The trustee’s commitment to your privacy
The trustee of the Merchant Navy Ratings Pension Fund (the “Fund”), (the “trustee”) is committed to protecting and respecting your privacy and rights. This privacy statement (“statement“) is relevant to you if you are a member of the Fund.
This statement gives you information about the trustee, how it will collect and use personal data about you, the circumstances in which it may share or otherwise use the personal data and to whom it may disclose this personal data. This statement also sets out important information regarding your rights in respect of the information we collect about you and how to contact us.
You are advised to regularly check and review the statement to ensure you understand how we may be processing your personal data.
Identity of the data controller
The trustee is a data controller in respect of the personal data it collects about you for the purposes of data protection legislation (by which we mean the UK Data Protection Act 2018 and the UK GDPR). The trustee’s address is Trustee of the Merchant Navy Ratings Pension Fund, c/o Pi Consulting (UK) Ltd, 2nd Floor Tuition House, 27-37 St George’s Road, London SW19 4EU.
In addition to the trustee, the Fund actuary is also a data controller. The Fund actuary is Towers Watson Limited (“WTW”) and its privacy notice outlining how it uses personal data to provide actuarial services to the Fund can be found on their website, which, at the date of this statement is available here.
Information the trustee may collect about you, your beneficiaries, dependents and next of kin
The trustee collects and processes personal data which you provide to it in connection with the Fund. The trustee also collects personal data about you from your employer or third parties. Periodically, the trustee may collect personal data relating to you from third parties such as former employers or regulatory authorities.
Please be aware that before you share the personal information of your beneficiaries, dependents, with the trustee, you must provide your beneficiaries, dependants and next of kin with relevant information from this statement.
The categories of personal information collected and processed may include:
- Personal Information: your name, gender, age and date of birth, and details of your beneficiaries, dependents and other persons in your household.
- Contact Information: your residential address, telephone number, and email address.
- Professional Information: details of your employer, your length of employment, salary information.
- Bank Information: your account details and other financial information.
- Benefits Information: your membership number, Fund joining and leaving date, contributions, and relevant matters affecting your benefits such as additional voluntary contributions.
- Correspondence: letters and emails from you, the trustee, or the administrator of the Fund, and records of other communications, including complaints.
In addition, the trustee may collect and process the following ‘special category’ information about you:
- Relationship Information: your marital status and the gender of your spouse, marriage and birth certificates.
- Health Information: reason for retirement (ill-health) or incapacity data, including health information provided in support of an ill-health or dependant pension application (e.g., reports from medical practitioners).
Purposes for and the basis upon which the trustee will process your personal data
The trustee will process your personal data, and the personal data of other persons (for example, your dependants) provided by you to us, in connection with the administration of benefits of your pension and related benefit entitlements arising as a result of your employment with your employer. Where necessary, the trustee uses your personal data to fulfil its legal obligations and exercise its legal rights in relation to the Fund.
Generally, the trustee relies upon the “legitimate interests” in you receiving your benefits and the successful operation of the Fund as the legal basis for processing your personal data, provided always that the legitimate interests are not overridden by the interests or fundamental rights or freedoms of Fund members (or others) which may require protection of personal data. The trustee also relies upon its legal obligation as a pension trustee, as it is under a legal duty to manage the Fund on behalf of its members and beneficiaries.
Where the trustee is required to process sensitive personal data, the trustee must identify an additional condition for processing under Article 9 of the GDPR. Depending upon the condition relied upon, the trustee may also need to meet the associated condition under Schedule 1 to the Data Protection Act 2018.
Retention of personal data
The trustee will hold personal data of Fund members and their dependants for as long as may be necessary in order to administer benefit entitlements and for the purposes of maintaining records of steps the trustee has taken to comply with its obligations under the Fund. Inevitably, this means that personal data may be retained by the trustee for extremely long periods of time, including after entitlement to receive benefits by an individual and/or their beneficiaries has ceased. The end date for holding personal data in respect of a particular beneficiary is expected to be 20 years from the date on which benefits cease to be payable to both that beneficiary and their survivor(s).
Disclosure of personal data
In the course of administering the Fund, the trustee will engage a number of external service providers and third parties. The trustee has contracts in place with these service providers and third parties restricting how they can use your information. At all times, the trustee will ensure that the personal data is processed in accordance with their instructions and in circumstances which require the recipient to observe industry standard security measures in respect of the personal data.
In addition to sharing your information (which may include your information presented in a pseudonymised format) for the purposes of providing your benefits and administering the Fund, the trustee may have to share your information with official authorities such as the Pensions Regulator and the Pensions Ombudsman. The trustee may also share your information where necessary for the restructuring or reorganisation of the Fund.
