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Data protection and your personal information
How we use your personal information
The Trustee needs to hold and process information about you, your dependants and your beneficiaries to administer the Scheme. This privacy notice explains how the Trustee uses and holds your personal information. This includes what you tell us about yourself and what we learn through discussions or correspondence with your dependants, relatives, your employer or others. This notice also tells you about your privacy rights and how the law protects you.
Data protection law says that we are allowed to use personal information only if we have a proper reason to do so. This includes sharing it outside the Trustee. The law says we must have one or more of these reasons:
- When it is to fulfil a legal obligation to which we are subject, or
- When it is in our legitimate interest, or
- When you consent to it.
The legitimate interests mentioned above include serving you as a member of the Scheme, which includes:
- Calculating and paying the correct benefits to you or your beneficiaries on time,
- Carrying out your instructions such as changes to investment choices or contributions/additional voluntary contributions, where applicable,
- Keeping your Scheme benefits safe,
- Responding to communications and queries appropriately, and;
- Minimising any disruption if there is a change to the Scheme or the Trustee.
The law and other regulations treat some types of sensitive personal information as special. This includes information about racial or ethnic origin, political opinions, sexual orientation, religious or philosophical beliefs, trade union membership, genetic or biometric data, or health data. Where we are required to process these special types of data, we will approach you or the relevant individuals for specific explicit consent to the processing of such data, unless there are other legal reasons for processing such data.
The Trustee needs to hold and process your personal information in order to administer your benefits under the Scheme; for example, to calculate and pay your benefits, for statistical and reference purposes, and in connection with the administration of the Scheme as a whole. The Trustee may also use your personal information for other purposes, including to process Trustee nominations, to comply with any present or future law or guidance in connection with any valuation, sale, merger, acquisition, disposal or similar activity involving the Scheme, and may transfer personal information to the Group for the Group to use in connection with employee tax or reward matters.
We use many different kinds of personal information. The table below sets out the different types of personal information we use and a non-exhaustive list of some examples of the types of information that may fall within each of these categories.
|Type of personal information||Description|
|Personal||Your name, gender, age, date of birth, date joined Scheme, Scheme retirement date.|
|Contact||Where you live and how to contact you including email address if provided.|
|Family/lifestyle||Where relevant, details of current and previous marriages and partnerships, family and dependants and your preferred beneficiaries for death benefits. Pension sharing order details.|
|Financial||Investment choices (if applicable), bank account details for the receipt of Scheme benefit payments.|
|Employment||Details about pensionable pay, length of service (including date commenced and date left service if applicable), usual place of employment.|
|Technology||Details on the devices and technology you use and information about your visits to our website – you can find more information about this below.|
|Documentary data||Details from certain documents or copies of them as proof of identity and key dates, which could include passport, driving licence, birth certificate and marriage certificate.|
|Special categories of personal data||Information about your physical or mental health in support of applications to take incapacity benefits and any subsequent reviews thereof.|
|Consents||Any permissions, consents, or preferences that you give us.|
|National identifier||A number or code given to you by a government to identify who you are, such as a National Insurance or a social security number.|
|Employee identifier||A number or code given to you by your employer to identify who you are, such as an employee number.|
When you visit our website we may collect technical information about you such as the devices or technology you use or information about your visit.
We may share your personal information with third parties in accordance with our policies and procedures. These third parties comprise any of the following:
- The Scheme’s administrators, sponsoring and participating employers.
- Our service providers and advisers, which can include the Scheme’s auditor, actuary, legal advisers and annuity broker where applicable.
- The trustees of any other Lloyds Banking Group pension scheme under which you are a beneficiary or any third parties providing services connected to the administration of the schemes (for example insurers and pension scheme administrators).
- Regulators and government bodies.
- Courts, tribunals and arbitrators or other judicial committees.
- Insurance companies and brokers.
Certain service providers and advisers may also be data controllers in relation to your personal information and have to comply with their own legal obligations, industry codes and standards when processing your data. Further information on third parties acting as data controllers in relation to your personal information and information on where to find their data protection information can be found below.*
We may also share your personal information if the Scheme or the Trustee changes in the future. During any such process, we may share your data with advisers. We’ll only do this if they agree to keep your data safe and private.
If a change to the Trustee happens, then other parties may use your data in the same way as set out in this notice.
Where appropriate, we will enter into a written agreement with the recipient which commits them to appropriate safeguards in relation to the handling of your personal information.
If we transfer information to our agents or advisers outside of the EEA, we will make sure that it is protected in the same way as if it was being used in the EEA. We’ll use one of these safeguards:
- Transfer it to a non-EEA country with privacy laws that give the same protection as the EEA. Learn more on the European Commission Justice website.
- Put in place a contract with the recipient that means they must protect it to the same standards as the EEA. Read more about this on the European Commission Justice website.
We will retain your personal data for as long as you are a member of the Scheme or you or your beneficiaries are in receipt of benefits from the Scheme. We may continue to hold and process your personal data after your death, to the extent that is necessary to do so in order to administer benefits payable to your spouse, dependants or other beneficiaries. We may also retain your personal data after you or your beneficiaries have ceased to be entitled to benefits from the Scheme for as long as is necessary for us to fulfil the purposes for which we collected it, including satisfying any legal, accounting or reporting requirements. We review the personal data held in relation to the Scheme on a regular basis and if we conclude that certain personal data is no longer needed, that personal data will generally be destroyed.
We will take appropriate legal, organisational and technical measures to protect your information consistent with applicable data protection and privacy laws.
You have the right of access to your personal data as well as information regarding the processing of your personal information. You also have the right to obtain and reuse your personal information for your own purposes across different services. For more details on how to request a copy of your information please email us.
You have the right to request the rectification of your personal information. We ask you to update your details yourself if you change things like your contact details, address or bank account. You should also do this if you think something is wrong or incomplete.
If you are still employed within Lloyds Banking Group, you can change most of your personal details on HR Online. If you are no longer employed within the Group, you can change your details on Your Pension.
You have the right to object to our use of your personal information in certain circumstances. This is known as the ‘right to object’.
You can also ask us to delete, remove, or stop using your personal information if there is no need for us to keep it. This is known as the ‘right to erasure’, or the ‘right to be forgotten’.
There may be legal or other official reasons why we need to keep or use your data. But please tell us if you think that we should not be using it.
We may sometimes be able to restrict the use of your data. This means that it can only be used for certain things, such as legal claims or to exercise legal rights. In this situation, we would not use or share your information in other ways while it is restricted.
You can ask us to restrict the use of your personal information if:
- It is not accurate.
- It has been used unlawfully but you don’t want us to delete it.
- It is not relevant any more, but you want us to keep it for use in legal claims.
- You have already asked us to stop using your data but you are waiting for us to tell you if we are allowed to keep on using it.
Please contact us if you want to object to how we use your data, or ask us to delete it or restrict how we use it.
Please contact us if you want more information about the way we use your personal information.
You also have the right to complain to the relevant data protection authority, or to a court of law, if your privacy rights are violated. You may be entitled to claim compensation for damages or distress incurred or suffered in consequence of unlawful processing of your personal information.
Find out on the ICO website how to report a concern.
* The following parties are also data controllers in relation to your personal information and have to comply with their own legal obligations, industry codes and standards when processing your data. We review the controller’s links periodically, but they are maintained and updated by the actual controllers:
- Willis Towers Watson – Actuarial Services
- Allen & Overy
- Law Debenture
- Hargreaves Lansdown
- Aon Hewitt