Privacy Notice - Data Protection
Carillion Pension Plan Trustee Limited is the Trustee of the Carillion Pension Plan ("the Plan").
We gather, hold and use personal information (also known as personal data) relating to members and former members of CPP, their family and dependants. We are committed to protecting, keeping secure and processing fairly and lawfully the personal information we gather, hold and use. This Privacy Notice explains how we do this.
We will amend this Privacy Notice from time to time to keep it up to date.
If you would like a hard copy of the Privacy Notice please contact the Secretary to the Trustee (see below for contact details)
Where you have provided us with personal data about other individuals, such as family members or your other dependents, please ensure that they are aware of the information contained within this notice.
1 About the Trustee
For the purposes of the data protection laws, we are a 'controller' of the personal information we gather, hold and use about you, your family and other dependents as we decide the purposes for and how the personal information we gather and use is processed.
2 The kinds of personal information we gather and use
We use different types of personal information depending on a person's circumstances at the time. This may include some or all the following information about you, your family and other dependents:
name (including former names), date of birth, gender, status - whether single, married, in a civil partnership or other relationship akin to marriage or civil partnership, postal address (and former addresses), telephone number (s), email address, Cookie id, IP address, national insurance number, employee and/or scheme number, tax details, details of bank account for the purpose of paying benefits, details about your dependants and/or beneficiaries (including their names and possibly details of their gender), details about investment choices, contribution history and your intended retirement date.
As part of running the CPP, we may also need to hold and process particularly sensitive information about you and/or your dependents and beneficiaries (known as "sensitive personal data"). See below for further details.
3 How we gather your personal information
We gather personal information from many sources including the following:
4 Our legal basis for using your personal information
We use personal information to comply with our legal obligations to provide benefits as well as complying with the legal requirements governing the operation of pension schemes. In addition, we have a legitimate interest in processing personal information about you so that we can amongst other things properly administer the CPP.
Although you can object to processing on this latter ground, this objection can be overridden where there are compelling reasons (e.g. because we need to process personal information to meet our legal obligation to pay benefits).
5 Special categories of data
Where special categories of personal information are processed, such as information about an individual's health or sexual orientation, further legal grounds apply:
Where we have your consent, you have the right to withdraw it. We will let you know how to do that at the time we gather your consent.
6 How we use your personal information
We gather, hold and use personal data to meet the legal requirements referred to in section 4 above:
We may, subject to compliance with the data protection laws, process personal information for another purpose if that purpose is compatible with the purposes set out above.
7 Sharing your personal information with others
We share personal data we hold with the trusted third parties including those set out below.
For administration purposes:
For compliance purposes
For other purposes
Some of the organisations referred to above 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.
8 Security and save storage of your personal data
The security of the data we hold is very important to us and we take this seriously. We will use appropriate procedures and security features to process and protect your information as will the third parties we engage for the purposes of the CPP. Any transfer of your personal data is done securely and consideration is always given to the most secure and efficient way of doing this such as the anonymisation of CPP personal data.
9 International transfers
The data protection laws restrict transfers of personal data outside of the EEA, unless there is adequate protection for the data or prescribed steps have been taken to ensure that the data is protected. Where any third party engaged by the Trustee or a third party with whom the trustee shares date wishes to process data outside of the EEA they must inform the Trustee and commit to ensuring that such processing complies with the stringent security measures we require and which comply with the data protection laws.
10 How long we keep your personal information for
We keep all personal data safe and secure and only hold it for as long as necessary. We will keep relevant personal information for as long is required to meet the purposes for which it was collected. In practice, this means for the life of the member, or the life of the last remaining beneficiary associated with the member, plus 7 years. However, there may be reasons why we need to keep data for longer such as for claims, data migration or archiving purposes. We will review the personal information we hold in relation. If the decision is taken that certain personal information is no longer needed, the personal information will generally be destroyed, erased or made inaccessible.
11 Your privacy rights
You have the following legal rights in relation to the personal information we hold about you:
Access to your personal information - you can request access to a copy of the personal information that we hold about you. Please make all requests in writing. You may be asked for evidence of your identity. Information will generally be provided to you free of charge, although we can charge a reasonable fee in certain circumstances. Please note that we can in some circumstances refuse to act on requests.
Correction - you can ask us to change or complete any inaccurate or incomplete personal information held about you.
Erasure - you can ask us to delete your personal information where it is no longer necessary for us to use it or where we have no lawful basis for keeping it
Restriction - you can ask us to restrict the personal information we use about you in certain circumstances, for example, whilst a complaint about its accuracy is being resolved.
Please note that your request to restrict processing or to erase your data can be overridden in certain circumstances.
Make a complaint - 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 (ICO) whose helpline number is: 0303 123 1113. The details for the ICO's website are ico.org.uk.
12 Who to contact about your personal data
If you wish to:
Please initially contact the Secretary to the Trustee, Carillion Pension Plan Trustees Limited, Carillion House, 84 Salop Street, Wolverhampton WV3 0SR*
* Due to the liquidation of Carillion plc (and its associated subsidiaries) an alternative contact for any queries will be provided in due course. Any queries on members' benefits should continue to be addressed directly to JLT Employee Benefits, Post Handling Centre "U", St James's Tower, 7 Charlotte Street, Manchester M1 4DZ (Tel: 01372 200355) or to firstname.lastname@example.org
Members can also access details of their Account at https://www.ama.jltgroup.com (log-in required).
