Privacy
Who we are
Magnox Electric Group Pension Trustee Co Ltd is the trustee (the “Trustee”) of the Magnox Group of the Electricity Supply Pension Scheme (the “Scheme”).
As the Trustee of the Scheme, we hold certain personal information (known as “personal data”) about scheme members and, where applicable, their dependants and beneficiaries. Most of the information held about you and processed by the Trustee in running the Scheme will be personal data (in other words, because we hold information from which you as an individual can be identified, any information we hold in respect of you will be subject to certain protections).
For legal purposes, the Trustee is known as the “data controller”, as we decide the purposes for and the means by which the personal data we hold is processed.
The Trustee’s actuarial advisers, currently Aon, are also data controllers in relation to some of your personal data that the Trustee holds. A short form privacy notice from Aon is contained in the Appendix to this Notice. This contains a link to Aon’s full privacy notice.
What information we collect about you
Depending on the circumstances and the stage of your membership, we may hold some or all of the following information about you:
• your name, date of birth, gender;
• your marital status;
• your address and other contact details (such as telephone number and email address);
• your national insurance number;
• information about your benefits under the Scheme, including pensions and death benefits, together with corresponding details of assets, investments and insurance;
• your pensionable service;
• relevant employment information, such as current and past salary information, pensionable pay, employment dates, length of service, and career history (where relevant);
• details of your bank account (to pay benefits);
• details about your dependants and/or beneficiaries (including their names and possibly details of their gender);
• medical and other details about your health (to pay health related benefits); and
• details of any divorce sharing orders.
In order to properly administer the Scheme and to calculate and pay benefits, from time to time we may also need to hold other information about you.
How we gather your personal information
We gather personal information from several sources including the following:
• directly from you;
• from your current or former employer;
• from persons acting as personal representatives of a deceased person’s estate;
• from a public body such as HMRC;
• from public databases such as the Register of Births, Deaths and Marriages;
• from other pension schemes, where transfers into the Scheme have been made;
• from an independent financial adviser, solicitor or other person instructed by a person to provide us with information;
• from our advisers;
• from third parties used to trace members or beneficiaries with whom we have lost contact;
• with your consent, from a registered medical practitioner; and
• from other third parties including, for example, your next of kin or anyone else entitled to benefit from your membership of the Scheme.
How we use that information
The Trustee has a legitimate interest in holding and processing the above information about you as it is needed for us to properly administer the Scheme and to calculate and pay benefits. We also keep the above information to allow us to comply with our obligations towards members under the Scheme governing documents, as well as under relevant legislation. For example, the relevant legislation allows “sensitive personal data” to be processed in connection with employment, social security and social protection, and the Trustee may rely on this provision from time-to-time
Personal data relating to the Scheme is held on paper and on computer systems. As the “data controller”, the Trustee must process this information fairly and lawfully.
As part of running the Scheme, we may also need to hold and process particularly sensitive information about you and/or your dependants and beneficiaries (known as “sensitive personal data”). Under data protection legislation, details relating to health, racial or ethnic origin, religious or other similar beliefs, sexual orientation and political affiliations are regarded as “sensitive personal data”. Except where the legislation allows it, this information cannot be processed or passed to a third party without your explicit consent.
What else we might do with personal data
We may transfer, store, or process your personal data outside of the UK or the European Economic Area (“EEA”) (as applicable). Where this is the case, we will take reasonable steps to ensure that your personal data continues to be appropriately secured. This may include entering into data transfer agreements based on the model clauses approved by the European Commission or, where relevant, the UK, to ensure that third parties commit to ensuring an adequate level of protection for your personal data.
Who we share it with
We are not allowed to disclose personal data about you to other parties except:
• when required for contractual or legal reasons or other specifically identified purposes; or
• where you have given your consent.
However, as the Trustee needs help from various advisers to properly administer the Scheme, we share personal data with the following:
• your current, past or future employer, which may include group companies which are based outside the UK or EEA (as applicable). Where data is sent outside the UK or the EEA (as applicable), appropriate safeguards are put in place to ensure that your data is kept secure
• the employers’ payroll service providers
• the Scheme’s professional advisers, including the Scheme actuary, auditor, medical advisers, investment adviser and lawyers
• the third parties who are responsible for the day-to-day administration of the Scheme on behalf of the Trustee
• HM Revenue & Customs and other statutory bodies (such as the Pensions Ombudsman, the Pensions Regulator and the Department of Work and Pensions) – the Trustee can be fined and subject to other action if it fails to provide certain information to these authorities
• the advisers and printers who help us prepare various communications we send to you, such as the annual benefit statement and newsletters
• our appointed insurance company or companies for the purposes of life insurance and additional voluntary contributions and investments such as annuity purchases
• depending upon how we pay pensions, the personal data we have to supply in order to effect a BACS transfer (the Bankers' Automated Clearing Service) or CHAPS (the Clearing House Automated Payment System] in the UK and/or a payment via Western Union the administrators’ banking providers when pensions are being paid overseas
• tracing agencies when we have lost contact with members or beneficiaries and mortality screening services
• the trustee’s website service provider
• external IT support companies
How long we keep personal data for
We must keep all personal data safe and only hold it for as long as necessary. To meet the requirements of both UK tax and pensions law, we must keep certain personal data (for example, details about the date a member joins the Scheme, their name and address, and details of benefits paid) for a minimum of 6 years. However, given the nature of pension schemes, the Trustee may be required to keep some of your personal information for the rest of your life. If the Trustee concludes that certain personal data is no longer needed, that personal data will generally be destroyed.
