West Yorkshire Pension Fund Privacy Notice

City of Bradford Metropolitan District Council (CBMDC) is registered with the information Commissioner's Office (ICO) under the provisions of the Data Protection Act 2018. The Council takes its responsibilities under the Act very seriously. This notice provides details of how CBMDC collects and uses information about you. For more general information about how CBMDC uses your information, please refer to the general Privacy Notice on CBMDC website. 

What is this information?

Over the course of your pension scheme membership, WYPF will collect the following information:

• name
• National Insurance number
• gender
• marital status
• date of birth
• contact details – address, telephone number, email
• pay reference
• employer
• job title
• date joined
• hours of employment
• pay
• pension contributions paid
• rank (if in the Firefighters’ pension scheme)
• date left
• reason for leaving
• bank details for pensioners and beneficiaries
• dependants and next of kin details
• death grant nominations
• details of other private pensions

Who uses this information?

West Yorkshire Fund use this information.  It may also be used by your employer and other organisations where it is legal to do so.  Not all of the information we collect about you will be shared with these organisations. See the section on ‘Who are we likely to share this information with?’

What authority does CBMDC have to collect and use this information?

The Fund has a legal obligation and a statutory duty to provide individuals with certain information under a number of regulations, including:

• The Occupational and Personal Pension Schemes (Disclosure of Information) Regulations 2013
• The Pensions Act 2011 (Transitional, Consequential and Supplementary Provisions) Regulations 2014
• The Occupational and Personal Pension Schemes (Disclosure of Information) Amendment Regulations 2015
• The LGPS Regulations 2013
• The Public Service Pensions Act 2013
• The Pensions Act 2004

What is ‘person identifiable data’?

The term ‘person identifiable data’ relates to any data that could potentially identify a specific individual. The following fields in West Yorkshire Pension Fund are classified as person identifiable: Name, age, address, postcode, place of birth, date of birth, gender, national insurance number, employer, date employment started, date retired, date left pension scheme, any information about an individual that can be used directly, or in connection with other data, to identify, contact or locate that person.

Why do we use this information?

We use this information to ensure that the Fund pays the correct amount of pension benefits to scheme members and their beneficiaries.

Who are we likely to share this information with?  

Type of service/advisor	Name of body/organisation	Reasons for sharing the personal data
Employer	Your employer whilst you were in the pension scheme.	We hold these details on computer so employers can use some of this data, eg. To check the accuracy of the information held, to produce retirement estimates, but only for their own employees. They cannot see the details of any death grant nominations.
Scheme Actuary	Aon	To calculate the value of the Fund's assets and liabilities based on its membership profile and to set employer contribution rates based on that information.
Scheme AVC Provider*	Prudential/Scottish Widows/Utmost Life and Pensions	To facilitate the creation and maintenance of individual member's AVC accounts
Scheme Auditor	Mazars LLP	To facilitate the statutory duty of auditing the Fund's Annual Report and Statement of Accounts and internal controls
LGPS National Insurance Database	South Yorkshire Pension Authority	To enable the Fund to identify if their members have benefits in other LGPS schemes to ensure that appropriate benefits are paid.
DWP Tell Us Once Service	Department for Work and Pensions	To enable the Fund to be notified of the death of a scheme member
Regulators, the government, law enforcement bodies including local and foreign courts, tribunals and arbitrators.	National Fraud Initiative Government Actuary Department The Pensions Regulator The Scheme Advisory Board	To comply with the Fund's statutory duty in the management and administration of benefits, this includes participation in the Cabinet Office's National Fraud Initiative for the purposes of the prevention and detection of fraud against the Fund and organisations within the public sector and the Government Actuary's department for the calculation of the triennial assessment of the cost of the Local Government Pension Scheme on a national basis as per the Public Service Pensions Act 2013.
The Fund's software provider for its pension administration system	Civica	To provide software management support in the delivery of the Fund's electronic pension case management and benefit calculation system.
Banking Services	HSBC	To enable the Fund to pay pensions to retired members and beneficiaries.
Mortality and lost contact tracing services	Accurate Data/Experian/Lexis Nexis	To enable the Fund to trace members who have we have lost contact with because correspondence has been returned from their last known address or their pension has been returned by the bank.
Voluntary deductions from pensions	Various	To enable the Fund to pay over deductions made from pensions to organisations such as hospital funds, charities, sporting clubs or organisations etc.
Printing	Various – using Bradford Council's framework contract	The enable the Fund to print letters payslips, annual benefit statements and newsletters to send to scheme members.

How do we keep this information secure?

We have appropriate security measures in place to prevent personal information from being accidentally lost, used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security incidents and we will notify you and the appropriate regulator of any incident where we are legally required to do so.

How long do we keep this information?

The Fund, in providing statutory duties under the regulations has determined that it cannot permanently delete a member's record. Member details and documentation are required to be retained to enable the Fund to comply with statutory and legal obligations. However, if a request is made to delete member details or documentation, it will be considered on a case-by-case basis.

Rights for individuals under GDPR

• Find out about the rights for individuals under GDPR

What are your rights?

Please contact the Corporate Information Governance Team at dpo@bradford.gov.uk to exercise any of your rights, or if you have a complaint about why your information has been collected, how it has been used or how long we have kept it for.

You can contact our Data Protection Officer at dpo@bradford.gov.uk  or write to: Data Protection Officer, City Hall, Centenary Square, Bradford, BD1 1HY.

The UK GDPR also gives you the right to lodge a complaint with the Information Commissioners Office who are the supervisory authority responsible to regulate and monitor the legislative obligations  within the UK and can be contacted on 03031 231113.