This privacy notice explains:
- what data we hold
- how we obtain it
- why we hold it
- what we do with it.
The information you provide will be treated confidentially at all times. Security safeguards apply to both manual and computerised held data, which can only be accessed by relevant staff.
You are entitled to request access to, and a copy of, any information we hold about you. You have the right to withdraw your consent to the processing of your data as set out in this notice.
Personal and special category data
The categories of personal data we are processing are:
- contact details: including name, address, telephone numbers and email address
- identifying details: including date of birth and national insurance number
- information relating to your benefits in the scheme(s), including length of service or membership and salary
- other information in relation to your membership of the scheme(s) or to enable the calculation or payment of benefits, for example, bank account details
- family, dependents or personal circumstances, for example, marital status and information relevant to the distribution and allocation of benefits payable on death
- 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 scheme(s)
- information about a criminal conviction if this has resulted in you owing money to your employer or the scheme(s) and the employer or scheme(s) may be reimbursed from your benefits
- sensitive personal data, such as health information. Extra protections apply under the data protection legislation for this category of data. We will only process this data with your consent, unless we can lawfully process this data for another reason permitted by that legislation. You have the right to withdraw your consent to the processing at any time by notifying the County Council in writing.
We may also receive information from:
- you directly
- your current or past employer(s) such as salary information
- a member of the scheme(s) (where you are or could be a beneficiary of the scheme(s) as a consequence of that person’s membership of the scheme(s))
- other sources including public databases (such as the Register of births, deaths and marriages), our advisers and government or regulatory bodies.
West Sussex County Council (WSCC) complies with the Data Protection Act and the General Data Protection Regulation (GDPR). It is registered as a ‘Data Controller’ with the Information Commissioner’s Office (Reg. No. Z6413427).
The legal basis for processing personal data
Processing is necessary:
- to satisfy our legal obligations as the scheme manager of the scheme(s)
- to carry out a task in the public interest or in the exercise of official authority in our capacity as a public body
- for the legitimate interests of administering the scheme(s) and liabilities under it, calculating, securing and paying benefits and performing our obligations and exercising any rights, duties and discretions the scheme manager has in relation to the scheme(s)
- to meet our contractual obligations in relation to the scheme(s) (for example, under an agreement that you will pay additional voluntary contributions to the scheme(s)), or to take steps at your request, before entering into a contract.
The legal basis for processing special category data
- Explicit consent of the data subject.
- Processing is necessary to protect the vital interests of a data subject or another individual where the data subject is physically or legally incapable of giving consent.
- Processing is necessary for reasons of substantial public interest on the basis of law which is proportionate to the aim pursued and which contains appropriate safeguards.
- If a child or other person is considered to be at risk of significant harm, people working with you will have a duty of care to share the information with the relevant services without consent.
If you do not give consent, or subsequently withdraw it, the County Council will not be able to process the relevant information to make decisions based on it, including the payment of your benefits.
Where you have provided us with personal data about other individuals, such as family members, dependants or potential beneficiaries under the scheme(s), please ensure that those individuals are aware of the information contained within this notice.
How we use your personal information
We will use this data to deal with all matters relating to the scheme(s), including its administration and management. This can include the processing of your personal data for all or any of the following purposes:
- to contact you
- to assess eligibility for, calculate and provide you (and, if you are a member of the scheme(s), your beneficiaries upon your death) with benefits
- to identify your potential or actual benefit options
- to comply with our legal and regulatory obligations as the scheme manager of the scheme(s)
- to address queries from members and other beneficiaries and to respond to any actual or potential disputes concerning the scheme(s).
Who we share your information with
We may pass data to:
- internal departments such as legal services, Internal Audit, WSCC Records Office
- central government such as Cabinet Office, Department for Work and Pensions, HM Revenue and Customs (if a member’s family opts to participate in the Tell Us Once (TUO) service)
- other third-party organisations, as allowed by law
- our appointed external Auditor and legal advisors
- our appointed Additional Voluntary Contribution Providers (if you have made an application)
- the Pensions Ombudsman
- the Pensions Regulator
- those who assist with discharging the County Council’s duty to protect the public funds it administers in the prevention and detection of fraud. This includes providing data to the National Fraud Initiative, the use of the Disclosure of death registration information (DDRI) and General Register Office (GRO) databases. Find further information about fraud in West Sussex.
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 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 scheme(s).
We will not share data with third-parties for marketing purposes.
Occasionally we may provide some of your data to your employer for the purposes of enabling your employer to understand its liabilities to the scheme.
Transfer outside the European Economic Area
If your data needs to be transferred we will make sure that an appropriate level of protection is in place.
How long we will keep your personal data
Personal data will not be retained for longer than necessary in relation to the purposes for which they were collected.