Your rights
• Right of Access – You have the right request information about the processing of your personal data, to see personal data that is held about you and a right to have a copy provided to you, or someone else on your behalf, in a machine readable (namely, digital) format.
• Right to Rectification – If at any point you believe that the personal data we hold about you is inaccurate, you can ask to have it corrected.
• Right to Restrict processing – You can require the Trustee to limit the processing of your personal data in certain circumstances, for example, whilst a complaint about its accuracy is being resolved.
• Right to object to processing – As we are relying on legitimate interests as a reason for processing, you can object to your personal data being processed, although the Trustee can override this objection in certain circumstances.
• Withdrawing consent – Where you have given us your consent to processing your personal data, you can withdraw that consent at any time by notifying us (see “Who to contact about your personal data” below). However, withdrawing your consent will not affect the processing of any personal data which took place beforehand and it may be possible for the Trustee to continue processing your personal data where this is justified.
• Right to be forgotten – You can request that your personal data is deleted altogether, although the Trustee can override this request in certain circumstances.
• Right to complain – You have the right to complain to the Information Commissioner’s Office, or to bring an action before the court, if your personal data rights are not complied with (see “Making a complaint to the Information Commissioner’s Office” below).
You should be aware that taking any of the above steps could impact on the payment of your benefits, your participation in the Scheme, and/or our ability to answer questions relating to your benefits.
Information will generally be provided to you free of charge, although the Trustee can charge a reasonable fee in certain circumstances.
Who to contact about your personal data
If you wish to:
• see your personal data or to exercise any of the rights mentioned above
• request a hard copy of the notice
• make a complaint about how we have handled your personal data
please contact Kelly Capdeville either by email at group.pensions@magnoxsites.com or in writing, Oldbury Technical Centre, Oldbury Naite BS35 1RQ.
Making a complaint to the Information Commissioner’s Office
If you are not satisfied with our response to any query you raise with us, or you believe we are processing your personal data in a way which is inconsistent with the law, you can complain to the Information Commissioner’s Office whose helpline number is: 0303 123 1113.
Updates to this notice
This notice is the latest version as at January 2024. This notice will be updated from time to time and you can see the current version at any time on the Trustee’s website at https://my-magnox-pension.com/library/scheme-documents
Alternatively, if you would prefer to receive a hard copy of the notice, please let us know (see “Who to contact” above).
Appendix
Aon Solutions UK Limited/ the Group Actuary’s Privacy Notice
Aon Solutions UK Limited (and, where appointed, the Scheme Actuary - together "Aon") has been appointed to provide pensions advisory and calculation services that relate to your membership of the pension scheme. In doing so Aon will use personal information about you, such as your name and contact details, information about your pension contributions, age of retirement, and in some limited circumstances information about your health (where this impacts your retirement age) in order to be able to provide these services. The purposes for which we use personal information will include management of the pension scheme and your membership within it, funding the pension scheme (i.e. helping to ensure that the funds within the pension scheme are sufficient to cover the members who are party to it), liability management (that is to say providing advice on the different ways benefits could be determined, and drawn, from the pension scheme), scheme actuary duties (which include assessing individuals who are members of the pension scheme and assessing how the make-up of the membership may affect the amounts payable and when they become payable so as to manage the pension scheme appropriately), regulatory compliance, process and service improvement and benchmarking.
We may pass your personal information to third parties such as financial advisors and benefits providers, insurers, our affiliates and service providers and to certain regulatory bodies where legally required to do so. Depending on the circumstances, this may involve a transfer of data outside the UK and the European Economic Area to countries that have less robust data protection laws. Any such transfer will be made with appropriate safeguards in place.
More detail about Aon’s use of your personal information is set out in our full Privacy Notice. We recommend that you review this notice which is available online at https://www.aon.com/unitedkingdom/retirement-investment/retirement-investment-services-privacy-statement.jsp, or you can request a copy by contacting contact us, including reference to the scheme name, at: Data Protection Officer, Aon Solutions UK Limited (Retirement and Investment UK), PO Box 730, Redhill, RH1 9F
Magnox Electric Group Pension Trustee Co Ltd is the trustee (the “Trustee”) of the Magnox Group of the Electricity Supply Pension Scheme (the “Scheme”).
