PRIVACY NOTICE FOR THE LAND ROVER PENSION SCHEME, THE JAGUAR PENSION PLAN AND THE JAGUAR EXECUTIVE PENSION PLAN (together “the Schemes”)
Why we are providing this notice
As the trustee of the Schemes we hold certain information about members of the Schemes and users of the Site (“personal data”). We are required by law to give you specified information about the personal data we hold about you, how we use it, and the safeguards that are in place to protect it. This notice is designed to give you that information.
Why we hold your personal data
The Trustee processes personal data about you, in its role as controller, for the proper handling of all matters relating to the relevant Scheme, including its administration and management, calculating, securing and paying benefits and managing liabilities in relation to it and in order to provide and operate the Site. Further information about how we process this data is provided under the heading “How we will use your personal data” below.
The legal basis for our use of your personal data will generally be one or more of the following:
a) We need to process your personal data to satisfy our legal obligations as trustee of the relevant Scheme.
b) We need to process your personal data for the legitimate interests of: administering and managing the relevant Scheme and liabilities under it; including operating the Site, calculating, securing and paying benefits; and performing our obligations and exercising any rights, duties and discretions the Trustee has in relation to the Schemes.
c) The processing is necessary for the performance of a contract to which you are party, or in order to take steps at your request prior to entering into a contract.
What personal data we hold and how we obtain it
The types of personal data we hold and process about you can include:
In operation of the Schemes
• Contact details, including name, address, telephone numbers and email address;
• Identifying details, including date of birth, national insurance number and employee and membership numbers;
• Information that is used to calculate and assess eligibility for benefits, for example length of service and salary information;
• Financial information relevant to the calculation or payment of benefits, for example bank account and tax details;
• Information about your family, dependents or personal circumstances, for example, marital status and information relevant to the distribution and allocation of benefits payable on death;
• Information about your health, for example, to assess eligibility for benefits payable on ill health, or when your health is relevant to a claim for benefits following the death of a member of the relevant Scheme;
• Information about a criminal conviction if this has resulted in you owing money to your employer or one or more of the Schemes and the employer or relevant Scheme(s) may be reimbursed from your benefits; and
• Information provided by you in telephone calls to or from the Schemes’ administrators, via the relevant Scheme’s contact centre number.
We obtain some of this personal data directly from you. We may also obtain data from your current or past employer(s) or companies that succeeded them in business (for example salary information), from a member of the relevant Scheme (where you are or could be a beneficiary of a Scheme as a consequence of that person’s membership), and from a variety of other sources including public databases, our advisers, and government or regulatory bodies.
Where we obtain information concerning certain “special categories” of particularly sensitive data, such as health information, extra protections apply under the data protection legislation. We will only process your personal data falling within one of the special categories with your consent, unless we can lawfully process this data for another reason permitted by that legislation. Where we rely on consent as the basis for that processing, you have the right to withdraw your consent to the processing at any time by notifying the Trustee in writing. However, if you do not give consent, or subsequently withdraw it, the Trustee may not be able to process the relevant information to make decisions based on it, including decisions regarding the payment of your benefits.
Where you have provided us with personal data about other individuals, such as family members, dependants or potential beneficiaries under any of the Schemes, please ensure that those individuals are aware of the information contained within this notice.
In operation of the Site
In the course of using the Site, we will collect additional personal data. This will generally include, but not be limited to:
• Information you provide by filling in forms on the Site;
• Records of any correspondence between you and us, if you contact us;
• Details of your visits to the Site and the resources that you access.
• Information collected when you search or interact with the Site and when you report a problem with the Site.
The information that is collected about your use of the Site may include the IP address of the device used to access the Site, the internet domain name through which you accessed the Site, the length of your session on the Site, details of the pages visited and resources accessed, the web browser used by your device to access the Site, your device’s operating system, and details of any website that provided you with a link to the Site.
How we will use your personal data
We may use this data to deal with all matters relating to the Schemes, including administration and management. This can include the processing of your personal data for all or any of the following purposes:
In operation of the Schemes
• to contact you;
• to assess eligibility for, calculate and provide you (and, if you are a member of one of the Schemes, your beneficiaries upon your death) with benefits;
• to identify your potential benefit options and, where relevant, implement those options;
• to allow alternative ways of delivering your benefits, for example, through the use of insurance products and transfers to or mergers with other pension arrangements;
• to comply with our legal and regulatory obligations as trustee of the relevant Scheme(s);
• to respond to queries from you and others that may receive benefits as a consequence of your membership, to ensure that information recorded is accurate, and to address any actual or potential disputes concerning the relevant Scheme(s);
• the management of the relevant Scheme’s liabilities, including the entering into of insurance arrangements and selection of the Schemes’ investments; and
• for statistical and financial modelling and reference purposes.
