The Bluesky Pension Scheme (Bluesky)

Privacy Notice

This notice explains how the Bluesky Pension Scheme and the trustees of Bluesky use and protect the personal information that they hold about members and other beneficiaries of Bluesky. The trustees change from time to time, but you can find out the names of the current trustees by using the contact details at the end of this notice.

The trustees are a "controller" for the purposes of the data protection laws. The current data protection laws are set out in the Data Protection Act 1998. These will be replaced by new data protection laws with effect from 25 May 2018. We refer to both the current and the new data protection laws as the “Data Protection Laws” in this privacy notice

You should share this notice with your family and dependants where you have provided us with personal information about them.

What is personal information?

Personal information broadly means information that identifies (or which could, with other information that we hold or are likely to hold, identify) a living individual.

This includes any information provided to us by or on behalf of you, Bluesky's employers or HM Revenue & Customs in relation to your membership of Bluesky.

What types of personal information might we hold about you?

We collect and process the information about you that you provide by filling in forms and by corresponding with us and our service providers by telephone, email or otherwise. We also collect and process information about you that is provided to us by the Scheme’s employers or by HM Revenue & Customs.

We may hold and process any or all of the following personal information about you: Why do we hold this information?

We hold this information because we need it to administer Bluesky. Without your personal information, we cannot provide you and your dependants with the correct benefits, at the right time. For example, we may need this information to verify your membership of Bluesky, to calculate your pension or to assess whether you are entitled to a specific benefit or how the tax rules apply to you.

We may use unique identifier information, such as your National Insurance number, passport number, pension or member reference number and employee number (where applicable) for the purposes of sending communications to you and verifying your identity.

In some instances, we may need to hold and process information relating to your physical or mental health, for example if you are applying for a pension on grounds of ill-health. We will ask for your explicit consent to this, unless there is an alternative legal basis for processing this information under the Data Protection Laws. Once you have given your consent, you can withdraw it at any time by writing to us using the contact details below.

Using your information in accordance with Data Protection Laws

Data Protection Laws require us to meet certain conditions before we are allowed to use your personal information in the way described in this privacy notice.

We rely on a condition that allows us to use your personal information to comply with our legal obligations in relation to Bluesky. We also rely on a condition known as 'legitimate interests' in order to use this information in the way described in this privacy notice. We have legitimate interests in collecting and processing your personal information as we need this to administer Bluesky and to provide benefits for you and your dependants.

We will keep the amount of personal information collected and the extent of any processing to a minimum.

We will only process ‘sensitive’ or ‘special categories' of personal information under the Data Protection Laws (e.g. information about your health) where you have explicitly consented to this or where there is an alternative legal basis for processing this information under the Data Protection Laws. This may mean that you will be asked to sign consent forms in the future. If you don't consent to our processing this information when asked to do so, it may mean that we are unable to pay benefits to you or your dependants. Once you have given your consent, you can withdraw it at any time by writing to us using the contact details below.

We will only process information about criminal convictions if these relate to money owed to Bluesky's employers in circumstances where they are entitled to be reimbursed from your benefits and either you consent to this or the processing is necessary for the exercise of a legal claim.

What do we do with the information?

We may use your personal information for a number of purposes relating to the administration of Bluesky, including the following:

How long do we keep your information for?

We will hold your personal information on our systems for as long as is necessary for Bluesky to provide benefits to you or your dependants.

So, for example, if your pension is paid from Bluesky when you retire, we will hold your information for the rest of your life, until your pension ceases on your death. If a pension is payable to any of your dependants after your death, we will then continue to hold your information until their pensions cease. We will then continue to hold your information for an indefinite period after all benefits payable to you and your dependants have ceased, in case there are any further queries about your membership of Bluesky.

If you cease to be a member of Bluesky (e.g. because you transfer your benefits to another pension arrangement), we will hold your information whilst you are a member and then for an indefinite period after you cease to be a member, in case any further queries arise about your membership of Bluesky.

Who do we share the information with?

Where appropriate for the purposes of administering Bluesky, we may share your information with:

These organisations use the information when advising the trustees and carrying out their respective professional obligations.

The entities listed above may also share personal data with their own business suppliers, for example in relation to the operation of IT systems or where they outsource part of their services. Some of these entities may also be controllers under the Data Protection Laws. However, in the first instance you should contact the trustees using the contact details below if you have any queries about how they use your personal information.

Please note that some of Bluesky's former service providers may continue to hold information about you for their own record keeping purposes once they have ceased to be involved with Bluesky.

Where we store your personal data

The data that we collect from you will be stored inside the UK. However, if you live or work outside of the UK or the EEA, we may need to transfer your personal data outside of the UK or the EEA to respond to any queries that you may have. Where this applies, we will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy notice.

Data may also be transferred outside the UK or the EEA where Bluesky's service providers host data outside the UK or the EEA. These transfers will be governed by the Data Protection Laws.

Your rights in relation to your personal information

The accuracy of the information that we hold about you is important to us. If any of the information that we hold is inaccurate or out of date, please let us know using the contact details set out at the end of this notice.

You have a number of rights under the Data Protection Laws in relation to the way we process your personal data, namely:

If you wish to exercise any of these rights, please let us know using the contact details set out at the end of this notice.

We will aim to respond to any request received from you within one month from your request.

Access to your data will usually be provided free of charge, although in certain circumstances we may make a small charge where entitled to do so under the Data Protection Laws.

Please note that we may be unable to delete or remove your data whilst we still need this to administer Bluesky – see the section 'How long do we keep information for?' above.

Any complaints?

If you are not happy with the way in which your personal information is held or processed, please contact us using the details below. You also have the right to complain about data protection matters to the Information Commissioner's Office (ICO).

The ICO is the UK's independent body set up to uphold information rights. You can find out more about the ICO on its website (www.ico.org.uk).

The ICO can be contacted by calling 0303 123 1113.

Changes to this privacy notice

This privacy notice is current as at 15 May 2018.

We keep our privacy notice under regular review, and may change it at any time. We will tell you about any significant changes.

Contact us

If you have any questions about Bluesky, queries about this privacy notice, or wish to exercise any of the rights above, please contact:

Bluesky
Evolve Pensions Limited
PO Box 128
Swanley
BR8 9BJ

To contact the Data Protection Contact, please contact:

Jessica Rigby
Data Protection Contact
Evolve Pensions Limited
PO Box 128
Swanley
BR8 9BJ

Dated 15 May 2018