As the Trustee of the Scheme, we hold certain personal information (known as “personal data”) about scheme members and, where applicable, their dependants and beneficiaries. Most of the information held about you and processed by the Trustee in running the Scheme will be personal data (in other words, because we hold information from which you as an individual can be identified, any information we hold in respect of you will be subject to certain protections).
For legal purposes, the Trustee is known as the “data controller”, as we decide the purposes for and the means by which the personal data we hold is processed.
The Trustee’s actuarial advisers, currently Aon, are also data controllers in relation to some of your personal data that the Trustee holds. A short form privacy notice from Aon is contained in the Appendix to this Notice. This contains a link to Aon’s full privacy notice.
What information we collect about you
Depending on the circumstances and the stage of your membership, we may hold some or all of the following information about you:
• your name, date of birth, gender;
• your marital status;
• your address and other contact details (such as telephone number and email address);
• your national insurance number;
• information about your benefits under the Scheme, including pensions and death benefits, together with corresponding details of assets, investments and insurance;
• your pensionable service;
• relevant employment information, such as current and past salary information, pensionable pay, employment dates, length of service, and career history (where relevant);
• details of your bank account (to pay benefits);
• details about your dependants and/or beneficiaries (including their names and possibly details of their gender);
• medical and other details about your health (to pay health related benefits); and
• details of any divorce sharing orders.
In order to properly administer the Scheme and to calculate and pay benefits, from time to time we may also need to hold other information about you.
How we gather your personal information
We gather personal information from several sources including the following:
• directly from you;
• from your current or former employer;
• from persons acting as personal representatives of a deceased person’s estate;
• from a public body such as HMRC;
• from public databases such as the Register of Births, Deaths and Marriages;
• from other pension schemes, where transfers into the Scheme have been made;
• from an independent financial adviser, solicitor or other person instructed by a person to provide us with information;
• from our advisers;
• from third parties used to trace members or beneficiaries with whom we have lost contact;
• with your consent, from a registered medical practitioner; and
• from other third parties including, for example, your next of kin or anyone else entitled to benefit from your membership of the Scheme.
How we use that information
The Trustee has a legitimate interest in holding and processing the above information about you as it is needed for us to properly administer the Scheme and to calculate and pay benefits. We also keep the above information to allow us to comply with our obligations towards members under the Scheme governing documents, as well as under relevant legislation. For example, the relevant legislation allows “sensitive personal data” to be processed in connection with employment, social security and social protection, and the Trustee may rely on this provision from time-to-time
Personal data relating to the Scheme is held on paper and on computer systems. As the “data controller”, the Trustee must process this information fairly and lawfully.
As part of running the Scheme, we may also need to hold and process particularly sensitive information about you and/or your dependants and beneficiaries (known as “sensitive personal data”). Under data protection legislation, details relating to health, racial or ethnic origin, religious or other similar beliefs, sexual orientation and political affiliations are regarded as “sensitive personal data”. Except where the legislation allows it, this information cannot be processed or passed to a third party without your explicit consent.
What else we might do with personal data
We may transfer, store, or process your personal data outside of the UK or the European Economic Area (“EEA”) (as applicable). Where this is the case, we will take reasonable steps to ensure that your personal data continues to be appropriately secured. This may include entering into data transfer agreements based on the model clauses approved by the European Commission or, where relevant, the UK, to ensure that third parties commit to ensuring an adequate level of protection for your personal data.
Who we share it with
We are not allowed to disclose personal data about you to other parties except:
• when required for contractual or legal reasons or other specifically identified purposes; or
• where you have given your consent.
However, as the Trustee needs help from various advisers to properly administer the Scheme, we share personal data with the following:
• your current, past or future employer, which may include group companies which are based outside the UK or EEA (as applicable). Where data is sent outside the UK or the EEA (as applicable), appropriate safeguards are put in place to ensure that your data is kept secure
• the employers’ payroll service providers
• the Scheme’s professional advisers, including the Scheme actuary, auditor, medical advisers, investment adviser and lawyers
• the third parties who are responsible for the day-to-day administration of the Scheme on behalf of the Trustee
• HM Revenue & Customs and other statutory bodies (such as the Pensions Ombudsman, the Pensions Regulator and the Department of Work and Pensions) – the Trustee can be fined and subject to other action if it fails to provide certain information to these authorities
• the advisers and printers who help us prepare various communications we send to you, such as the annual benefit statement and newsletters
• our appointed insurance company or companies for the purposes of life insurance and additional voluntary contributions and investments such as annuity purchases
• depending upon how we pay pensions, the personal data we have to supply in order to effect a BACS transfer (the Bankers' Automated Clearing Service) or CHAPS (the Clearing House Automated Payment System] in the UK and/or a payment via Western Union the administrators’ banking providers when pensions are being paid overseas
• tracing agencies when we have lost contact with members or beneficiaries and mortality screening services
• the trustee’s website service provider
• external IT support companies
How long we keep personal data for
We must keep all personal data safe and only hold it for as long as necessary. To meet the requirements of both UK tax and pensions law, we must keep certain personal data (for example, details about the date a member joins the Scheme, their name and address, and details of benefits paid) for a minimum of 6 years. However, given the nature of pension schemes, the Trustee may be required to keep some of your personal information for the rest of your life. If the Trustee concludes that certain personal data is no longer needed, that personal data will generally be destroyed.
