Newsquest Pension Trustee Limited - Privacy Notice

Who we are

Newsquest Pension Trustee Limited is the trustee (the “Trustee”) of the Newsquest Pension Scheme (the “Scheme”) and the Newsquest Life Assurance Scheme (the “LAS”) and we hold certain personal information (known as “personal data”) about scheme members and, where applicable, their dependants and beneficiaries.  For legal purposes, the Trustee is known as the “data controller”, as we decide the purposes for and the means by which the personal data we hold is processed. “Personal data” is information from which you as an individual can be identified.  If you are a member of the Scheme and/or the LAS, the information in this notice applies to you.

What information we collect about you

Depending on the circumstances and the stage of your membership, we may hold some or all of the following information about you:

• your name and date of birth
• your address
• your marital status
• your national insurance number
• details about your pension benefits and salary information
• details of your bank account (to pay benefits)
• details about your dependants and/or beneficiaries so that we can pay benefits following your death
• medical and other details about your health that you have given us if you apply to receive benefits on these grounds or if these details are collected for statistical purposes
• possible details of any former pension arrangements you may have transferred into the Scheme
• your company and pension service dates
• possible divorce information if you have entered into a pension sharing order

How we use that information

The Trustee needs to hold and process information about you as it is needed for us to properly administer the schemes and to calculate and pay benefits. In legal terms, this means that we have a legitimate interest in processing the information.  We also keep the above information in order to allow us to comply with our obligations towards members under the governing documents of the schemes, as well as under relevant legislation.  We will not collect any personal data from you that we do not need. 

Personal data relating to members and beneficiaries of the schemes is held on paper and on computer systems.  As the “data controller”, the Trustee must process this information fairly and lawfully.

As part of running the schemes, we may also need to hold and process other information about you, particularly sensitive information about you and/or your dependants and beneficiaries (known as “sensitive personal data”).  Under the legislation, details relating to health, racial or ethnic origin, religious or other similar beliefs, sexual orientation and political affiliations are regarded as “sensitive personal data”.  Except where the legislation allows it, this information cannot be processed or passed to a third party without your explicit consent.

We will not process personal data for any purpose or purposes which we have not told you about.  However, there are exceptions to this.  For example, if it were obvious to an individual that personal information would be processed for the new purpose or if the new purpose was in fact compatible with the original purpose(s) for which the personal data was collected.

How we gather your personal information

Your personal data will generally be collected directly from you or from your Newsquest employer.  However, we may also receive personal data from other parties such as HM Revenue & Customs, the Pensions Ombudsman or someone acting on your behalf, such as an independent financial adviser. If you are receiving a dependant’s benefit from the Scheme, or a benefit resulting from divorce or the dissolution of a civil partnership, we may have been given your personal data by the member or through enquiries undertaken by us on a member’s death.

Who we share it with

As the Trustee needs help from various advisers to administer the schemes, we share personal data with the following people and organisations:

• the Group Pensions Manager at Newsquest and the third parties who are responsible for the day-to-day administration of the schemes on behalf of the Trustee including companies which host our website and run our administration systems
• your current or past employer (i.e. your Newsquest employer) and other companies in the Newsquest group
• the schemes’ professional advisers, including the Scheme actuary, auditor, investment adviser, medical advisers and lawyers
• HM Revenue & Customs and other statutory bodies (such as the Pensions Ombudsman and the Pensions Regulator) or other third parties as required by law – the Trustee can be fined and subject to other action if it fails to provide certain information to these authorities
• persons in connection with any investment changes, sale, merger, acquisition, disposal, reorganisation or similar change involving the schemes (including any counterparties, potential or actual purchaser and their advisers)
• the advisers and printers who help us prepare various communications we send to you, such as the annual benefit statement
• our appointed insurance company or companies and our insurance brokers for the purposes of death benefits (including death in service benefits under the LAS) and additional voluntary contributions
• insurance companies with which we may secure benefits for scheme members or beneficiaries
• depending upon how we pay pensions, the personal data we have to supply in order to effect a BACS transfer (the Bankers' Automated Clearing Service) in the UK and/or a payment when pensions are being paid overseas
• tracing agencies and consultants who assist the Trustees with updating scheme data or providing statistical information from time to time

As the Scheme’s Actuary needs to have access to personal data about the membership to carry out its actuarial functions in relation to the Scheme (eg determining the value of a member’s pension or the funding level of the Scheme as a whole) and to comply with its legal and professional obligations, Willis Towers Watson will, in some circumstances, also be a data controller. A link to Willis Towers Watson’s own Privacy Notice can be found at www.willistowerswatson.com/personal-data.

How long we keep personal data for

We must keep all personal data safe and only hold it for as long as necessary.  To meet the requirements of both UK tax and pensions law, we must keep certain personal data (for example, details about the date a member joins the schemes, their name and address, and details of benefits paid) for a minimum of 6 years.  But, given the nature of pension schemes, the Trustee may be required to keep some of your personal information for the rest of your life so that we have the information we need to pay benefits and to answer queries about your benefits. 

We review the personal data held in relation to the schemes on a regular basis in accordance with our data protection policy (as amended from time to time).  If we conclude that certain personal data is no longer needed, that personal data will generally be destroyed. 

Your rights

• You have the right to request information about the processing of your personal data and see personal data that is held about you and a right to have a copy provided to you, or someone else on your behalf, in a machine readable (namely, digital) format
• If at any point you believe that the personal data we hold about you is inaccurate, you can ask to have it corrected
• You can require the Trustee to limit the processing of your personal data in certain circumstances, for example, whilst a complaint about its accuracy is being resolved
• You can object to your personal data being processed
• Where you have given us your consent to processing your personal data, you can withdraw that consent at any time by notifying us (see “Who to contact” below). However, withdrawing your consent will not affect the processing of any personal data which took place beforehand
• You can request that your personal data is deleted altogether.

You should be aware that taking any of the above steps could impact on the payment of your benefits and our ability to answer questions relating to your benefits.  Please note that in certain circumstances the Trustee can override your objection to the processing of your personal data, request to withdraw consent to the processing of your personal data and/or request to delete your personal data.

Information will generally be provided to you free of charge, although the Trustee can charge a reasonable fee in certain circumstances.

Who to contact about your personal data

If you wish to:

• see your personal data or to exercise any of the rights mentioned above
• make a complaint about how we have handled your personal data

please contact:

• Mercer if you have benefits held under the Newsquest Pension Scheme;

Mercer Limited

Post Handling Centre U

Newsquest Pension Scheme

St James's Tower

7 Charlotte Street

Manchester

M1 4DZ

[email protected]

• the Group Pensions Manager at Newsquest if you have benefits under the Newsquest Life Assurance Scheme;

Newsquest Media Group

4th Floor

Queens House

55/56 Lincoln’s Inn Field

London WC2A 3LJ

Please note Mercer deals with the administration of benefits for members of the Newsquest Pension Scheme section which includes the CN Pension Fund and the CN Supplementary Pension Plan section within the Newsquest Pension Scheme.

Making a complaint to the Information Commissioner’s Office

If you are not satisfied with our response to any query you raise with us, or you believe we are processing your personal data in a way which is inconsistent with the law, you can complain to the Information Commissioner’s Office whose helpline number is: 0303 123 1113.

Updates to this notice

This notice is the latest version as at February 2020. This notice will be updated from time to time and you can see the current version at any time on the Trustee’s website at http://www.newsquest.co.uk/newsquest-pension-trustee-limited-privacy-notice/

If you would like a hard copy of the notice at any time, please contact Mercer or the Group Pensions Manager at Newsquest as relevant (contact details above).

February 2020