Privacy Notice for the members and beneficiaries of Merseyside Pension Fund

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This privacy notice is for members and beneficiaries of Merseyside Pension Fund (the “Fund”). It has been prepared by Wirral Metropolitan Borough Council (the “Administering Authority”, or “we”) in its capacity as the administering authority of the Fund.  As the Administering Authority of the Fund we hold certain information about you and from which you can be identified ("personal data") which we need to administer the Fund. 
 
What personal data do we hold?
The types of data we hold and process about you can include:
 
  • Contact details, including name, address, telephone numbers and email address.
  • Identifying details, including date of birth, national insurance number, employee membership numbers, and, if you have used a pensions dashboard to access information about your pension, a "pension identifier" (PEI), which is used to confirm a match and identify your specific benefits under the Fund for the purposes of displaying information via a dashboard.
  • Information that is used to calculate and assess eligibility for benefits, for example, length of service or membership and salary information.
  • Financial information relevant to the calculation or payment of benefits, for example, bank account 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 where your health is relevant to a claim for benefits following the death of a member of the Fund.
  • Information about a criminal conviction if this has resulted in you owing money to your employer or the Fund and the employer or Fund may be reimbursed from your benefits.
  • Information about any previous membership of other public service pension schemes and other LGPS administering authorities, including your date of leaving and whether the previous pension scheme/authority assessed your eligibility for underpin protection.
 
We obtain some of this personal data directly from you.  We may also obtain data (for example, salary information) and from other sources including public databases and the advisers and service providers that we may share your personal data which are listed in the Full Privacy Notice below.
 
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. You have the right to withdraw your consent to the processing at any time by notifying the Administering Authority in writing.
 
However, if you do not give consent, or subsequently withdraw it, the Administering Authority may not be able to process the relevant information to make decisions based on it, including decisions regarding the payment of your benefits.
 
What will we do with your personal data?
We will use this personal data to administer the Fund and to calculate and provide you (and, if you are a member of the Fund, your beneficiaries if you die) with benefits. We will also use this personal data for statistical and financial modelling and reference purposes (for example, when we assess how much money is needed to provide members' benefits and how that money should be invested), and to comply with our legal obligations. We will also use your personal data to facilitate your access your pensions information via a pensions dashboard. For more details about the purposes for which we process your personal data, please see the Full Privacy Notice below.
From time to time, we will share your personal data with third parties, including our contractors, advisors, government bodies and dispute resolution and law enforcement agencies and insurers in order to comply with our obligations under data protection legislation, and in connection with the provision of services that help us carry out our duties, rights and discretions in relation to the Fund.  These organisations are listed in the Full Privacy Notice.
 

We may also process your personal data to assess and, if appropriate, action a request you make to transfer your benefits out of the Fund.

In some cases recipients of your personal data may be outside the UK. If this occurs, we will make sure that additional safeguards are in place to protect your data in accordance with applicable data protection laws. Please use the contact details below if you want more information in connection with this.

What is the lawful basis for our use of your personal data?

The lawful basis for our use of your personal data will usually be that we need to process your personal data to satisfy our legal obligations as the Administering Authority of the Fund, including our obligations under the Pensions Dashboard Regulations 2022.

Where that lawful basis does not apply then the lawful basis for our use of your personal data will be one or more of the following:

  1. we need to process your personal data to carry out a task in the public interest or in the exercise of official authority in our capacity as a public body; and
  2. we need to process your personal data for the legitimate interests of administering and managing the Fund and liabilities under it, calculating, securing and paying benefits and performing our obligations and exercising any rights, duties and discretions the Administering Authority has in relation to the Fund; and
  3. because we need to process your personal data to meet our contractual obligations in relation to the Fund (for example, under an agreement that you will pay additional voluntary contributions to the Fund), or to take steps, at your request, before entering into a contract.

 

Please note that where we indicate that our processing of your personal data is necessary for us to comply with a legal obligation, or for us to take steps, at your request, to potentially enter into an employment contract with you, or to perform it, and you choose not to provide the relevant personal data to us, we may not be able to enter into or continue our contract with you.

How long do we keep your personal data?
We will only keep your personal data for as long as we need to in order to fulfil the purpose(s) for which it was collected and for so long afterwards as we consider may be required to deal with any questions or complaints that we may receive about our administration of the Fund, unless we elect to retain your data for a longer period to comply with our legal and regulatory obligations.
 
In practice, this means that your personal data will be retained for such period as you (or any beneficiary who receives benefits after your death) are entitled to benefits from the Fund and for so long afterwards as we consider may be required to deal with any questions or complaints that we may receive about our administration of the Fund.  For the same reason, your personal data may also need to be retained where you have received a transfer, or refund, from the Fund in respect of your benefit entitlement.
 
Where you seek to access your pensions information via a pensions dashboard, the pensions dashboard regulations require us to retain different types of information (some of which includes personal data) for specific periods, as described in more detail here: https://www.pensionsdashboardsprogramme.org.uk/standards/data-retention-schedule.
 
Do you have a right to access and obtain a copy of the personal data that we hold?
You have a right to access and obtain a copy of the personal data that the Administering Authority holds about you and to ask the Administering Authority to correct your personal data if there are any errors or it is out of date or incomplete.
 
In very limited circumstances, you may also have a right to ask the Administering Authority to restrict the processing of your personal data, or to transfer or (in extremely limited circumstances, such as where your personal data is no longer needed for the purpose for which it is being processed) erase your personal data. You should note that we are not obliged to erase your personal data if we need to process it for the purposes of administering the Fund.
 
You can obtain further information about these rights from the Information Commissioner’s Office at: www.ico.org.uk or via their 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 Fund Administrator as indicated below. You also have the right to lodge a complaint in relation to this privacy notice or the Administering Authority’s processing activities with the Information Commissioner’s Office which you can do through the website above or their telephone helpline.
 
The personal data we hold about you is used to administer your Fund benefits and we may from time to time ask for further information from you for this purpose.  If you do not provide such information, or ask that the personal data we already hold is deleted or restricted this may affect the payment of benefits to you (or your beneficiaries) under the Fund. In some cases it could mean the Administering Authority is unable to put your pension into payment or has to stop your pension (if already in payment).
 
 Full Privacy Notice (December 2025, PDF, 6 pages, 161kb)