In operation of the Site
• To enable you to participate in the interactive features of the Site;
• To deal with any queries, complaints or problems reported on the Site;
• To analyse how the Site is used, and its effectiveness, to ensure that content from our Site is presented in the most effective manner for you and for your computer; and
• To protect the Site.
Organisations that we may share your personal data with
From time to time we will share your personal data with our advisers and service providers so that they can help us carry out our duties, rights and discretions in relation to the relevant Scheme(s). These include the following:
In operation of the Schemes
• The relevant Scheme’s administrator, currently JLT c/o The St Botolph Building, 138 Houndsditch, London, EC3A 7AW.
• The relevant Scheme’s actuary, currently Jonathan Gainsford, c/o Parkside House, Ashley Road, Epsom, Surrey, KT18 5BS. Please see the actuary’s / Aon Hewitt Limited’s separate short-form Privacy Notice and the link to the full document at the end of this notice.
• Actuarial consultants, currently Aon Hewitt Limited c/o The Aon Centre, The Leadenhall Building, 122 Leadenhall Street, London EC3V 4AN. Please see the actuary’s / Aon Hewitt Limited’s separate short-form Privacy Notice and the link to the full document at the end of this notice.
• The relevant Scheme’s auditors, currently PricewaterhouseCoopers LLP c/o 1 Embankment Place, London, WC2N 6RH. Their privacy statement can be found on their website:
• Investment advisers, currently Willis Towers Watson c/o Global Privacy Office, at 51 Lime Street, London, EC3M 7DQ.
• Covenant advisers, currently EY c/o 1 More London Place, London, SE1 2AF.
• Custodians, currently Northern Trust c/o 50 Bank Street, Canary Wharf, London, E14 5NT.
• Tax advisers, currently KPMG c/o 1 Snow Hill Queensway, Birmingham B4 6GH.
• Medical advisers, currently Duradiamond Healthcare Limited c/o Tribune House, Bell Lane, Uckfield, TN22 1QL.
• Trustee election service provider, currently Electoral Reform Services c/o The Election Centre, 33 Clarendon Road, London, N8 0NW.
• Additional voluntary contribution providers including Equitable Life Assurance Society c/o PO Box 177, Walton Street, Aylesbury, Buckinghamshire, HP21 7YH, Aegon UK c/o Edinburgh Park, Edinburgh, EH12 9SE, Legal & General Assurance Society, Legal & General House, 1 Coleman Street, London, EC2R 5AA and Prudential, Lancing, BN15 8GB.
• Any tracing bureaus used from time to time for mortality screening and locating members and beneficiaries.
• The Trustee’s insurers from time to time.
• The relevant Scheme’s banks from time to time.
• Suppliers of IT, document production and distribution services from time to time.
In some instances advisers and service providers will be controllers in their own right and will be directly responsible to you for their use of your personal data. They may be obliged under the data protection legislation to provide you with additional information regarding the personal data that they hold about you and how and why they process that data.
We may also provide some of your data to the sponsoring employer of the relevant Scheme and group companies of those employers, their advisers and potential purchasers of their businesses.
In addition, where we make investments or seek to provide benefits for the relevant Scheme’s members in other ways, such as through the use of insurance or pension scheme mergers, then we may need to share personal data with providers of investments, insurers and other pension scheme operators. In each case we will only do this to the extent that we consider the information is reasonably required for these purposes.
The advisers, service providers and organisations referred to in the paragraphs above may use personal data to perform their functions as well as for statistical and financial modelling (such as calculating expected average benefit costs and mortality rates) and planning, business administration and regulatory purposes. They may also pass the data to other third parties (for example, insurers may pass personal data to other insurance companies for the purpose of obtaining reinsurance), to the extent they consider the information is reasonably required for a legitimate purpose.
Where requested or if we consider that it is reasonably required, we may also provide your personal data to government bodies and dispute resolution and law enforcement organisations, including the courts, the Pensions Regulator, the Pensions Ombudsman, the Pension Protection Fund and Her Majesty’s Revenue and Customs (HMRC). They may then use the data to carry out their functions.