Please quote your date of birth, membership number and/or National Insurance number in any correspondence.
Other Information about the Plan
The State Pension
Being a member of the Plan does not affect your right to a State Pension. As long as you have paid enough National Insurance Contributions, under the current legislation, you will receive a State Pension from State Pension Age.
For more details about the State Pension, please vist the Government's website: www.gov.uk
The Trustee - Carillion Pension Plan Trustees Limited
The Plan is set up under a Trust and its assets are legally separate from those of the Company. The Group's creditors have no claims over members' pension savings. The Plan continues to be managed by an independent Trust Company, Carillion Pension Plan Trustees Limited, and continues to operate, for the immediate future, as an open Plan.
There are currently up to eight Directors under the Trust Company, four of whom are nominated and selected by the Plan membership and four of previously nominated by Carillion plc. The current company nominated Directors are Richard Tapp (Chairman), Dean Smith, and Sally Spencer, with one vacancy. The current member nominated Director is Steven Brunswick with three vacancies due to employees recently leaving the business. The current Secretary to the Trustee is Peter Clarke.
All of the Directors have access to specialist training and the Trust Company has appointed professional advisers to assist with the management of the Plan - an auditor, investment adviser and solicitor - and a pensions administration company, who regularly attend the Trustee meetings. The Trustee normallly meets at least four times a year.
The Trustee may be contacted at the following address: Carillion Pension Plan Trustees Limited, Carillion House, 84 Salop Street, Wolverhampton WV3 0SR.
Annual Report & Chairman's Statement
Every year the Trustee normally produces an annual Report and Accounts setting out the Plan's financial position and how the investments have performed. You can ask the Plan administrator, JLT, for a full copy of the Report and Accounts, which includes the Chairman's Statement for the year covering the governance arrangements for the Plan, including the statutory "value for members" assessment and disclosure of investment charges under the Plan.
For 2017, the accounting period has been extended, due to Carillion plc (and other Plan employers) being placed into liquidation, to 31 March 2018. The 2017 audited accounts will therefore be signed off in August 2018 this year.
Benefit statements are normally issued annually in June each year by the Plan administrator but are being deferred in 2018 due to the high volume of leaver statements being issued. The Benefit statements normally confirm the contributions paid during the Plan Year (which is normally the Pension Input Amount for the Plan) and the Account value at 1 April and the current investment choices, however members can view details of their Account at any time on the member secure site (log-in required): https://ama.jltgroup.com
Further details are available on request to the Plan administrators.
Fund Fact Sheets
Fund Fact sheets setting out more details on the funds, the managements costs, benchmarks and performance are available on request from the Plan administrator.
Statement of Investment Principles ("SIP")
The Trustee maintains a Statement of Investment Principles ("SIP") setting out the principles around the investment decisions they have reached after taking advice from a qualified person and on the governance arrangements around them. A copy is available on request from the Plan administrators, JLT.
Your Plan benefits are personal to you. You cannot charge, assign or otherwise dispose of them to anyone else. If you try, you may forfeit them.
If you leave your employer owing money as a result of any criminal, negligent or fraudulent act or omission by you, what you owe may be recovered from your account.
Future Amendments to the Plan
Although the Trustee is responsible for the management of the Plan, the benefits and contributions offered to employees were determined by the Company as part of their Reward strategy.
The Plan is currently continuing to operate as an "open" plan for the immediate future following Carillion plc being placed into liquidation on 15 January 2018. If the Plan is subsequently clsoed and "wound up", benefits will be paid to the members according to the Trust Deed and Rules. The Trustees would separately notify the members of any changes in advance of them being implemented and provide details of how their benefits may be affected in wind-up.
A copy of the Trust Deed and Rules is available on request from the Plan administrators, JLT or the Secretary to the Trustee.
Disputes are rare and hopefully normally resolved quickly. If you do have a complaint or dispute about the Plan, you should raise it with the Secretary to the Trustee first. In most cases, a simple explanation is enough to resolve the dispute. If you are unhappy with the Secretary's explanation, you can use the formal complaints procedure. You can ask the Secretary for a complaints form, which explains how to make a complaint. The Secretary will then normally give you a written reply within two months of receiving your completed form. In some circumstances, the two month deadline can be extended, in which case you will be told.
If you are not happy with the Secretary's written reply, you can appeal to the Trustee. Details of how to do this will be sent with the written reply.
You can contact the Secretary by writing. Please address letters to the Secretary to the Carillion Pension Plan at Carillion House, 4th Floor, Salop Street, Wolverhampton WV3 0SR.
Other Sources of Help
The Pensions Ombudsman (TPO)
TPO is available at any time to assist members and beneficiaries with any pension's query they may have, or any complaint or difficulty which they have failed to resolve with the Trustee.
You can contact TPO at:
10 South Colonnade
London E14 4PU
Phone: 0800 917 4487 (option 1)
Control Version: 21 May 2018