Your rights
• Right of Access – You have the right request information about the processing of your personal data, to see personal data that is held about you and a right to have a copy provided to you, or someone else on your behalf, in a machine readable (namely, digital) format.
• Right to Rectification – If at any point you believe that the personal data we hold about you is inaccurate, you can ask to have it corrected.
• Right to Restrict processing – You can require the Trustee to limit the processing of your personal data in certain circumstances, for example, whilst a complaint about its accuracy is being resolved.
• Right to object to processing – As we are relying on legitimate interests as a reason for processing, you can object to your personal data being processed, although the Trustee can override this objection in certain circumstances.
• Withdrawing consent – Where you have given us your consent to processing your personal data, you can withdraw that consent at any time by notifying us (see “Who to contact about your personal data” below). However, withdrawing your consent will not affect the processing of any personal data which took place beforehand and it may be possible for the Trustee to continue processing your personal data where this is justified.
• Right to be forgotten – You can request that your personal data is deleted altogether, although the Trustee can override this request in certain circumstances.
• Right to complain – You have the right to complain to the Information Commissioner’s Office, or to bring an action before the court, if your personal data rights are not complied with (see “Making a complaint to the Information Commissioner’s Office” below).
You should be aware that taking any of the above steps could impact on the payment of your benefits, your participation in the Scheme, and/or our ability to answer questions relating to your benefits.
Information will generally be provided to you free of charge, although the Trustee can charge a reasonable fee in certain circumstances.
Who to contact about your personal data
If you wish to:
• see your personal data or to exercise any of the rights mentioned above
• request a hard copy of the notice
• make a complaint about how we have handled your personal data
please contact Kelly Capdeville either by email at group.pensions@magnoxsites.com or in writing, Oldbury Technical Centre, Oldbury Naite BS35 1RQ.
Making a complaint to the Information Commissioner’s Office
If you are not satisfied with our response to any query you raise with us, or you believe we are processing your personal data in a way which is inconsistent with the law, you can complain to the Information Commissioner’s Office whose helpline number is: 0303 123 1113.
Updates to this notice
This notice is the latest version as at January 2024. This notice will be updated from time to time and you can see the current version at any time on the Trustee’s website at https://my-magnox-pension.com/library/scheme-documents
Alternatively, if you would prefer to receive a hard copy of the notice, please let us know (see “Who to contact” above).
Appendix
Aon Solutions UK Limited/ the Group Actuary’s Privacy Notice
Aon Solutions UK Limited (and, where appointed, the Scheme Actuary - together "Aon") has been appointed to provide pensions advisory and calculation services that relate to your membership of the pension scheme. In doing so Aon will use personal information about you, such as your name and contact details, information about your pension contributions, age of retirement, and in some limited circumstances information about your health (where this impacts your retirement age) in order to be able to provide these services. The purposes for which we use personal information will include management of the pension scheme and your membership within it, funding the pension scheme (i.e. helping to ensure that the funds within the pension scheme are sufficient to cover the members who are party to it), liability management (that is to say providing advice on the different ways benefits could be determined, and drawn, from the pension scheme), scheme actuary duties (which include assessing individuals who are members of the pension scheme and assessing how the make-up of the membership may affect the amounts payable and when they become payable so as to manage the pension scheme appropriately), regulatory compliance, process and service improvement and benchmarking.
We may pass your personal information to third parties such as financial advisors and benefits providers, insurers, our affiliates and service providers and to certain regulatory bodies where legally required to do so. Depending on the circumstances, this may involve a transfer of data outside the UK and the European Economic Area to countries that have less robust data protection laws. Any such transfer will be made with appropriate safeguards in place.
More detail about Aon’s use of your personal information is set out in our full Privacy Notice. We recommend that you review this notice which is available online at https://www.aon.com/unitedkingdom/retirement-investment/retirement-investment-services-privacy-statement.jsp, or you can request a copy by contacting contact us, including reference to the scheme name, at: Data Protection Officer, Aon Solutions UK Limited (Retirement and Investment UK), PO Box 730, Redhill, RH1 9F
