Privacy Notice

Full Privacy Notice for the Members and Beneficiaries of the Gwynedd Pension Fund

This privacy notice is for members and beneficiaries (referred to as "you") of the Gwynedd Pension Fund (the "Fund"). It has been prepared by Cyngor Gwynedd (the "Administering Authority", or "we") in its capacity as the administering authority of the Fund. This privacy notice describes how we collect and use personal data in accordance with data protection legislation.

It is important that you read this privacy notice together with any other privacy notice or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.

This privacy notice replaces any general privacy notice we may have previously issued and supplements any other notices and privacy policies we issue that are specific to particular data collection and processing activities.

Why We Are Providing This Notice to You

As the Administering Authority of the Fund, we hold certain information about you from which you can be identified ("personal data") which we use to administer the Fund and to pay benefits from it.

In line with data protection legislation, we are required to give you specified information about the personal data we hold about you, how we use it, your rights in relation to it and the safeguards that are in place to protect it. This notice is designed to give you that information.

The Technical Bit

The Administering Authority holds personal data about you, in its capacity as a controller, for the proper handling of all matters relating to the Fund, including its administration and management.

This includes the need to process your data to contact you, to calculate, secure and pay your benefits, for statistical and financial modelling and for reference purposes, and to manage liabilities and administer the Fund generally.

Lawful Basis for Processing

The lawful basis for our use of your personal data will usually be that we need to process your personal data to satisfy our legal obligations as the Administering Authority of the Fund, including our obligations under the pensions dashboard regulations.

Where that legal basis does not apply, the legal basis for our use of your personal data will be one or more of the following:

We need to process your personal data to carry out a task in the public interest or in the exercise of official authority in our capacity as a public body.
We need to process your personal data for the legitimate interests of administering and managing the Fund and liabilities under it, calculating, securing and paying benefits and performing our obligations and exercising any rights, duties and discretions the Administering Authority has in relation to the Fund.
We need to process your personal data to meet our contractual obligations to you in relation to the Fund, or to take steps at your request before entering into a contract.

Please note that where we indicate that our processing of your personal data is necessary for us to comply with a legal obligation, or to take steps at your request before entering into or performing a contract, and you choose not to provide the relevant personal data to us, we may not be able to enter into or continue our contract with you.

What Personal Data We Hold and How We Obtain It

The types of personal data we hold and process about you can include:

Contact details, including name, address, telephone numbers and email address.
Identifying details, including date of birth, National Insurance number, employee membership numbers and pension identifiers (PEIs).
Information used to calculate and assess eligibility for benefits, such as service and salary information.
Financial information relevant to the calculation or payment of benefits, including bank and tax details.
Information about your family, dependants or personal circumstances.
Information about your health where relevant to pension benefits.
Information about criminal convictions where relevant to pension recovery provisions.
Information about membership of other public service pension schemes and LGPS funds.

We obtain some of this personal data directly from you. We may also obtain information from your current or former employer, public databases, pensions dashboards, advisers, government bodies and regulatory organisations.

Where we obtain special category personal data, such as health information, additional protections apply. We will only process such information where permitted by data protection 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.

How We Will Use Your Personal Data

We will use this data to deal with all matters relating to the Fund, including its administration and management.

To contact you.
To assess eligibility for, calculate and provide benefits.
To identify and implement benefit options.
To facilitate access through pensions dashboards.
For statistical and financial modelling.
To process transfer requests.
To comply with legal and regulatory obligations.
To respond to enquiries and disputes.
To manage the Fund's liabilities and investments.
In connection with employer business transfers or reorganisations.
To determine eligibility for McCloud underpin protection.

For further information about underpin protection, visit:

https://www.lgpsmember.org/mccloud-remedy/

Organisations That We May Share Your Personal Data With

From time to time we will share your personal data with advisers and service providers so that they can help us carry out our duties, rights and discretions in relation to the Fund.

Processors

Administrator – currently Cyngor Gwynedd.
Additional Voluntary Contribution providers.
Accountants.
Tracing bureaus for mortality screening and member tracing.
Overseas payment providers.
Integrated service providers supporting pensions dashboards.
Printing companies.
Pensions software providers.
Suppliers of IT, document production and distribution services.

Controllers

Actuarial consultants.
Fund benefit consultants.
Investment advisers.
Additional Voluntary Contribution providers.
Legal advisers.
Fund actuaries.
Statutory, external and internal auditors.
Insurance companies relating to ill-health benefits.
LGPS administering authorities.
Other public service pension scheme administrators.
The Department for Work and Pensions.
The Government Actuary's Department.
The Cabinet Office.
HM Revenue & Customs.
The Courts of England and Wales.
Money & Pensions Service.

We may also share your personal data with insurers, investment managers, pension scheme operators, your employer and relevant government bodies where required for the administration and management of the Fund.

Transferring Information Outside the UK

In some cases recipients of your personal data may be outside the United Kingdom.

Where this occurs, appropriate safeguards will be implemented to ensure your personal data is protected in accordance with applicable data protection legislation.

How Long We Keep Your Personal Data

We will only keep your personal data for as long as necessary to fulfil the purposes for which it was collected and to comply with our legal and regulatory obligations.

Your personal data will generally be retained for as long as benefits are payable and for 15 years after benefits cease.
Data relating to pensions dashboards will be retained in accordance with pensions dashboard regulations and data retention schedules.

Your Rights

You have the right to:

Access your personal data.
Request correction of inaccurate or incomplete data.
Request restriction of processing in certain circumstances.
Request transfer of your personal data where applicable.
Request deletion of personal data in limited circumstances.
Object to processing in certain circumstances.

Further information about your rights can be found on the Information Commissioner's Office website:

www.ico.org.uk

You can also contact the ICO via their helpline on 0303 123 1113.

If you wish to exercise any of these rights or have any concerns about how your personal data is processed, please contact the Fund Administrator or Data Protection Officer.

You can submit a data protection complaint using the online form:

Contact Form

You also have the right to lodge a complaint with the Information Commissioner's Office.

Please note that restricting or deleting personal data may affect our ability to administer your pension benefits or make payments from the Fund.

Updates

We may update this notice periodically. Where we do so, we will inform members and beneficiaries of the changes and the date on which the changes take effect.

Contacting Us

Please contact the Fund Administrator, Cyngor Gwynedd, for further information.

Data Protection Officer

You may also contact our Data Protection Officer for further information or if you have a complaint about how we have handled your personal data.

Cookies

When you visit our website you will be asked to accept cookies from the site.

No sensitive information such as telephone numbers or email addresses are stored within these cookies. The cookies we use provide us with information regarding the behaviour of users within our site, including which areas are of interest to them and which services they frequently use. They may also be used to remember login details for some services.

Cookies We Use

The table below explains the cookies we use and why:

Cookie	Name	Purpose
SiteImprove SiteAnalyze Statistics	ASP.NET_SessionId	The purpose of this cookie is to track the sequence of pages a visitor looks at during a visit to the site. This information can be used to reduce user journeys and enable visitors to find relevant information more quickly.
Cyngor Gwynedd Cookie	dangos-neges-cwcis	This cookie records whether you have accepted cookies from this website. No personal details are held within this cookie.

Updates to this Page

The Gwynedd Pension Fund can update these terms at any time. You should visit this page occasionally to review the information provided to you as a user.