Data protection notice for Plan participants and beneficiaries
This data privacy notice is provided by Cummins UK Pension Plan Trustee Limited (the Trustee) to Cummins UK Pension Plan (the Plan) participants and their beneficiaries. The notice is intended to inform you about how the Trustee collects and processes personal data in connection with the Plan, and about your data privacy rights in relation to the data that is collected and held about you.
Personal information is information, or a combination of pieces of information, that could reasonably allow you to be identified.
Data collection and use
The personal data that the Trustee collects from you and processes in relation to the Plan is limited to that which is relevant and/or required for enrolling you in the Plan and administering it. Generally, the data elements that are collected include:
- personal details (for example, your full name, WWID, birth date)
- your contact details (for example, your phone number, home and business address, email address)
- information necessary to calculate and pay your contributions or benefits (for example, your job title, hire date, employee type (e.g., full or part-time) and other employment history, your salary and expected retirement date)
- bank details and National Insurance number
- details about who you would like us to consider paying benefits to if you die and other relevant beneficiary information.
Almost all of this information is already collected from you in relation to your employment with Cummins. We may also collect some sensitive personal data to administer your benefits under the Plan (for example, to allow for early retirement on grounds of ill health).
The information that the Trustee collects is used for a number of reasons, including to establish and maintain your pension benefits, facilitate pension pay outs to you upon retirement, and to comply with its legal and administrative obligations. The personal data is not used for purposes unrelated to the Plan.
The Trustee must have a legal reason to use your personal data. This will usually be one of the following:
- to fulfil its legal obligations, such as giving you specified information about your benefits as required by pension legislation
- to meet its legitimate interests to administer the Plan efficiently and to pay benefits to you and your survivors in accordance with the Plan rules
- because the Trustee needs to use the information to fulfil its obligations (for example, to pay ill-health pensions or benefits after your death) and its use of the information is authorised by law
- because the information is necessary in relation to a legal claim.
In a few cases, especially where you’ve given the Trustee information about your health, it may ask for your consent to process your data. Where this applies, you may take back your consent at any time by contacting the Plan administrator, Isio at: [email protected] or telephone 0800 122 3266.
Access and sharing
The Trustee limits access to the personal data collected in relation to the Plan to individuals employed by Cummins, whose job responsibilities require such access. The Trustee also shares that data with third parties who assist it in administering the Plan and making payments to you, such as:
- the Plan’s administrators and the Trustee’s advisers (such as the Plan actuary and legal advisers)
- His Majesty’s Revenue and Customs (HMRC) and other government organisations, including potentially the Pensions Regulator and the Pension Protection Fund
- insurance companies or other occupational pension schemes and their advisers with a view to securing benefits through long-term insurance policies or a merger of schemes.
We may also provide some of your personal data to Cummins to help it to make decisions relevant to its role as principal employer. The Trustee only does so to the extent it considers necessary for these purposes.
Third parties are required to provide written assurances that they will uphold an equivalent level of protection for your data and comply with applicable data protection law. The Trustee does not permit those third parties or anyone else assisting them to use your data for a purpose unrelated to the Plan.
The Trustee has put in place technical and organisational safeguards that are consistent with its legal obligations and designed to protect your data from loss, misuse, alternation, destruction or unauthorised access. Those safeguards are updated as the legal requirements and security threats evolve, in order to best ensure that your data continues to be appropriately safeguarded.
Because Cummins and some of the Trustee’s advisers are global organisations, some of your personal data will be transferred, processed or stored outside of the UK. While data protection laws and requirements in other countries do not always offer the same level of protection as those in the UK, where personal data is stored on Cummins’ systems, steps are taken to ensure that your personal data is protected in a manner consistent with the UK Data Protection Act 2018 to ensure that applicable data transfer requirements are appropriately fulfilled or exceeded if data is transferred outside of the UK. In general, Cummins and the Trustee rely on the EU Standard Contractual Clauses for transfers of UK personal data to countries that have not received an ‘adequacy’ determination from the UK Information Commissioner’s Office (ICO).
You have the right to contact the Trustee to ask questions about your data or, in certain circumstances, to access, correct, delete or transfer your personal data. You also have the right to object to the processing of your data if you believe it was collected in violation of the data protection laws. The Plan upholds those rights in a manner consistent with applicable laws. However, if you’re unsatisfied with the outcome of your request to the Plan or believe that your data has been mismanaged, you also have the right to file a claim with the ICO.
The Trustee retains personal data of the Plan’s participants and their beneficiaries for as long as it has a relationship with you or your beneficiaries. When deciding how long to keep personal information after such relationships end, the Trustee takes into account its legal obligations and regulators’ expectations. It may also retain records to investigate or defend potential legal claims. Any data that is not retained will be securely destroyed.
Accuracy of the data
The Trustee takes steps to ensure that the information it collects, processes and holds about Plan participants and their beneficiaries is accurate and complete. The Trustee asks that you notify us promptly should any of your information change (e.g., address, contact details, beneficiaries).
Questions or concerns
If you have a question for the Trustee about your data, please email the Plan administrator, Isio at [email protected] or telephone 0800 122 3266.