The Honourable Society of the Inner Temple Pension and Life Assurance Scheme

Who we are

The Inner Temple Pension and Life Assurance Scheme (the “Scheme”) is managed by the trustees of the Scheme (“the Trustee”).

As the Trustee of the Scheme, we hold certain personal information (known as “personal data”) about Scheme members and, where applicable, their dependants and beneficiaries.  Most of the information held about you and processed by the Trustee in running the Scheme will be personal data.

For legal purposes, the Trustee is known as the “data controller”, as we decide the purposes for and the means by which the personal data we hold is processed.

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:

• your name
• your age and date of birth
• your gender
• your marital status
• your address and other contact details
• your national insurance number
• information about your benefits under the Scheme, including pensions and death benefits
• your pensionable service
• relevant employment information, such as current and past salary information, pensionable pay, salary caps, employment dates, length of service and career history (where relevant)
• details of your bank account (to pay benefits)
• details about your dependants and/or beneficiaries (including their names and possibly details of their gender and marital status)
• medical and other details about your health.

In order to administer the Scheme properly and to calculate and pay benefits, from time to time we may also need to hold other information about you.

How we gather your personal information

Your personal data will generally be collected directly 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 undertaken by us on a member’s death. We will not collect any personal data that we do not need.

How we use that information

The Trustee has a legitimate interest in holding and processing the above information about you as it is needed for us properly to administer the Scheme and to calculate and pay benefits.  We also keep the above information in order to allow us to comply with our obligations towards members under the Scheme governing documents, as well as under relevant legislation.

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

As part of running the Scheme, 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 disclose personal data about you to other parties except:

• when required for contractual or legal reasons or other specifically identified purposes; or
• where you have given your consent.

However, as the Trustee needs help from various advisers to administer the Scheme properly, we share personal data with the following:

• your employer or any sponsor of the Scheme
• the Trustee’s professional advisers, including the Scheme actuary, auditor, medical advisers, investment consultant and lawyers
• the third parties who are responsible for the day-to-day administration of the Scheme on behalf of the Trustee (including the Scheme administrator which, at the time of issuing this notice, is Quantum Advisory LLP)
• HM Revenue & Customs and other statutory bodies (such as the Pensions Ombudsman and the Pensions Regulator) – the Trustee can be fined and subject to other action if it fails to provide certain information to these authorities
• the advisers and printers who help us prepare various communications we send to you, such as the annual benefit statement
• our appointed insurance company or companies for the purposes of life insurance and additional voluntary contributions
• tracing agencies who assist the Trustee with updating Scheme data from time to time
• BACS (the Bankers’ Automated Clearing Service) and CHAPS (the Clearing House Automated Payment System) for payments in the UK and other banking providers when pensions are being paid overseas

The Scheme’s actuary (currently Simon Hubbard of Quantum Advisory LLP) and Quantum Advisory LLP in providing actuarial services act as joint data controllers with the Trustee in relation to your personal data. This means that they have to comply with the requirements of data protection legislation, as well as relevant industry codes and standards, when processing your personal data. For more information about what personal data they hold about you and how they use it, please visit the following link:

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 a minimum of six years.  But, given the nature of pension schemes, the Trustee may be required to keep some of your personal data for the life of the Scheme. However, if we conclude that certain personal data is no longer needed, that personal data will generally be destroyed.

Your rights

• Right of Access – you have the right to see personal data that is held about you and a right to have a copy provided to you, or someone else on your behalf, in a machine readable (namely, digital) format
• Right to Rectification – if at any point you believe that the personal data we hold about you is inaccurate/wrong, you can ask to have it corrected
• Right to restrict processing – you can require the Trustee to restrict the processing of your personal data in certain circumstances, for example, whilst a complaint about its accuracy is being resolved
• Right to object to processing – as we are relying on legitimate interests as a reason for processing, you can object to your personal data being processed, although the Trustee can override this objection in certain circumstances
• Withdrawing consent – where you have given us your consent to processing your personal data, you can withdraw that consent at any time by notifying us (see “Who to contact” below). However, withdrawing your consent will not affect the processing of any personal data which took place beforehand and it may be possible for the Trustee to continue processing your personal data where this is justified
• Right to be forgotten – you can request that your personal data is deleted altogether, although the Trustee can override this request in certain circumstances
• Right to complain – you have the right to complain to the Information Commissioner’s Office, or to bring an action before the court, if your personal data rights are not complied with (see “Making a complaint to the Information Commissioner’s Office” below)

You should be aware that taking any of the above steps could impact on the payment of your benefits, your participation in the Scheme, and/or our ability to answer questions relating to your benefits.

Information will generally be provided free of charge, although the Trustee may charge a small fee to cover the administration costs involved in providing you with a copy of your personal data.

Who to contact about your personal data

If you wish to:

• see your personal data or to exercise any of the rights mentioned above
• request a hard copy of the notice
• make a complaint about how we have handled your personal data

please contact Quantum Advisory LLP as administrator:

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.

Updates to this notice

This notice is the latest version as at September 2019. This notice will be updated from time to time and you can see the current version at any time on the employer website at innertemple.org.uk/pensions. Alternatively, if you would prefer to receive a hard copy of the notice, please let us know (see “Who to contact” above).