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Personal Data Privacy Statement

March 2018

Who we are

As the Trustee Directors of the Nestlé UK Pension Fund Trust Ltd (the Trustees), we hold certain personal information (known as “personal data”) about Nestlé UK Pension Fund (the ‘Fund’) members and, where applicable, their dependants and beneficiaries. Most of the personal data held and processed by the Trustees in running the Fund will be personal data (in other words, it is information from which you as an individual can be identified). The Trustees are the “data controller” of the Fund’s personal data.

Because he also needs access to the personal data that we hold on you in order to look after the scheme, The Scheme Actuary, Mr JD Jones of Lane Clark and Peacock LLP, is also a “data controller”. You can read more about this at www.lcp.uk.com/privacy-policy/

What information we collect about you

Depending on the circumstances and the stage of your membership, we may hold some or all of the following information about you:

How we use that information

The Trustees need to hold and process information about you because it is needed for us to administer the Fund and to calculate and pay benefits. In legal terms, this means that we have a legitimate interest in holding and processing the above information. We also keep the above information in order to allow us to comply with our obligations towards members under the Fund governing documents, as well as under relevant legislation. We will generally collect your personal data from you or from your employer. However, we may also receive personal data from other parties such as HM Revenue & Customs, the Pensions Ombudsman or someone acting on your behalf, such as an independent financial adviser. If you are receiving a dependant’s benefit from the Scheme, or a benefit resulting from divorce or the dissolution of a civil partnership, we may have been given your personal data by the member or through enquiries we’ve carried out on a member’s death. We will not collect any personal data from you that we do not need.

Personal data relating to the Fund is held on paper and on computer systems. As the “data controller”, the Trustees must process this information fairly and lawfully.

As part of running the Fund, we may also need to hold and process particularly sensitive information about you and/or your dependants and beneficiaries (known as “sensitive personal data”). Under the legislation, details relating to health, racial or ethnic origin, religious or other similar beliefs, sexual orientation and political affiliations are regarded as “sensitive personal data”. Except where the legislation allows it, this information cannot be processed or passed to a third party without your explicit consent.

Who we share it with

We are not allowed to share personal data about you with other organisations and people, unless the law allows us to do so or you have given your consent. As we need to share information with others in order to provide you with benefits, there is a legitimate interest in the Trustees sharing this information. We may also need to share it in order to meet contractual and other legal obligations.

We share personal data with the following:
How long we keep personal data for

We must keep all personal data safe and only hold it for as long as necessary. To meet the requirements of both UK tax and pensions law, we must keep certain personal data (for example, details about the date a member joins the Fund, their name and address, and details of benefits paid) for a minimum of 6 years. But, given the nature of pension schemes, the Trustees may be required to keep some of your personal information for the rest of your life so that we have the information we need in order to pay your benefits and to answer queries relating to your benefits.

We review the personal data held in relation to the Fund on a periodic basis in accordance with our data retention policy. If we conclude that certain personal data is no longer needed, that personal data will be destroyed.

Your rights

You should be aware that taking any of the above steps could impact on the payment of your benefits and/or your participation in the Fund.

Information will generally be provided to you free of charge, although the Trustees can charge a reasonable fee in certain circumstances.

Who to contact about your personal data
If you wish to:

please contact Nestlé Pensions in writing at:

Nestlé Pensions
1 City Place
Gatwick
RH6 0PA

Email: pensions@uk.nestle.com

Making a complaint to the Information Commissioner’s Office

If you are not satisfied with our response to any query you raise with us, or you believe we are processing your personal data in a way which is inconsistent with the law, you can complain to the Information Commissioner’s Office whose helpline number is: 0303 123 1113.