Information

Privacy

This article outlines how ‚Äčthe Trustee and RPMI will use your data and your rights under the new General Data Protection Regulation (GDPR) which comes into force from 25 May 2018.

Background

In the UK, data protection law is currently covered under the Data Protection Act 1998 (DPA 1998). However, a new EU data protection law called The General Data Protection Regulation (GDPR) will apply from 25 May 2018. This new law was deemed necessary to take into account technology changes over the last 20 years and to harmonise data protection law across Europe. 

How we use information about you

We, the Railways Pension Trustee Company Limited and RPMI Limited (each with its registered address at 7th Floor, Exchange House, 12 Exchange Square, London, EC2A 2NY), currently handle personal information in compliance with the Data Protection Act 1998. From May 2018, we will be required to comply with the General Data Protection Regulation (GDPR).

Each of the Railways Pension Trustee Company Limited and RPMI Limited is a “data controller” in respect of your personal information for the purposes of applicable data protection legislation. If there is a Pensions Committee for your section, it will also comply with the data protection legislation. 

We will use your personal details in order to deal with and pay any benefits you may be entitled to under the rules of the Railways Pension Scheme, The BT Police Superannuation Fund, The British Railways Superannuation Fund, or any other pension fund administered by RPMI.

Purpose of using information

We process information or data for the reasons/purposes mentioned above. This information may include:

  • personal details
  • family, lifestyle and social circumstances
  • financial details
  • employment and education details
  • goods or services provided 

We may also need to process sensitive classes of information, such as physical or mental health details, in order to administer ill- health retirement payments and applications

This information may be obtained from your employer, ex-employer, government agencies, service providers or from yourself.

We will only collect and use your personal information where:

  • there is a legal obligation for us to do so;
  • it is for our legitimate business interests; or
  • you have given us your consent to do so.
Our legitimate business interests include fulfilling our role in dealing with, assessing eligibility for and paying any benefits you may be entitled to. We will not use your data for our legitimate business interests if they are overridden by your interests, rights or freedoms.  
You do not have to provide the information requested from you, but there may be a delay in the payment of your benefits if that information is not provided.

If we are processing your data on the basis of your consent, you can withdraw your consent at any time by contacting RPMI’s Data Protection Officer (full details in the Your Rights section). The withdrawal of consent will not affect the processing of personal data carried out before consent was withdrawn.

Who the information may be shared with

From time to time, we may need to share your information with other organisations. Where this is necessary, we are required to comply with all aspects of the DPA 1998 and, from 25 May 2018, the GDPR. The types of organisations we may need to share some of your information with are: 

  • claimants,  beneficiaries, assignees and payees
  • pension schemes with which the person whose personal information we are processing has an association
  • trade and business associates and professional advisers
  • healthcare, social and welfare organisations
  • financial organisations and advisers
  • central and local government
  • service providers
  • ombudsmen and regulatory authorities
  • suppliers
  • family, associates or representatives of the person whose personal data we are processing
  • tracing agencies

Retention of data

One of the key principles of the DPA 1998 and the GDPR is that the personal data we store and process shall be adequate, relevant and limited to what is necessary for the purpose it was originally collected. Our standard policy is for information or data to be kept for only as long as necessary. It is then disposed of in a managed and secure way. However, as pensions are a long-term saving vehicle, it may be necessary to retain your personal data for the remainder of your life and any dependants’ lives in order to pay you the benefits you are entitled to, along with any dependant’s benefits payable.

Transferring data overseas

Our core systems, data, and administration services are all carried out and stored within the UK. 

However, TCS an international multinational information technology service, based in India, provides maintenance support. Therefore, on rare occasions it may be necessary to transfer your data overseas to TCS.

Transferring personal data to a country outside the European Economic Area that does not have adequate data protection is prohibited unless the country has been approved by the European Commission as providing an adequate level of data protection or adequate safeguards have been put in place to ensure the security of the data. 

As India is currently not on the European Commission’s list of countries providing adequate data protection, the Railways Pension Trustee Company Limited and RPMI Limited have taken steps to put in place appropriate and suitable safeguards. RPMI and TCS have entered into a data protection contract using standard clauses adopted by the EU Commission (so-called ‘model clauses’). These contain enforceable data subject rights and effective legal remedies for data subjects against TCS. A copy of these are available upon request at the address ‚Äčin the Your Rights section.

If, at any time, we propose to use your personal data for any other reason than outlined, we will provide you with further details as to why and for what reason we intend to do so.

Your rights

You will have a number of rights under the GDPR. These include the right to:

  • see the information we hold about you:
  • request personal data to be amended if it is inaccurate or incomplete;
  • request the deletion or removal of personal data where there is no compelling reason for its continued use;
  • block or restrict the processing of your personal data; and
  • object to the processing of your personal data. 

There is also a right under the GDPR to receive your personal data (in a structured, commonly used and machine-readable format) and to transfer your data to another service provider or data controller. This right applies where your data is being processed on the basis of your consent or in line with a contract to which you are party. Please note that, for the majority of members, this is not applicable as we rely on our legitimate business interest to collect and process your data rather than individual consent or contracts.

If you wish to exercise any of your rights or have concerns about the processing of your personal data or wish to raise any issues in relation to data protection, including in relation to the use of it by Railways Pension Trustee Company Limited, RPMI Limited or the Pensions Committee for your Section, please contact the Data Protection  Officer at RPMI.

The Data Protection  Officer is: 

Mark Beck
RPMI
Stooperdale Offices

Brinkburn Road
Darlington
County Durham
DL3 6EH
Tel: 0800 2 343434
Email: csu@rpmi.co.uk

If you are acting on behalf of a child, we may also hold and use your personal information, which will be dealt with on the same basis as set out earlier.

If you are unhappy with how your personal information is being handled, you also have the right to make a complaint to the Information Commissioner’s Office, an independent body set up to uphold information rights, which will investigate your complaint.