Do we share your personal data with organisations from time to time?

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From time to time we will share your personal data with advisers and service providers so that they can help us carry out our duties, rights and discretions in relation to the Fund.  Some of those organisations will simply process your personal data on our behalf and in accordance with our instructions.
Other organisations will be responsible to you directly for their use of personal data that we share with them.  They are referred to as data controllers and we have highlighted them in the table below.  You will be able to find out about their own data protection policies (which will apply to their use of your data) on their websites.
These organisations include the Fund’s​:
Data Processors
Data Controllers
Administrator (Wirral Council)
Additional Voluntary Contribution providers (currently Equitable Life, Prudential and Standard Life)
Overseas payments provider to transmit payments to scheme member with non-UK accounts (currently Citibank UK)
Fund Actuary (currently Mercer UK)
Pensions software provider (currently Aquila Heywood)
External auditor (currently Grant Thornton UK LLP)
Address Tracing Services (currently LexisNexis)
Internal auditor (Wirral Council)
Mortality Screening Services GBG Group
Bulk Email Distribution (currently MailChimp)
LGPS National Insurance Database (South Yorkshire Pensions Authority)
Other Data Controllers
The Department for Work & Pensions (DWP)
The Government Actuary's Department (GAD)
The Cabinet Office  - for the purposes of the National Fraud Initiative
Her Majesty's Revenue & Customs (HMRC)
The Courts of England & Wales - for the purpose of processing pension sharing orders on divorce
In each case we will only do this to the extent that we consider the information is reasonably required for these purposes.
In addition, where we make Fund investments or seek to provide benefits for Fund members in other ways, such as through the use of insurance, 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.
From time to time we may provide some of your data to your employer and their relevant subsidiaries (and potential purchasers of their businesses) and advisers for the purposes of enabling your employer to understand its liabilities to the Scheme. Your employer would generally be a controller of the personal data shared with it in those circumstances. For example, where your employment is engaged in providing services subject to an outsourcing arrangement, the Administering Authority may provide information about your pension benefits to your employer and to potential bidders for that contract when it ends or is renewed.
Where requested or if we consider that it is reasonably required, we may also provide your data to government bodies and dispute resolution and law enforcement organisations, including those listed above, the Pensions Regulator, the Pensions Ombudsman and Her Majesty’s Revenue and Customs (HMRC).  They may then use the data to carry out their legal functions.
The organisations referred to in the paragraphs above may use the personal data to perform their functions in relation to the Fund 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.
In some cases these recipients may be outside the UK. This means your personal data may be transferred outside the EEA to a jurisdiction that may not offer an equivalent level of protection as is required by EEA countries. If this occurs, we are obliged to verify that appropriate safeguards are implemented with a view to protecting your data in accordance with applicable laws.  Please use the contact details below if you want more information about the safeguards that are currently in place.
We do not use your personal data for marketing purposes and will not share this data with anyone for the purpose of marketing to you or any beneficiary.