Privacy Policy

High Commission of Canada in the United Kingdom Locally Engaged Staff Pension Scheme - Privacy Notice

This Privacy Notice has been issued by the Trustees and Scheme Actuary of the High Commission of Canada in the United Kingdom Locally Engaged Staff Pension Scheme (the Scheme) to comply with the General Data Protection Regulation (GDPR).

Data controllers

The Trustees of the Scheme are as appointed by deed and are listed in the Scheme’s annual report and accounts. The Scheme Actuary to the Scheme is John Lawton of Barnett Waddingham LLP.

In accordance with guidance issued by the Information Commissioner’s Office (ICO), the Trustees and Scheme Actuary of the Scheme are considered “joint data controllers” (the holders, users and processors of personal data) for the purposes of the GDPR. The joint data controllers can be contacted as follows:

Barnett Waddingham LLP, 3 Devon Way, Birmingham, B31 2TS
Email: HCC@barnett-waddingham.co.uk
Telephone: 0333 11 11 222

It is possible that in some circumstances other professional advisers may be considered to be data controllers. This might include the Scheme’s auditor, Secretary or legal advisers, who are engaged by the Trustees to fulfil certain services.

Use, transfer and storage of personal data

In order to operate the Scheme and pay benefits to members, we are required to hold personal information about each member, including the following:

• Personal details including your name, National Insurance number, gender, age, date of birth, marital status, postal and/or email address and telephone number.
• Salary and data relating to investments and pension assets held within and outside of the Scheme (to the extent they are relevant for the calculation and payment of your benefits, or to the taxation of your benefits from the Scheme
• Employment history, including employment dates and historic pay records.
• Bank account details for payment of benefit instalments and HMRC tax code information.
• Descriptions relating to your physical and mental health (to the extent that they are relevant to the calculation and payment of your benefits from the Scheme, eg to comply with a request for early retirement due to health reasons).

In the course of running the Scheme, we may require information from you in relation to your marital status (which may include the gender of your spouse or civil partner) and / or information about your (or your partner’s) health. Such information will be used by the Scheme’s administrators to determine the benefits payable to you and your beneficiaries.

Your personal data has been provided to the data controllers by the sponsoring employers or may have been obtained directly from you. It is not publicly accessible data. The personal data collected relates to your employment and membership of the Scheme. Your personal data will be stored until such time as we no longer need it but in any event for not longer than 15 years after the date the Scheme is wound up.

The Trustees share your data with the Scheme’s administrator Barnett Waddingham LLP, Scheme Actuary, the sponsoring employers and AVC providers. They may also share data with the Trustees’ other professional advisers (including the Scheme Auditor, Secretary and other pension consultants), insurers and regulatory bodies (including, but not limited to, HM Revenue and Customs, the Department for Work and Pensions and the Pensions Regulator).

Your data may be shared by the Scheme’s administrator with sub-processors for particular outsourced activities such as bulk printing jobs, confirmation of address/existence, offsite backup and archive. A comprehensive list of parties with whom data may be shared is set out in the Trustees’ formal Data Mapping document, available on request in writing to the data controllers at the address above.

The Scheme administrators, on behalf of the Trustees, will use your personal data to ensure that the correct benefits can be paid to you and that your requests can be dealt with efficiently, in accordance with the Trustees’ legal obligation to run the Scheme in accordance with the Trust Deed and Rules. The Trustees and / or administrators may contact you directly in order to provide relevant information, or to deal with your queries.

In addition, it is in yours and the Trustees’ legitimate interests to use or share your personal information to:

• Keep up to date and accurate records about your membership of the Scheme in order to calculate and pay benefits
• Comply with the law, including regulations and guidance issued by the Pensions Regulator
• Efficiently manage the relationship between the Scheme and the sponsoring employers, which may include undertaking risk-management exercises as the request of the sponsoring employers

The Scheme Actuary uses your personal data to advise the Trustees on the financial management of the Scheme. This advice helps to ensure the Trustees are able to meet their obligations to pay members’ benefits, and is necessary to comply with obligations placed on them by legislation, including the Pensions Act 2004. The Scheme Actuary will not pass your personal data to any third party without the prior agreement of the Trustees.

The Trustees have conducted due diligence on their suppliers to ensure they process data within the UK and/or the EEA. If data needs to be transferred outside of the EEA, we will ensure appropriate safeguards are in place.

Your rights in relation to your data

The purpose of this Privacy Notice is to fulfil your right to be informed about the use of your personal data. In addition:

• You have the right to access your personal data. If you wish to request copies of your personal data please contact the Data Controller at the address above.
• You have the right to have your personal data rectified if it is inaccurate or incomplete.
• You have the right to have your personal data deleted or removed if there is no reason for its continued storage and processing.
• You have the right to object to your personal data being processed and to restrict the processing of your personal data in certain circumstances. While processing is restricted, the data controllers are permitted to store the personal data to ensure the restriction is respected in future. You will be informed if a restriction on processing is lifted.
• You have the right to lodge a complaint about the data controller with the ICO.

Please note that if you choose to exercise your rights to withhold data or insist on its deletion, then the Trustees may not be able to perform their duties in relation to the Scheme, and your benefits could be affected.

Further details about GDPR and your rights under GDPR can be found on the ICO’s website at https://ico.org.uk/