corrected, and to ask us to erase information about you. Depending on the circumstances, you may also have the right to request a restriction of processing of such information, object to the processing of such information and/or request a copy of such information in a portable format.

To make a request please contact us.

Please also contact us if you think any information we hold about you is wrong, or if any of your personal data changes, for example because you move home.

You have the right to obtain access to, or copies of, your personal data (known as a data subject access request) and ask us to correct any errors, or ask us to erase your personal data.

Data subject access requests are normally free of charge but we may charge a reasonable fee or refuse a request if it is unfounded, excessive or is for information that has already been provided. You may be asked to prove your identity by providing copies of two pieces of approved identification (at least one of which must contain your current address), which can be:

Passport
Driving licence
Birth certificate
Utility bill (from last 3 months)
Current vehicle registration document
Bank statement (from last 3 months)
Rent book (from last 3 months).

If you believe any of the information that we hold about you is incorrect please let us know as soon as possible. Please include your reference number, staff number or pension number in any correspondence.
To find out what personal data we hold about you, or if you believe any of the information that we hold about you is incorrect please contact us.

You can always close your myPension Online account by contacting us. Closing your myPension Online account will not erase personal data that we are holding. If you close your myPension Online account then you will be unable to access any information about your Scheme benefits online and you will need to contact us if you have any questions about your benefits.

We will not be able to delete all your personal data even if you transfer your benefits to another pension arrangement as we need to keep a record as evidence that we have discharged the liability.

8. Changes to our Privacy Notice

This notice was produced on 24 November 2023. It may be updated from time to time and you can see the latest version at any time on our website. Alternatively, please contact us if you would prefer to receive a hard copy.

9. How to contact us

If you have any questions or comments about this Privacy Notice, or concerns about the way we handle your personal data please contact us via myPension Online or email mypension@bbc.co.uk. You can also call us on 0303 081 2848 or write to us at: 91热爆 Pension and Benefits Centre, 3 Central Square, Cardiff, CF10 1FT.

You can find out more about your rights regarding your personal data or raise a concern or complaint by contacting the Information Commissioner鈥檚 Office (ICO) at . Their helpline number is: 0303 123 1113.

91热爆

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The personal data we process includes:

Personal data that comes from you or third parties

Personal data received from web browsers and devices

Special category personal data

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