T-Mobile International UK Pension Scheme

Nomination
info

Introduction

The Trustee of the T-Mobile International UK Pension Scheme (‘the Scheme’) needs to hold some personal information relating to you in order to administer your pension and/or death benefits payable from the Scheme.  The Trustee is committed to protecting your personal information. This Notice sets out important information about how it collects and uses your personal data.

You should read this notice carefully and raise any questions that you may have with the Trustee by emailing [email protected].

Scope

This Notice applies to members and beneficiaries of the Scheme. 

The Trustee of the Scheme, T-Mobile International UK Pension Trustee Limited (‘the Trustee’) (Orion House, Bessemer Road, Welwyn Garden City, AL7 1HH), is a data controller in respect of the information which it holds about you.

Other parties involved in running the Scheme may also need to collect and use information about you to carry out their functions.  This includes the Scheme Actuary (currently Colin Downie of Willis Towers Watson Limited) who, together with Willis Towers Watson Limited, will also be a data controller for these purposes. 

Willis Towers Watson has also issued a privacy notice on behalf of itself and the Scheme Actuary.  The privacy notice can be accessed via the following link: https://tmipensions.co.uk/wp-content/uploads/2019/09/WTW_Privacy_Notice.pdf. 

Willis Towers Watson may make changes to its privacy notice from time to time so you should check the latest version of their privacy notice on a regular basis.  The Trustee takes your privacy very seriously and it asks that you read Willis Towers Watson’s privacy notice carefully as it contains important information.

The information collected and used regularly by the Scheme Actuary and Willis Towers Watson Limited is most likely to relate to members of the defined benefit section of the Scheme.  However, the Scheme Actuary and Willis Towers Watson Limited may also have had access to Scheme-wide information which may also relate to members of the defined contribution section.  The Trustee therefore strongly suggests that all Scheme members take the opportunity to read Willis Towers Watson’s privacy notice.

What personal data does the Trustee collect?

Personal data means information which identifies you and relates to you as an individual. The Trustee of the Scheme collects, uses and stores your personal data for a wide variety of reasons in connection with the administration of your pension benefits.

It may collect and process the following data about you:

·  your name, date of birth, national insurance number and bank account information (where benefits are in payment).
·  contact details, including address, email address and phone number.
·  if your benefits from the scheme derive from your employment, details of your employer when you were building up benefits in the scheme, how long you worked for them and your salary from time to time.
·  whether you are married or in a civil partnership and other information we might need to pay any benefits due on your death.
·  any information you have provided about who you would like to receive any benefits due on your death.
·  if your benefits from the scheme form part of a divorce settlement, details of that settlement.

You may give it this information by phone, in writing, by email or in person or by completing forms either in writing and/or electronically.

The Trustee may sometimes use other information about you.  This could include information about your health, where it is relevant to, for example, early payment of benefits from the Scheme, or details about personal relationships to determine who should receive benefits on your death.  It might also, very rarely, have information about criminal convictions and offences, but only where it is relevant to the payment of scheme benefits.

The list set out above is not exhaustive, and there may be other personal data which the Trustee collects, stores and uses in the context of administering your pension benefits. The Trustee will update this Notice from time to time to reflect any notable changes in the categories of personal data which it processes.

Where the Trustee gets your personal data from

Some of the information the Trustee has comes directly from you.  In addition, Capita and Fidelity, who administer the scheme on the Trustee’s behalf, may have obtained information about you and passed it to the Trustee.  The Trustee may, in turn, pass information about you to the other scheme advisers, brokers and insurers or may instruct the administrator to do so.  The Trustee is the source of the personal data which the scheme advisers, brokers and insurers have about you. 

Sometimes the Trustee gets information from other sources: for example, from your scheme employer (for information such as salary and length of service); from another scheme if you have transferred benefits from that scheme; from governmental departments such as HMRC and DWP; and from publicly accessible sources (e.g. the electoral roll) if the Trustee has lost touch with you and is trying to find you.  The Trustee may in turn pass this information to the Scheme advisers, brokers and insurers.

If the Trustee asks you for other information in the future (for example about your health), it will explain whether you have a choice about providing it and the consequences for you if you do not do so.

How does the Trustee use your personal data?

The Trustee must by law provide benefits in accordance with the Scheme’s governing documentation and must also meet other legal requirements in relation to the running of the scheme.

The Trustee will use your personal data to comply with these legal obligations, to establish and defend its legal rights and to prevent and detect crimes such as fraud.  The Trustee may need to share your personal data with other people for this reason, such as courts and law enforcement agencies.

The Trustee also has a legitimate interest in properly administering the scheme.  This includes paying benefits as they fall due; purchasing insurance contracts; communicating with you; and ensuring that correct levels of contributions are paid, benefits are correctly calculated and the expected standards of scheme governance are met (including standards set out in Pensions Regulator guidance).

