PRIVACY NOTICE FOR THE AIRWAYS PENSION SCHEME
Airways Pension Scheme Trustee Limited (the "Trustee"), and, to the extent necessary to service the Scheme, British Airways Pension Services Limited ("BAPSL"), (together "we") hold and process personal data about Scheme members and beneficiaries in order to run the Scheme. In doing so, we comply with relevant data protection legislation.
What we do with your data
The Trustee and, where necessary, BAPSL, jointly act as controllers of your personal data, which we collect and process for the purposes of complying with our legal duties to administer the Scheme and for other legitimate purposes relating to the operation of the Scheme. This includes:
- calculating, administering and paying your benefits under the Scheme or following your death;
- dealing with any queries/complaints/appeals etc. regarding decisions we have made, for example in relation to your entitlement to benefits/the relevant beneficiary's entitlement to benefits under the Scheme; and/or
- compliance with legal, regulatory and good governance obligations and as otherwise lawfully permitted from time to time.
How we collect information about you
Whilst much of the data we hold has been provided by you, we also hold and process data provided by third parties such as British Airways Plc ("BA Plc") as the sponsoring employer of the Scheme, other employers or pension schemes associated with BA Plc, medical advisers, any pension scheme or arrangement from which benefits are transferred to the Scheme, from HMRC, the DWP and regulatory bodies and from tracing organisations. We may also receive information from you about your proposed beneficiaries, who would be eligible to receive benefits on your death. We assume that you have the consent of those individuals to provide us with this information and that you will share this privacy notice with them. We will not provide a copy of this notice to those individuals as to do so is likely to seriously impair our ability to properly pay the benefits due under the Scheme.
In some circumstances we also share responsibility as controllers for your personal data with Willis Towers Watson for actuarial support, the legal advisers (who may process your data to comply with their professional duties as advisers to the Trustee), insurers, auditors and BA Plc. BA Plc holds your data to comply with its legal obligations as the sponsoring employer of the Scheme. It has a legitimate interest in the Scheme being run in a cost‑effective way and may have an interest in offering certain options to members. The Trustee will share information with BA Plc and its auditors and advisers for this purpose.
What data is processed?
The data we hold about you includes (but is not limited to):
- full name, date of birth, national insurance number and or other governmental identification numbers;
- business and/or personal contact details, including address, telephone numbers and email addresses;
- financial information, including salary, pension or prospective pension entitlement, bank account details;
- employment status, including years of service, employment start and leave date;
- your preferences in relation to your pension benefits, including any elections you may make online through mybapension online; and
- marital status and relationship data, including the full name, date of birth, contact details and relationship to your proposed beneficiaries.
We may also hold and process some special categories or "sensitive" data about you for the purposes of administering the Scheme (for example in relation to ill-health or death benefits). We will in most circumstances process this data as necessary for the establishment, exercise or defence of legal claims to benefits or in the performance of our legal obligations in connection with employment, social security and social protection (as allowed by legislation). If there are any occasions where we seek your explicit consent to process sensitive data then you can withdraw it at any time.
Who else processes your data?
We share your personal data with certain third parties involved in running the Scheme, for example, British Airways Pension Services Ltd (to the extent it acts as a processor) as the Scheme administrator; Willis Towers Watson as the actuarial support team (WTW privacy notice); BA Plc as the Scheme employer and other companies within the BA Plc’s group (the "British Airways Group"); and certain insurers including Legal & General and its reinsurers (LGAS privacy notice, LGAS' reinsurers' privacy notices) and Rothesay Life and its reinsurers (Rothesay Life privacy notice), through which the Trustee has secured certain scheme liabilities, as well as service providers, such as those providing support, maintenance and troubleshooting services for our IT systems, the administration or website system providers, our professional advisers and other persons who may become involved in or responsible for providing or communicating benefits, including occupational health service providers.
In addition, we may make your personal data available to any other employers associated with BA Plc, or to companies and firms which are considering or have acquired the Scheme employer or the whole or part of the employer's business, or to the trustee(s), administrators or professional advisers of any pension scheme to or from which your rights under the Scheme may be, are being or have been transferred, or to any company participating in such a pension scheme.
Where you are a member of, or have benefits under, the New Airways Pension Scheme and/or the British Airways Pension Plan, we may make your personal data available to the Trustee of the relevant Scheme/Plan for the purposes of administering those benefits.
Your personal data may also be released to other external parties if authorised by you, or as required or permitted by law, or to comply with a judicial proceeding, court order, request from the Pensions Regulator, Pensions Ombudsman or any other regulator or any other legal process served on or involving the Trustee, or where it is necessary for the purposes of our legitimate interests relating to the operation of the Scheme.
Transferring your data outside the United Kingdom ("UK") and the European Economic Area ("EEA")
The Trustee and BAPSL are situated in the United Kingdom, which currently shares similar data privacy laws to the EEA. However, you should be aware that recipients of your personal data, including companies within the British Airways Group, service providers and other advisers may from time to time transfer data to other countries, including outside the UK and the EEA. In particular, The Bank of New York Mellon processes the Scheme’s overseas pension payroll. Where such transfers are made, the parties involved will ensure adequate safeguards are in place. Such transfers will generally be made based on the EU Commission’s standard contractual clauses.
Storage of your personal data
Pension benefits are paid over a long period and your right to benefits under the Scheme is based on information that may go back many years. Our policy is therefore to retain information relating to you until your membership of the Scheme ends.
Once your membership ends, we may decide to delete some of the data held in relation to you after 6 years. However, information may be held for longer where we consider it appropriate in order to ensure the Scheme pays the correct benefits and to deal with any queries relating to your benefits which may arise after that time.
You have the right to obtain access to, or copies of, your personal data and request that we rectify any errors in the data that we hold, or request that we erase your personal data. In some circumstances, you can also ask that we restrict the way we process your personal data or object to its processing. In some circumstances, you have a right to request a copy of your personal data for the purposes of transmitting elsewhere. You can exercise these rights by contacting the Trustee. Please notify us as soon as possible if there has been a change in your details (for example if your personal circumstances such as your nominated beneficiary or home address change).
Where we have requested and obtained your consent to process particular information, you may withdraw that consent at any time. However, if we do not hold all the data we need to administer your benefits, we may not be able to pay out your pension entitlements.
If you want to know more about the information held by the Trustee, the purposes for which it is held or about the Scheme's data protection arrangements please contact British Airways Pension Services Limited.
This notice will be updated from time to time and you can see the current version at any time on the Trustee’s website. Alternatively, if in the future you would prefer to receive a hard copy of the latest version, please contact us.
What if you have a complaint?
If you are not satisfied with how we have handled your personal data you can complain. Please contact us if you wish to make a complaint.
If you are not satisfied with our response to your complaint or believe our processing of your information does not comply with data protection law, you can make a complaint to the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF. Telephone: 0303 123 1113 or 01625 545 745.
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