Pensions Schemes Data Privacy Notice
Who is collecting the data?
Your personal data is being collected by the trustees (the “Trustees”) of the following schemes, collectively referred to as the “Schemes”.
- An Post Superannuation Scheme
- An Post Spouses’ and Children’s Scheme
- An Post and An Post Trade Union Group AVC Scheme
The Trustees, as the data controller, are required by the European General Data Protection Regulation (GDPR) to notify you about the collection, storing, use, disclosure, transfer and disposal (collectively known as “processing”) of personal information (or data) relating to you.
What data is being collected?
The Trustees retain personal data about you to manage and administer the Schemes, including your entitlements under the Schemes, and all related activities.
The personal information about you is normally obtained from you or your employer. The data which will be collected includes:
- Personal details such as name (including former names), date of birth, sex, contact details (e.g. home address and former addresses, telephone numbers and e-mail address) and identifiers such as PPS number;
- Employment and pension scheme membership details such as dates of joining and leaving employment (including reason for leaving, where relevant to benefit calculations) and (if applicable) employment history (eg whether part-time or full-time, periods of absence which impact on your scheme service and job title), periods of pensionable service, purchased notional service, transferred service, earnings and details of other benefits, added professional years, paid marriage gratuity and severance;
- Employment and pension scheme membership details (if applicable) in relation to other public body service such as dates of joining and leaving employment (including reason for leaving, where relevant to benefit calculations) and employment history (eg whether part-time or full-time, periods of absence and job title), periods of pensionable service, earnings and details of other benefits;
- Details of pension contributions and benefits, such as compulsory and voluntary contributions, actual or potential defined benefits and defined contribution account information (eg investment allocation and account balance);
- Other financial details such as other pension arrangements, relevant tax and PPS details, bank sort code and account number, tax codes, tax credits, Personal Fund Threshold and deductions from pension payroll;
- Details of family and social circumstances such as current marriage or civil partnership, any previous relationships and dependants and death benefit distribution information (including expression of wish forms);
- Copies of identification and similar documents (e.g. birth, marriage, civil partnership and death certificates, passport identity pages, decree absolute, Pension Adjustment Orders); and
- Information about health to determine and provide benefits.
The Trustees respects your right to privacy and ensure that your personal data is kept securely and is processed in accordance with applicable data protection laws, including the GDPR, and the Trustees’ data protection policies.
How will the data be used?
The data will be used to manage and administer the Schemes and to ensure the correct benefits are paid to you or to your dependants.
What is the legal basis for processing the data?
The Trustees process your data to comply with their legal obligations under the Schemes’ governing documents, pension and trust law requirements, and for the purpose of the Trustees’ legitimate interest in promoting the proper and efficient administration and management of the Schemes in order to provide benefits for you or your dependents.
Will the data be shared with any third parties?
Your personal data will be held confidentially but may be disclosed to the Trustees’ advisers, service providers and other third parties, for example:
- Trustees’ professional advisers (for example legal advisers, administrators, actuaries, investment consultants and insurers)
- Registered Administrators
- Scheme auditors
- Sponsoring employer
- Other Public Sector Bodies
- Insurance, PRSA providers and broker/financial consultants
- Regulatory authorities (for example the Pensions Authority, Central Bank and Revenue Commissioners)
- Members’ advisers (only with authorisation from the member)
- Other service providers (for example payroll providers, banks, investment managers and tracing agencies)
The Trustees may be required to disclose information to the Revenue Commissioners, the Financial Services and Pension Ombudsman, the Pensions Authority and other regulatory authorities. Where this is required, we, the Trustees will only do so if there is a legal basis for complying.
The Trustees may also disclose personal information to the Sponsoring Employer for the purposes of the business of the Sponsoring Employer as it relates to the Schemes and as there is a legal basis for processing – for example to allow a risk assessment, financial monitoring or to meet accounting disclosure requirements as they apply to the Schemes.
Some of the third parties above may be joint controllers with the Trustees or independent controllers of the data. The Trustees will agree with any joint controller(s) that each will comply with data protection law. The Trustees will seek confirmation from any independent controllers that they comply with the data protection law.
Your personal data may be transferred outside of the European Union to service providers who use resources or data processing facilities outside of the European Union. Any such transfers will comply with the Trustees’ data protection obligations including using contracts approved by the European Commission.
How long will the data be stored for?
Usually your personal data will be kept for a maximum of seven years after the date of wind-up of the Schemes to allow the Trustees to comply with statutory obligations to maintain the Schemes’ records and to be in a position to verify claims and queries relating to benefits.
What rights do you have and how can you raise a complaint?
You may have the right under data protection legislation to raise objections in relation to the processing of your personal data, which may include a right to restrict such processing in certain instances. You have a right to request a copy of your personal data and, in limited circumstances, to request its rectification or erasure.
Any queries regarding your data should be sent to the address below and will be processed in accordance with applicable data protection legislation. In the event that your query has not been resolved to your satisfaction, you have the right to raise the matter with the Data Protection Commissioner, Lo call 1890 252231 or email firstname.lastname@example.org
Please note that if you fail to provide accurate membership information or object to processing of your data it may result in a delay or an inability to process a claim for your benefits under the Schemes.
Further information on your data privacy rights is available on the website of the Data Protection Commissioner www.dataprotection.ie
If you have any questions relating to the processing of your personal data, information may be obtained by contacting the Schemes’ Data Protection Officer at:
Pension Scheme Data Protection Officer
Data Privacy Office
Where can I view the most up to date privacy notice?
The latest privacy notice can be viewed on-line at the following address www.AnPost.com/Privacy
The Trustees may revise the privacy notice from time to time and you should check this page regularly to view the most up to date Privacy Notice.
This privacy notice was last reviewed on 27 September 2018.