What Sensitive data does the Trustee keep?

Certain categories of data are considered "sensitive personal data" and are subject to additional safeguards.

The Trustee may need to use information about your health (or other very personal information) which would be classed as sensitive personal data.

If the Trustee needs to use this type of information it may ask for your consent.  However, sometimes there may be reasons of public interest or law which enable the Trustee to use this information without consent and it will do so where that is necessary to run the scheme in a sensible way.  You can withdraw your consent at any time by contacting the Trustee using the contact details given below.  This may affect what the Trustee can do for you, unless the Trustee has another lawful reason for using your information. 

When does the Trustee share personal data?

The Trustee will share personal data with other parties only in limited circumstances and where this is necessary for the administration of your pension benefits or to comply with a legal obligation as follows:

·  Accountants, lawyers and other professional advisers and service providers (including but not exhaustively services such as actuarial services, risk management, legal advice and defined benefit and defined contribution investment and administration management)
·  Management staff of Deutsche Telekom (UK) Ltd, its successors or its ultimate parent company (Deutsche Telekom AG)
·  HM Revenue and Customs
·  IT and data storage providers
·  If your benefits are transferred to another scheme or pension arrangement, the Trustee may need to provide the Trustee or administrators of that scheme or arrangement with information about you.

The Trustee may also be required to disclose your personal information in response to requests from a government agency, court, tribunal, ombudsman or regulator or for other purposes related to a dispute process.

In the majority of cases, your personal data is shared under the terms of a written agreement between the Trustee and the third party which includes appropriate security measures to protect the personal data in line with this Notice and our obligations. The third parties are permitted to use the personal data only for the purposes which are identified, and not for their own purposes, and they are not permitted to further share the data without the Trustee’s express permission.

The Trustee may also share personal data in response to requests from third parties such as banks, mortgage lenders, independent financial advisors, lawyers, actuaries, accountants and other third parties (in each case only if you have explicitly consented to the sharing of your personal data).

The Scheme’s employers may also have a legitimate interest in contacting you about your benefits under the Scheme, and any additional options which may be available to you in relation to those benefits.  In such circumstances, the Trustee may share your personal information with the employers so that they can contact you for that purpose.

In all cases, where personal data is transferred to a country which is deemed not to have the same level of protection for personal data as the home country, the Trustee will put in place written data transfer agreements to protect the personal data. In the case of any transfer of personal data from a country within the European Economic Area (EEA) to a country outside of the EEA, these transfer agreements will incorporate the standard contractual clauses approved by the European Commission. If you have any questions about the transfer of your personal data in these circumstances, please email [email protected].

For how long will my personal data be retained?

The Trustee needs to keep some of your personal information long enough to make sure that it can satisfy its legal obligations in relation to the Scheme and pay any benefits due to or in respect of you.

The Trustee keeps your information for long enough to ensure that, if a query arises in the future about your benefits, it has enough information to deal with it where it has a legal obligation to do so.  To meet this aim, the Trustee will keep your information for as long as is necessary to deal with queries (from you or your beneficiaries/other persons who might ask the Trustee if they are entitled to payments), complaints (from you or them), and our legal obligations mentioned above.

What are my rights in relation to my personal data?

The Trustee will always seek to process your personal data in accordance with its obligations and your rights.

In certain circumstances, you have the right to seek the erasure or correction of your personal data, to object to particular aspects of how your data is processed, and otherwise to seek the restriction of the processing of your personal data. You also have the right to request the transfer of your personal data to another party in a commonly used format and the right not to be subject to automated decision-making including profiling where it produces legal or other significant effects on you. If you have any questions about these rights, please email [email protected].

You have a separate right of access to your personal data processed by the Trustee.  You may be asked for information to confirm your identity and/or to assist the Trustee to locate the data you are seeking as part of the Trustee's response to your request.  If you wish to exercise your right of access you should email [email protected].

You can exercise all of these rights free of charge except in some very limited circumstances, and these will be explained to you where they are relevant.

Finally, you have the right to raise any concerns about how your personal data is being processed with the Information Commissioner’s Office (ICO) using the following contact details:

ICO helpline
Telephone:  0303 123 1113

Where can I get further information?

The Trustee has appointed James Rowe, Trustee Director, to oversee compliance with this Notice and to deal with any questions or concerns.   If you would like further information about the matters set out in this Notice, please contact [email protected].

September 2019

You should complete a nomination form to let us know who you’d like your death benefits to go to. The Trustee is not legally bound by your wishes but will take them into consideration.

Click here to complete a nomination form MISSING: NOMINATION FORM LINK?