Privacy Notice

Why we are providing this notice to you

As the Administering Authority of the Fund we hold certain information about you (“personal data”) which we use to administer the Fund and to pay benefits from it. This notice is designed to give you information about the data we hold about you, how we use it, your rights in relation to it and the safeguards that are in place to protect it.

We carefully protect your data from loss, misuse, unauthorised access or disclosure, alteration, or destruction. Appropriate technical and organisational measures are in place to protect your data.

The technical bit

The Administering Authority holds personal data about you in its capacity as data controller for the proper handling of all matters relating to the Fund, including its administration and management. This includes the need to process your data to contact you, to calculate, secure and pay your benefits, for statistical and financial modelling and for 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 manage liabilities and administer the Fund generally.

Legal basis for our use of your personal data

The legal basis for our use of your personal data will generally be one or more of the following:

• we need to process your personal data to satisfy our legal obligations as the Administering Authority of the Fund
• 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 any rights, duties and discretions the Administering Authority has in relation to the Fund
• we need to process your personal data to meet our contractual obligations to you in relation to the Fund (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

What personal data we hold, and how we obtain it

The types of personal data we hold and process about you can include:

• contact details, including name, address, telephone numbers and email address
• identifying details, including date of birth, national insurance number and employee and membership numbers
• information that is used to calculate and assess eligibility for benefits, for example, length of service or membership and salary information
• financial information relevant to the calculation or payment of benefits, for example, bank account and tax 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 of the Fund
• information about a criminal conviction if this has resulted in you owing money to your employer or the Fund and the employer or Fund may be reimbursed from your benefits

We obtain some of this personal data directly from you. We may also obtain data from:

• your current or past employer(s) or companies that succeeded them in business (top obtain for example salary information)
• a member of the Fund (where you are or could be a beneficiary of the Fund as a consequence of that person’s membership of the Fund)
• a variety of other sources including public databases (such as the Register of Births, Deaths and Marriages)
• our advisers, government and/or regulatory bodies, including those in the list of organisations that we may share your personal data with set out in Appendix A 

Where you have provided us with personal data about other individuals, such as family members, dependants or potential beneficiaries under the Fund, please ensure that those individuals are aware of the information contained within this notice.

What we will do with your personal data

We will use this personal data to administer the Fund and to calculate and provide you (and 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.

Organisations that we may share your personal data with

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

In some limited cases these recipients may be outside the UK. If this occurs, we will make sure that appropriate safeguards are in place to protect your data in accordance with applicable laws.

We may also share your personal data with advisers and service providers so that they can help us carry out our duties, rights and discretions in relation to the Fund. Some of those organisations will process your personal data on our behalf and in accordance with our instructions. Other organisations will be responsible to you directly for their use of personal data that we share with them. They are referred to as data controllers and we have highlighted them in Appendix A. You will be able to find out about their own data protection policies (which will apply to their use of your data) on their websites.

How long we keep your personal data

We will only keep your personal data for as long as we need to in order to fulfil the purpose(s) for which it was collected; and for so long afterwards as we consider may be required to deal with any questions or complaints that we may receive about our administration of the Fund, unless we elect to retain your data for a longer period to comply with our legal and regulatory obligations.

In practice, this means that your personal data will be retained for such period as you (or any beneficiary who receives benefits after your death) are entitled to benefits from the Fund and for a period of [50years] after those benefits stop being paid. For the same reason, your personal data may also need to be retained where you have received a transfer, or refund, from the Fund in respect of your benefit entitlement.

Islington Council will retain as much information as is necessary to enable any future queries regarding benefits to be answered fully and accurately.

Your rights

You have the right to access and obtain a copy of the personal data that we hold about you. You can ask for a copy of the data we hold about you by making a ‘subject access request’.

If you believe that the data we hold about you is inaccurate, you can ask us to correct it.

In some circumstances you may also have the right to ask us to restrict the processing of your personal data until any errors are corrected, to object to our processing or transferring or (in very limited circumstances) erase your personal data.

Complaints process

If you’re not happy with how we handle your personal data, the contents of this privacy notice or our processing activities, please tell us by using the contact details below.

You also have the right to complain to the Information Commissioner’s Office (ICO) about the way we are handling your personal information. For more information on how you can do this, visit the Information Commissioner's Office website.

More information

If you would like more information about how the council processes your personal data and your rights, refer to the council privacy policy.

Or you can contact the Data Protection Officer / Information Governance team:

Islington Council
Resources Department
Information Governance
222 Upper Street
Islington
London, N1 1EX

Email: DP@islington.gov.uk.

List of data processors on behalf of Islington Pension Fund

Function	Company Name	Address
Overseas Payment provider to transmit payments to scheme members with non-UK accounts	Equiniti Group	Overseas Payment Services Sutherland House, Russell Way, Crawley, West Sussex, RH10 6SN
Printing Company for Annual Pension Statements	DSI Group	Evolution House, Choats Road, Dagenham, Essex, RM9 6BF
Tracing Bureau for locating Members	Department for Work and Pensions	Bulk Letter Forwarding Service Mail Handling Site A Wolverhampton WV98 2DU
Supplier of Pensions Application Software	Aquila Heywood	Hamilton House Church Street Altrincham, Cheshire WA14 4DR
Third Party Payroll Agency	Education Personnel Management	St John’s House Spitfire Close Ermine Business Park Huntingdon Cambridgeshire PE29 6EP
Locating Past Membership of the LGPS	National Insurance Database – Hosted by the South Yorkshire Pensions Authority	18 Regent Street Barnsley South Yorkshire S70 2HG
Actuary	Government Actuary’s Department	Finlaison House, 15-17 Furnival St, London EC4A 1AB
HMRC	N/a	PAYE & Self-Assessment P O Box 1970 Liverpool, L75 1WX
Internal Auditors	Islington Council	222 Upper Street Islington London N1 1XR
External Auditors	KPMG	15 Canada Square Canary Wharf London E14 5GL
National Fraud Initiative	Cabinet Office	70 Whitehall Westminster London SW1A 2AS
Fund Actuary	Mercer	No. 4 St Paul's Square, Old Hall St, Liverpool L3 9SJ
Additional Voluntary Contribution (AVC) Provider(1)	Prudential plc	Laurence Pountney Hill London EC4R 0HH
Additional Voluntary Contribution (AVC) Provider(2)	Equitable Life	Walton Street Aylesbury Buckinghamshire HP21 7QW
Additional Voluntary Contribution (AVC) Provider(3)	NPI	Lynch Wood Park Lynch Wood Peterborough PE2 6FY
Investment Adviser	M J Hudson Allenbridge	4th Floor, 8 Jewry London EC2R 8DN
Fund Custodian	BNY Mellon	Canary Wharf Group Plc 1 Canada Square London E14 5AL
Corporate Governance Research and Voting Advice Service	Pension Investments Research Consultants	Suite 8.02, Exchange Tower 2, Harbour Exchange Square, Isle of Dogs, London E14 9GE
Governance and Administration	Islington Council Local Pension Board	Islington Council Town Hall, Upper Street London N1 2UD
Government Agency	Department for Works & Pensions	Caxton House, Tothill Street London SW1H
The Courts of England & Wales	N/a	N/a
Other Local Authorities	N/a	N/a