Police officer pensions privacy notice
This privacy notice relates to Police Officer Pensions and is aimed at members and beneficiaries of Police Pension Schemes.
The Chief Constable of North Yorkshire Police is committed to protecting your personal information.
This Privacy Notice contains important information about what personal details we collect; what we do with that information; who we may share it with and why; and your choices and rights when it comes to the personal information you have given to us.
We may need to make changes to our Privacy Notice, so please check our website for updates from time to time. If there are important changes such as changes to where your personal data will be processed, we may need to contact you to let you know.
Who we are?
This Privacy Notice is provided to you by the Chief Constable of North Yorkshire Police who is the Police Pension Scheme Manager and data controller of this data.
Your personal data – what is it?
“Personal data” is any information about a living individual which allows them to be identified. Identification can be directly using the data itself, or by combining it with other information which helps to identify a living individual. The processing of personal data is governed by legislation relating to personal data which applies in the United Kingdom including the General Data Protection Regulation (the “GDPR”) and the Data Protection Act 2018, and other legislation relating to personal data and rights, such as the Human Rights Act.
The data we may collect about you:
Personal Data that we may collect includes:
- 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 Scheme; and
- Information about a criminal conviction where this may result in pension forfeiture.
We obtain some of this personal data directly from you. We may also obtain data (for example, salary information) from your current or past employer(s), from a member of the Scheme (where you are or could be a beneficiary of the Scheme as a consequence of that person’s membership of the Scheme) and from a variety of other sources including public databases (such as the Register of Births, Deaths and Marriages), our advisers and government or regulatory bodies.
Where we obtain information concerning certain “special categories” of particularly sensitive data, such as health information, extra protections apply under the data protection legislation. We will only process your personal data falling within one of the special categories 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 Police Pension Authority in writing. However, if you do not give consent, or subsequently withdraw it, the Police Pension Authority may not be able to process the relevant information to make decisions based on it, including decisions regarding 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, please ensure that those individuals are aware of the information contained within this notice.
What is the legal basis for processing your personal data?
The Chief Constable of North Yorkshire Police may process personal data for the following reasons:
- To process your personal data to satisfy their legal obligations as Scheme Manager in managing and administering pensions;
- To process your personal data to carry out a task in the public interest;
- For the legitimate interests of administering and managing the Scheme 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; and
- To meet a contractual obligations to you in relation to the Scheme (for example, under an agreement that you will pay additional voluntary contributions), or to take steps, at your request, before entering into a contract.
The Data Controller will comply with data protection law. This says that the personal data we hold about you must be:
- Used lawfully, fairly and in a transparent way;
- Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes;
- Relevant to the purposes we have told you about and limited only to those purposes;
- Accurate and kept up to date;
- Kept only as long as is necessary for the purposes we have told you about;
- Kept and destroyed securely, including ensuring that appropriate technical and security measures are in place to protect your personal data and to protect personal data from loss, misuse, unauthorised access and disclosure.
Sharing your personal data:
We may engage the services of advisers and service providers to carry out our duties, rights and discretions in relation to the Pensions Scheme.
Some of those organisations will simply process your personal data on our behalf and in accordance with our instructions; for example; accountants; overseas payment providers to transmit payments to scheme members with non-UK accounts; and printing companies. Other organisations will be responsible to you directly for their use of personal data that we share with them. These include additional voluntary contribution providers; legal advisers; and external and internal auditors.
We may share pensioner information with NARPO for the legitimate interests of administering and managing the Scheme. The actions undertaken by NARPO will uphold NYP’s duty of care to its retired Officers by supporting their wellbeing.
We may also share data as part of participate in National Fraud Initiative exercises.
Where we have these arrangements, there is always a contract, memorandum of understanding or information sharing agreement in place to ensure that the requirements of the GDPR on handling personal information are met.
Where requested or if we consider that it is reasonably required, we may also provide your data to government bodies and dispute resolution and law enforcement organisations, including those listed above, the Pensions Regulator, the Pensions Ombudsman and Her Majesty’s Revenue and Customs (HMRC). They may then use the data to carry out their functions.
Where we are required to disclose information by law, for example for safeguarding purposes, we may do so without these arrangements.
We engage with third party processors who handle some, or all, of the above mentioned information on our instruction.
NYP will take steps to ensure any disclosures of personal data are necessary and proportionate, as required by law. Whenever we share your personal information, sharing options will be evaluated to ensure that your data is shared in the most secure manner.
How do we keep your personal information secure?
We are committed to ensuring that your personal data is safe and processed securely. In order to prevent your personal data from being accidentally lost, used or accessed in an unauthorised manner, altered or disclosed, we have put in place suitable physical, electronic and managerial measures. These include information security awareness training for our staff. We have also compiled procedures to safeguard and secure the information that we hold about you which our staff adhere to.
We limit the access to your personal information to those employees who have a business need to know, for instance through secure work areas and access controls on all of our systems. Employees, contractors and other third parties who handle personal data will only process your personal information in line with our direct instructions.
How long do we keep your personal information?
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 it may be required to deal with any questions or complaints that we may receive about our administration of the Scheme. This is in line with the Force’s Retention Schedule.
If we elect to retain your data for a longer period to comply with our legal and regulatory obligations, 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 Scheme and for a period of 15 years 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 Scheme in respect of your benefit entitlement.
Administration of the Scheme for recipients living outside of the European Economic Area (EEA)
In some cases recipients of your personal data may be outside the UK. This means your personal data may be transferred outside the European Economic Area (EEA) to a jurisdiction that may not offer an equivalent level of protection as is required by EEA countries. If this occurs, we are obliged to verify that appropriate safeguards are implemented with a view to protecting your data in accordance with applicable laws. Please use the contact details below if you want more information about the safeguards that are currently in place.
Your rights and personal data:
A key area of change in the new Data Protection Act relates to individuals’ rights. The law refreshes existing rights by clarifying and extending them and introduces new rights.
However your information rights will be dependent on the reason why the data was collected, how the data was collected and why it is being used.
Further information about your rights can be found on the Your Data Rights page.
The organisations referred to in “sharing your personal data” may use the personal data to perform their functions in relation to the Scheme as well as for statistical and financial modelling (such as calculating expected average benefit costs and mortality rates) and planning, business administration and regulatory purposes. They may also pass the data to other third parties to the extent they consider the information is reasonably required for a legitimate purpose.
If we wish to use your personal data for a new purpose, not covered by this Privacy Notice, we may provide you with a new notice explaining this new use and setting out the relevant purposes and processing conditions, prior to commencing the processing. We will seek your prior consent to the new processing if this is appropriate.
Details as to how we can be contacted as well as how you can submit a complaint is available on our website: https://northyorkshire.police.uk/access-to-information/data-protection/
This version of our Privacy Notice was last updated on 12 February 2020.