In some cases recipients of your personal data may be outside the UK. This means your personal data may be transferred outside the European Economic Area (EEA) to a jurisdiction that may not offer an equivalent level of protection as is required by EEA countries. If this occurs, appropriate safeguards must be implemented with a view to protecting your data in accordance with applicable laws. Please contact the Trustee, using the contact details below, if you want information about the safeguards that are currently in place.
How long we keep your personal data
We will only keep your personal data for as long as we need to in order to fulfil the purposes identified above. In practice this means that we will retain your data for such period as you (or any beneficiary who receives benefits after your death) are entitled to benefits from the Schemes and for so long afterwards as may be required to deal with any questions, complaints or claims that we may receive about our administration of the Schemes. We may also retain your data for a longer period to comply with our legal and regulatory obligations. Recordings of calls via the Scheme contact numbers are retained by the Scheme administrator for the duration of their appointment by us.
You have a right to access and obtain a copy of the personal data that the Trustee hold about you and to ask the Trustee to correct your personal data if there are any errors or it is out of date or incomplete. In certain circumstances you have the right to object to the processing of your personal data; for example you have the right to object to processing of your personal data which is based on the legitimate interests identified in the section above headed “Why we hold your personal data”, or where the processing is for direct marketing purposes. In some cases you may also have a right to ask the Trustee to restrict the processing of your personal data, or to transfer or erase your personal data. You can obtain further information about these rights from the Information Commissioner’s Office at: ICO website or via its telephone helpline (0303 123 1113).
If you wish to exercise any of these rights or have any queries or concerns regarding the processing of your personal data, please contact the Trustee using the contact details provided below. You also have the right to lodge a complaint in relation to this privacy notice or the Trustee’s processing activities with the Information Commissioner’s Office, you can do this via the ICO’s website or telephone helpline.
As explained in the section above headed “How we will use your personal data”, one of the one of the reasons we collect and hold your personal data is to administer your benefits under the relevant Scheme(s). If you do not provide the information we request, or ask that the personal data we already hold is deleted or that the processing of the personal data be restricted, this may affect our ability to administer your benefits, including the payment of benefits from the relevant Schemes). In some cases it could mean the Trustee is unable to put your pension into payment or has to stop your pension (if already in payment).
We may update this notice from time to time and will post any changes on this web page, as well as the date on which the change will take effect
Links to other sites
The Site may contain links to and from other websites, including sites operated by third parties. We have no control over any third party sites that link to or from the Site. If you follow a link to any third party websites, then please note that they will have their own separate privacy policies. Please check those privacy policies before you use or submit any personal information to third party websites. We do not accept any liability or responsibility for any third party websites, the privacy policies applicable to them or their use of the information that they collect from you.
If you have any queries in respect of the above, please contact the Secretary to the Trustee of the relevant Scheme(s) c/o Jaguar Land Rover, W/1/19, Abbey Road, Whitley, Coventry CV3 4LF.
Aon Hewitt Limited’s Privacy Notice
(applicable to all of the Schemes)
Aon Hewitt Limited (and the Scheme Actuary – together “Aon”) has been appointed to provide pensions advisory and calculation services that relate to your membership of the pension scheme. In doing so Aon will use personal information about you, such as your name and contact details, information about your pension contributions, age of retirement, and in some limited circumstances information about your health (where this impacts your retirement age) in order to be able to provide these services. The purposes for which we use personal information will include management of the pension scheme and your membership within it, funding the pension scheme (i.e. helping to ensure that the funds within the pension scheme are sufficient to cover the members who are party to it), liability management (that is to say providing advice on the different ways benefits could be determined, and drawn, from the pension scheme), scheme actuary duties (which include assessing individuals who are members of the pension scheme and assessing how the make-up of the membership may affect the amounts payable and when they become payable so as to manage the pension scheme appropriately), regulatory compliance, process and service improvement and benchmarking.
We may pass your personal information to third parties such as financial advisors and benefits providers, insurers, our affiliates and service providers and to certain regulatory bodies where legally required to do so. Depending on the circumstances, this may involve a transfer of data outside the UK and the European Economic Area to countries that have less robust data protection laws. Any such transfer will be made with appropriate safeguards in place.
More detail about Aon’s use of your personal information is set out in our full Privacy Notice.
We recommend that you review this notice which is available online at Aon website, or you can request a copy by contacting us, including reference to the scheme name, at: Data Protection Officer, Aon Hewitt Limited (Retirement and Investment UK), PO Box 730, Redhill, RH1 9FH