Privacy Policy for Marie Curie Defined Benefit Pension Scheme

This Privacy Policy (the 'policy') sets out how the Defined Benefit Pension Scheme (the 'scheme') at Marie Curie collects information, and what rights you have as a participant of the scheme.

Who controls data held by the scheme?

The Trustees of the Marie Curie Defined Benefit Pension Scheme, of One Embassy Gardens, 8 Viaduct Gardens, London SW11 7BW are the Data Controller of personal information collected by or provided to them about members and (where relevant) their spouses, partners and dependants, in connection with the administration of the scheme.

What are the grounds on which the scheme collects personal information?

The scheme collects personal information to:

• provide services to its members and other stakeholders
• fulfil its legal obligations and duties under a number of regulations.

How does the scheme use personal information?

The scheme will use information to:

• communicate with you (whether by phone, email, text message, mail or other means) and manage our relationship with you (including updating our records in relation to your details and preferences)
• administer and manage the scheme, including via third-party providers (detailed below)
• fulfil any contractual obligations to you, including providing you with information and statements
• meet any regulatory or legal obligations, including the prevention and detection of crime, as well as auditing or reporting requirements.

What types of information does the scheme collect?

The scheme processes different types of personal information, including:

• employment: details of periods of employment, salary information, name of employer and National Insurance number
• financial: such as bank details
• personal: name, address, date of birth, home address
• details of other stakeholders: such as any spouse or dependants.

Special data

The scheme may also have to collect 'special data' about a member, such as health information, to assess a member’s eligibility for ill-health retirement. Where this is the case, the scheme will seek explicit consent from the stakeholder in order to do this.

Data collection may be mandatory (eg from an employer) in order to fulfil the legal requirements on the scheme. Where any collection is not mandatory, members will be advised that this is the case.

How does the scheme collect information?

Information may be provided to the scheme in one of three ways:

• by members: eg by completing an initial application form, or via correspondence (whether by phone, email or post)
• by employers: (whether current or former)
• by other third parties: this may include anyone entitled to benefit from your membership of the scheme, your next of kin, or doctors.

Does the scheme share information with any third-parties?

The scheme may share and disclose personal information of members (and their spouses / dependants) in the following circumstances.

Service providers

The scheme engages the services of various third parties, such as professional and financial advisers, tracing agencies, lawyers, accountants, insurers and other service providers, to help administer and manage the scheme, in accordance with its legal or contractual obligations.

In certain circumstances, they may also be data controllers.

Administrator

• Company name: Capita  
• Reason for sharing/disclosing: to calculate pensions payable

Scheme Actuary

• Company name: Capita  
• Reason for sharing/disclosing: to calculate and valuate the scheme funding in accordance with Pension Regulations

Scheme Auditor

• Company name: Hays MacIntyre  
• Reason for sharing/disclosing: to annually audit the scheme to ensure compliance both internally and externally with Pension Regulations

Life Assurance

• Company name: Canada Life  
• Reason for sharing/disclosing: to supply relevant data of all eligible members of the scheme for brokering and coverage in the event of a member’s death

Legal & General

In January 2021, we purchased a policy with Legal & General, a market-leading insurer, to insure benefits of members in the Scheme. Legal & General need certain membership data, for example, details of members’ benefit entitlement. This information is shared securely and limited only to the information needed to insure benefits. You can view Legal & General’s formal privacy notice here.  

Legal obligation

The scheme may be compelled by an order of a court of law, tribunal or ombudsman service; or be under a legal obligation, such as to share information with government agencies such as HMRC or the DWP

Individuals or entities connected to the member: such as former employers; personal financial advisers; family members or representatives; beneficiaries; associated pension schemes.

What rights do members have?

Under the General Data Protection Regulation (GDPR)  , individuals have a number of rights in relation to data held about them. These include:

• Right of access: you can obtain a copy of information held about you.
• Right of erasure: often referred to as the “right to be forgotten”. In order to fulfil its legal obligations, the scheme is unable to permanently delete records of its members (but please note the other rights outlined below).
• Right of data portability: this is most frequently exercised when a member wishes to transfer out of the Scheme: the Scheme will provide the member’s data in an appropriate format to the new provider;
• Right of rectification: if any information held about you is incorrect, please advise us and we will amend it.
• Right to object to or restrict processing: you can (in certain circumstances) limit the ways in which the Scheme can use your data.

If you wish to exercise any of the above rights, please email paul.underhill@mariecurie.org.uk with details of your request.

How long does the scheme retain personal information?

The scheme has a retention schedule which ensures that information is only held for as long as necessary. If you wish to see a copy of this schedule, please email paul.underhill@mariecurie.org.uk.

Find out more

If you have any questions about this policy, please contact paul.underhill@mariecurie.org.uk.

If you’re not satisfied with how the scheme has handled your personal information, you can complain to the Information Commissioner’s Office  .

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