This notice sets out how the following entities (“we”, “us” and “our”) use and protect your personal data in accordance with applicable data protection law:
- Your employer – see your employment contract for the identity and contact details of your employer or contact your local HR team;
- Associated British Foods Pension Trustees Limited (00628939) of Weston Centre, 10 Grosvenor Street, London, W1K 4QY, trustees of the Associated British Foods Pension Scheme for ABF's UK businesses and other participating employers (the "ABF Scheme");
- Trustees of the Weston Provident Fund (283311) of 50-51 Russell Square, London, WC1B 4JU ("WPF"), a charitable fund that assists with the welfare of employees and former employees of ABF or their dependants in the UK.
It also describes your data protection rights (including the right to object to some of the data handling we carry out).
More information about your rights and how you can exercise them is set out in the "Your rights" section below.
References to "you" and "your" in this notice refer to any potential, current or former ABF Scheme members, their relatives, dependants and nominated beneficiaries, and potential, current or former beneficiaries of the fund operated by WPF and their relatives, dependants and nominated beneficiaries.
Not all of us will be using and processing your data in accordance with this notice. An ABF employer will only be using and processing your data if you are a current or former employee of a company in the ABF Group. The ABF Scheme will only use and process your data if you become a member of the ABF Scheme. The WPF will only use and process your data if you are eligible for a charitable grant.
Further information regarding the way in which we use your personal data is set out in Annex 1.
Please see the breakdown for further information about what data we collect and how it will be used.
We process the following personal data:
Personal Identification and Communication Information: your name, home address, date of birth, phone number, email address, nationality, gender, employee payroll number, and national insurance number;
Family and Other Social Circumstances Information: your nominated beneficiaries’, dependant's and relatives' details, marital status, applications for early retirement or distribution of death benefits. We will also ask for copies of certain identification documents before we can pay any benefits due to you (such as birth certificates, marriage certificates and passports) to comply with Anti Money Laundering regulations;
Employment and Pension Scheme Membership Details: pensionable pay, length of service, retirement date, employment and career history, job title, financial details such as income, salary, assets and investments held within the Scheme, bank account details to process pension payments, benefit grants, automatic enrolment history and any registered tax protection status which you may disclose to us; and
Benefit Related Information: medical or other unpaid leave information and any medical certificates or other documents so we can assess eligibility for, and to support your application for, certain benefits or cover (including death in service cover, ill health benefits or incapacity retirement under the ABF Scheme) or grants from the WPF (as described in more detail within Annex 1).
We will usually only ask you to supply your personal data which is necessary in order to fulfil the purposes described in this notice. However, whenever we ask you to supply us with personal data and the provision of this data is optional we will tell you about this and where relevant we will explain what the consequences will be if you decide not to provide the requested information.
Please ensure that if you provide personal data about your relatives, dependants or nominated beneficiaries to us, you have provided this notice to them.
Sensitive personal data includes, amongst other things, personal data concerning health or a person’s sexual orientation. Where sensitive personal data is collected, we will ensure that any additional legal requirements are complied with.
Further information about the way in which we protect your personal data is available from us on request using the details provided below.
We will each use your personal data for the following reasons:
- compliance with the automatic enrolment legislation, including assessing your eligibility for automatic enrolment, communicating with you about how automatic enrolment applies to you, and enrolling you into the ABF Schemes, and / or opting you in or out of the ABF Scheme when you choose to do so;
- providing employment-related information about scheme members to the Trustees to assist in the administration of the ABF Scheme
Associated British Foods Pension Trustees Limited:
- administering the ABF Scheme, including communicating with you (for example providing information about the Scheme and benefits as well as any changes to them), ensuring the security of members’ benefits, assessing and processing applications for cover and benefits, processing contributions and benefits and making payments to members and nominated beneficiaries;
- for internal and legislative record-keeping purposes;
- to make disclosures as required by law; and
- for scheme financing/funding and for risk management purposes (including credit risk analysis, and for the insurance of longevity risks and related demographic risks).
Trustees of the Weston Provident Fund:
- operating and administrating charitable grants, including communicating with you and your nominated beneficiaries (for example, providing information about the fund, benefits, and any changes to them), assessing eligibility for charitable grants (in particular, identifying members who may be eligible for a grant and determining who will receive a grant on a discretionary basis, taking into account information we already hold (including the pension benefit which you may receive from us and any additional information you provide to support your application)) and processing contributions and benefits and making payments to members and nominated beneficiaries;
- for internal and legislative record-keeping purposes;
- to make disclosures as required by law;
- for internal and legislative record keeping purposes; and
- for fund financing / funding and for risk management purposes (including, credit risk analysis and the insurance of longevity risks and related demographic risks).
Further information about the way in which your personal data is used for these purposes is included in the table in Annex 1 of this notice. This table explains the legal bases that we rely on when we use your data for each of these purposes. For example:
- in some cases, we use your personal data in order to perform a contract between us and you;
- in some cases, we use your personal data in order to comply with the law;
- in some cases, we will use your personal data because this is necessary for a legitimate interest which is not overridden by your own privacy interests; and
- in exceptional circumstances, we can only use your personal data if you consent. If we ask you for your consent so that we can use your data for a particular purpose, we will remind you that you are free to withdraw your consent at any time and will tell you how you can do this.
- In some cases, and in relation to your sensitive personal data, we may also use your data in order to comply with obligations arising in connection with your employment or former employment with ABF
We will your personal data in a form that identifies you for no longer than is necessary for the purposes for which the personal data is processed.
Personal data collected for pension purposes will usually need to be retained on a long-term basis and therefore personal data will generally be retained for 110 years from your date of birth, except should you no longer hold any further liability within the Scheme (for example, you take a full refund or a transfer out), then any data no longer required will be cleared down 6 years after the event that removed the liability from the Scheme (leaving a shell record as proof that the liability was removed).
We each ensure that we comply with the applicable legal requirements when transferring personal data outside the European Economic Area (the "EEA") (i.e. all 27 EU Member States plus Iceland, Liechtenstein and Norway). Further information regarding these data transfers (including the destination territories) is set out in Annex 1 of this notice and can be obtained from us on 0800 090 2267 (+44 (0)20 7636 8111 from outside the UK) or email email@example.com.
We have taken appropriate technical, administrative, physical and procedural security measures, consistent with local and international information practices, to protect your personal data from misuse, unauthorised access or disclosure, loss, alteration, or destruction.
If you wish to access your personal data or exercise any of your rights you should contact us on 0800 090 2267 (+44 (0)20 7636 8111 from outside the UK) or email firstname.lastname@example.org.
You have the right to ask each of us to rectify, block, complete and delete your personal data, to restrict its use, and to ‘port’ your personal data (that is, to ask for it to be provided to you in a structured, commonly-used and machine readable format and to transmit it directly to another organisation). You also have the right to request a copy of your personal data.
You also have the right to object to the processing of your data by each of us in some circumstances, in particular where we don’t have a legitimate interest to process the data or need to process the data to meet a contractual or other legal requirement.
There are exceptions to these rights, however. For example, it will not be possible for us to delete your data if we are required by law to keep it. Similarly, access to your data may be refused if making the information available would reveal personal information about another person or if we are legally prevented from disclosing such information.
You also have the right to make a complaint to the data protection supervisory authority or to seek a remedy through the courts if you believe that your rights have been breached.