Police staff pensions privacy notice
This privacy notice is aimed at police staff 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 data controller of this data.
The North Yorkshire County Council (NYCC) is an administering authority under the Local Government Pension Scheme (LGPS), and it manages and administers the North Yorkshire Pension Fund (NYPF) for North Yorkshire Police Staff. The NYCC is a data controller for the copies of your personal data they hold. The Chief Constable of North Yorkshire Police and NYCC are separate and independent data controllers.
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 such as your title, name and address, email address and telephone numbers;
- Identifying details such as your date of birth and national insurance number;
- Date you joined and left the fund;
- Information used to assess your eligibility for benefits, such as your employer, job title and post;
- Financial information such as your salary, contribution rate and hours;
- Information about your family, dependants or personal circumstances, for instance marital status and information relevant to the appointment of a beneficiary;
- Information relating to your physical or mental health which may be used for payment of ill-health retirement benefits; and
- Any other information relevant and necessary to carrying out our functions for the purpose of administering pensions.
We obtain information from employers and pension scheme members. Pension scheme members are asked to provide personal data such as bank account details for pension payments, and evidence to prove age and marital status.
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 legislation.
Where you have provided us with personal data about other individuals, such as family members, dependants or potential beneficiaries, please ensure that those individuals are aware of the information contained within this notice.
North Yorkshire Police will use the minimum amount of personal information necessary to carry out a particular activity.
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:
- It is necessary for the performance of a contract (employment contract);
- It is necessary for the carrying out of obligations and exercising specific rights of the data controller or of the data subject in the field of employment;
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 engage with third party processors who handle some, or all, of the above mentioned information on our instruction.
The Chief Constable of North Yorkshire Police is under a statutory obligation to share your name, gender, date of birth, national insurance number, pensionable pay, employer and employee pension contributions, details of any additional pension contributions and additional voluntary contributions with the NYCC annually. We will notify NYCC if an error is discovered in your personal data to enable the correction of records. We may also share data as part of participate in National Fraud Initiative exercises.
In order to meet their statutory obligations, the NYPF may further share your information with, or disclose the information to, other agencies. These include;
- Consultants for the purpose of calculating the scheme’s assets and liabilities to set employer contribution rates, specific benefits, and to advise on scheme administration functions;
- Additional voluntary contributions scheme providers to facilitate the creation and maintenance of individual member’s additional voluntary contributions;
- Overseas payment providers to transmit payments to scheme members with a non-UK bank account;
- The LGPS national insurance database to enable the NYPF to identify whether its members have benefits in other LGPS schemes;
- Department for Work and Pensions and ATMOS (Life existence checks) to enable the NYPF to be notified of the death of a scheme member;
- Any other authorities involved in the administering of the pensions.
The NYPF is also required by law to share your information with government organisations such as Her Majesty’s Revenue and Customs (HMRC) and the Department for Work and Pensions (DWP) in certain circumstances, so that they can monitor their performance and ensure that public funds are safeguarded.
The NYPF will share your data with any persons connected with any transfer of employment under TUPE (Transfer of Undertakings (Protection of Employment) regulations) that results in a transfer out of this scheme to another pension scheme.
Where there are arrangements to share your personal data, there is a contract, memorandum of understanding or information sharing agreement in place to ensure that the requirements of the Data Protection legislation on handling personal information are met. Where information is required to be disclosed by law, for example for safeguarding purposes, sharing may take place without these arrangements.
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?
North Yorkshire Police keeps your personal information as long as is necessary for the particular purpose, or purposes, for which it is held.
Records that contain your personal information processed for “general data” purposes will be managed in accordance with the Force’s Retention Schedule.
In order to make pension payments to members and subsequent beneficiaries, the NYPF retains a member’s data for 100 years following the death of the last beneficiary.
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.
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 6 November 2019.