Further information about what information we share with service providers and third parties is included in the table below.
| Service provider/third party | Purpose | Information shared |
| Aptia | Fund administration | • Personal information • Contact information • Professional information • Bank information • Benefits information • Correspondence • Relationship information • Health information |
| WTW | Actuarial services | • Personal information • Professional information • Benefits information • Relationship information • Health information |
| Pi Consulting | Trustee services | • Personal information • Contact information • Professional information • Benefits information • Correspondence • Relationship information • Health information |
| Mayer Brown | Legal advice | • Personal information • Contact information • Professional information • Bank information • Benefits information • Correspondence • Relationship information • Health information |
| PwC | Auditing services | • Personal information • Professional information • Benefits information • Relationship information • Health information |
| Taylor Wessing | Legal advice | • Personal information |
| Utmost | AVC services | • Personal information • Professional information • Benefits information • Correspondence • Relationship information • Health information |
| Pi Consulting | Fund secretarial services | • Personal information • Contact information • Professional information • Benefits information • Correspondence • Relationship information • Health information |
| Heka Global | Tracking services | • Personal information • Contact information • Professional information |
| LexisNexis | Tracking services | • Personal information • Contact information • Professional information |
| Beauchamps LLP | Project Greenwich legal adviser | • Personal information • Contact information • Professional information • Benefits information • Correspondence • Relationship information |
| Clever Fulton Rankin | Project Greenwich legal adviser | • Personal information • Contact information • Professional information • Benefits information • Correspondence • Relationship information |
| McRoberts | Project Greenwich legal adviser | • Personal information • Contact information • Professional information • Benefits information • Correspondence • Relationship information |
| Kays Medical | Medical adviser | • Personal information • Contact information • Professional information • Health information |
| Knowa | Online board pack data and member case management | • Personal information • Contact information • Professional information • Bank information • Correspondence • Benefits information • Relationship information • Health information |
| Insurers and Reinsurers including MetLife | • Insurance and reinsurance services • Entering into longevity swap arrangements | • Personal information • Benefits information |
| Public authorities, regulators or government bodies including HM Revenue & Customs and the Department for Work & Pensions | Regulatory and compliance | • Personal information • Contact information • Professional information • Bank information • Benefits information • Correspondence • Relationship information • Health information |
| The Pensions Ombudsman / The Money and Pensions Service | Complaints | • Personal information • Benefits information • Correspondence • Relationship information • Health information |
| Beneficiaries | Beneficiary payments | • Personal information |
| IT providers | IT systems and support | • Personal information • Contact information • Professional information • Bank information • Benefits information • Correspondence • Relationship information • Health information |
| Buy-in/buy-out insurers or other counterparties | To enter into buy-in/buy-out contracts | • Personal information • Contact information • Professional information • Bank information • Benefits information • Correspondence • Relationship information • Health information |
| Third party pension providers you ask us to disclose your information to | Transfer of your pension to another provider | • Personal information • Contact information • Professional information • Bank information • Benefits information • Correspondence • Relationship information • Health information |
International transfers of personal data
As required by data protection legislation, the trustee has strict security procedures regarding the storage and disclosure of personal data.
The personal data that it collects about you may be transferred to, and stored at, or processed in one or more countries outside the UK. It may also be processed by staff operating outside the UK who work for the Trustee or for our third parties. In such cases, except where the relevant country has been determined by the ICO to ensure an adequate level of data protection, the trustee will ensure that the transferred information is protected, for example by a data transfer agreement in the appropriate standard form approved for this purpose by the ICO. If the trustee cannot ensure such an adequate level of data protection, your personal data will not be transferred outside the UK.
If you wish to obtain a copy of these safeguards, please contact the Fund’s administrators, Aptia, at the address quoted at the end of this statement or contact them at Merchant Navy Ratings Pension Fund, Aptia UK Limited, Maclaren House, Talbot Road, Stretford, Manchester, M32 0FP requesting a copy of these safeguards.
Automated decision-making
We do not envisage that any decisions will be taken about you using automated means. If this position changes, we will notify you in writing.
Your rights under data protection law
You have rights under data protection law including:
- the right to access your personal data;
- the right to have your personal data rectified if it is inaccurate or incomplete;
- the right to have your personal data deleted or removed if there is no reason for its continued storage and processing;
- the right to object to your personal data being processed and to restrict the processing of your personal data in certain circumstances;
- where you have provided your consent to the collection, processing and transfer of your personal data for a specific purpose, you have the right to withdraw your consent
You may address your requests to Aptia, the Fund’s administrator. Please contact them at Merchant Navy Ratings Pension Fund, Aptia UK Limited, Maclaren House, Talbot Road, Stretford, Manchester M32 0FP.
Changes to this statement
The trustee reserves the right to change this statement and any other relevant policies or procedures at any time, and will take appropriate steps to bring any such amendments to your attention. Any changes the trustee may make to this statement (which will, unless otherwise indicated, apply to any personal data already obtained by the trustee before the changes were made) will be effective from the date on which those changes have been notified to you. Where appropriate, it may notify you of any changes made by email.
Contact
If you have any questions concerning this statement or the policies or procedures referred to above, please contact the Fund’s administrators, Aptia, at:
| Address: | Merchant Navy Ratings Pension Fund c/o Aptia UK Limited, Maclaren House, Talbot Road, Stretford, Manchester, M32 0FP |
Where you are dissatisfied with any aspect of our handling of your personal data you have a right to lodge a complaint with the Information Commissioner’s Office. Their contact details are:
| Address: | Information Commissioner’s Office Wycliffe House Water Lane Wilmslow Cheshire SK9 5AF |
| Tel: | 0303 123 1113 or 01625 545 745 |
| Fax: | 01625 524 510 |
| Email: | casework@ico.org.uk |
If you are based in the EU, you have a right to complain to the EU Data Protection Authority (“DPA”) in your jurisdiction. If you would like to be directed to the appropriate DPA, please contact Aptia at the details above.
This statement was last updated in August 2024.