Privacy Notice
Trafalgar House Pensions Administration Limited understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of all our customers and business partners and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.
This Privacy Notice only applies in relation to the processing of personal information that we undertake as a controller. It does not apply to activities that we perform as a processor on behalf of our clients (such as pension scheme administration services). Details of such processing will be set out in the privacy notice of your relevant pension scheme trustee and/or employer.
1. Information About Us
Trafalgar House Pensions Administration Limited (“Trafalgar House”). A Limited business registered in England under company number 11101662.
Registered address: Ascent 4, 2 Gladiator Way, Farnborough Aerospace Centre, Farnborough, England, GU14 6XN.
2. What Does This Notice Cover?
This Privacy Information explains how we use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data.
This Privacy Notice only applies in relation to the processing of personal information that we undertake as a controller. It does not apply to activities that we perform as a processor on behalf of our clients (including pension scheme administration and trustee management services). Details of such processing will be set out in the privacy notice of your relevant pension scheme trustee and/or employer.
3. What Is Personal Data?
Personal data is defined by the UK GDPR and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
The personal data that we use is set out in Part 5, below.
4. What Are My Rights?
Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:
a) The right to be informed about our collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 11.
b) The right to access the personal data we hold about you. Part 10 will tell you how to do this.
c) The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 11 to find out more.
d) The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold. Please contact us using the details in Part 11 to find out more.
e) The right to restrict (i.e. prevent) the processing of your personal data.
f) The right to object to us using your personal data for a particular purpose or purposes.
g) The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
h) The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
i) Rights relating to automated decision-making and profiling. We do not use your personal data in this way.
For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 11.
It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data.
Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first, using the details in Part 11.
5. What Personal Data Do You Collect and How?
We may collect and hold some or all of the personal and non-personal data set out in the table below, using the methods also set out in the table. We do not collect any ‘special category’ or ‘sensitive’ personal data or personal data relating to children.
Information provided by you (or your employer or pension scheme on your behalf) or from publically available sources:
- Year of birth;
- Gender;
- Email address and contact telephone number;
- Employee ID;
- Job title and employment grade;
- Employment location and office address;
- Employer name;
- Employment periods;
- Employee performance;
- Employee benefits;
- Salary and remuneration arrangements;
- Short and long term incentive payouts and targets;
- Pension and other benefit amounts;
- Company cars;
- Business travel information;
- Educational background.
- Our correspondence – If you contact us, we will typically keep a record of that correspondence.
- Website communication usage – Details of your visits to our website and information collected through cookies and other tracking technologies including, but not limited to, your IP address and domain name, your browser version and operating system, traffic data, location data, web logs and other communication data, and the resources you access. Information on how we handle this type of data can be found in our website cookie notice.
6. How Do You Use My Personal Data?
Under the Data Protection Legislation, we must always have a lawful basis for using personal data. The following describes how we use your personal data, and our lawful bases for doing so:
We may use your personal information for the following purposes:
a) Compensation, Benefit and Human Resources Benchmarking and Analysis: For the production of our Workforce Analytics and Remuneration and Policy Surveys and Guides with the aim of providing products and services to our clients in respect of job matching, gender equality, organisation design and industry remuneration and compensation benchmarking.
Use justification: legitimate interests (to enable us to perform our contractual obligations), legal obligation.
b) Data analytics: To conduct benchmarking, modelling and data analytics in relation to remuneration, pension services and other related services.
Use justification: Legitimate interests (to enable us to perform our contractual obligations and allow us to improve our service), legal obligation.
c) Regulatory compliance: To undertake such other activities as are required in order to meet our ongoing regulatory, legal and compliance obligations, including the prevention and detection of crime, for fraud detection purposes, anti-money laundering and sanctions checks and in order to liaise with statutory bodies.
Use justification: legitimate interests (to enable us to perform our contractual obligations and to cooperate with our regulators), legal obligation.
d) To communicate effectively with our clients: To conduct our business, including to respond to our clients’ queries and to otherwise communicate with our clients, including to inform them of changes to our services and products and to handle claims.
Use justification: legitimate interests (to enable us to perform our obligations and provide our services to you), legal obligations, legal claims.
e) To reorganise or make changes to our business: To share data as part of any due diligence process, or following a sale or reorganisation, in the event that we: (i) are subject to negotiations for the sale of all or part of our business to a third party; (ii) are sold to a third party; or (iii) undergo a reorganisation.
Use justification: Legitimate interests (in order to allow us to change our business).
f) To provide you with marketing material: To provide you with updates and offers, where you have chosen to receive these. We may use your personal information to provide you with information about products or services which we think would be of interest to you. These may be sent by email, SMS, phone, or post.
We take care to ensure that our marketing activities comply with all applicable EEA and UK legal requirements. In some cases, this may mean that we ask for your consent in advance of us sending you marketing materials.
In all cases, you can always opt out of receiving marketing communications from us, at any time. We will always provide an option to unsubscribe or opt-out of further communication on any electronic marketing communications sent to you or you may opt out by contacting us as set out below.
Please note that, even if you opt out of receiving marketing messages, we may still send you communications in connection with the services we provide to you.
Use justification: consent and legitimate interest (to keep you updated with news in relation to our products and services).
We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If we do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us using the details in Part 11.
If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, we will inform you and explain the legal basis which allows us to do so.
In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.
7. How Long Will You Keep My Personal Data?
We will retain your personal information for as long as is necessary for the processing purpose(s) for which it was collected and any other permitted linked purpose (for example where we are required to retain personal information for longer than the purpose for which we originally collected it in order to comply with certain regulatory requirements). Our retention periods are based on business needs and your information that is no longer needed is either irreversibly anonymised (and the anonymised information is retained) or securely destroyed.
8. How and Where Do You Store or Transfer My Personal Data?
We store your personal data in the UK and within the European Economic Area (the “EEA”). The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein. This means that your personal data will be fully protected under the EU GDPR and/or to equivalent standards by law. Transfers of personal data to the EEA from the UK are permitted without additional safeguards.
9. Do You Share My Personal Data?
We may share your personal information with the following categories of recipients:
a) Our clients, such as the trustee or trustees of your pension scheme, your employer or former employer and their respective service providers or such other third parties as they instruct us to release the personal data to on their behalf;
b) Law enforcement bodies, third party agencies and sanctions lists, in connection with the prevention or detection of criminal activities, including fraud;
c) Public authorities, regulators and government bodies (such as HMRC), where this is necessary for us to comply with our legal and regulatory obligations;
d) Advisers, including legal advisers, loss adjusters and claims investigators, in connection with the investigation, exercise or defence of legal claims;
e) Third parties (and their advisers) in the event of a sale or reorganisation of our business;
f) Third party suppliers to whom we have outsourced certain activities, who process personal information on our behalf.
10. How Can I Access My Personal Data?
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 11.
The Information Commissioner’s Office has created a service to help individuals make a subject access request via a tool on their website. The tool creates an email to Trafalgar House with the individual’s request for personal information and the relevant information required to process the subject access request.
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
We will respond to your subject access request within three weeks and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
11. How Do I Contact You?
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details (for the attention of the Data Privacy Manager):
Email address: compliance@thpa.co.uk
Postal Address: Trafalgar House Pensions Administration, Ascent 4, 2 Gladiator Way, Farnborough GU14 6XN
Changes to this Privacy Notice
We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.
Any changes will be made available on our website. This Privacy Notice was last updated on 20 February 2024.