Under the Data Protection Act 1998, the Trustee of the Telefonica UK Pension Plan and the scheme actuary, Bart Huby of Lane Clark & Peacock LLP, are “data controllers” in relation to “personal data” of Plan members, their beneficiaries and other persons associated with them (each a “data subject”).  Personal data is information personal to an individual, and which identifies them, such as their name, address and National Insurance number.  Some of this information may be sensitive (such as details of health and personal relationships).


As “data controllers”, the Trustee and the scheme actuary process sensitive and non-sensitive personal data of “data subjects” for any purposes associated with the Plan.  They may process personal data themselves, or use carefully selected advisors and third parties (“data processors”) to help them.  They may also pass personal data to other third party data controllers for purposes associated with the Plan.


This may involve transferring personal data to third parties who advise or assist the Trustee and the scheme actuary, the sponsoring employer and any business associated with it, prospective purchasers of any of them (although in this latter case, where practicable, the data is anonymised), Government bodies, fund providers, insurance companies and persons associated with the Plan member.  This may also involve transferring personal data to organisations in countries outside the European Economic Area (the “EEA”).