Privacy Notice – personal information about our members and their survivors¹

As Trustee of the Scheme we need to collect and use personal information about our members and their survivors. This privacy notice sets out how we collect, use and protect your personal information and your rights in relation to your information.

Personal information is information, or a combination of pieces of information, that could reasonably allow you to be identified.Personal information we use

We hold or will collect personal information about you from a variety of sources, including information from you directly, information provided by the Scheme's employers and information we get from other sources, including public databases.

What Information may we collect directly from you?

The categories of personal information that we collect directly from you include:

1. personal details (for example, your name, date of birth, marital status);

2. your bank details and National Insurance number;

3. your contact details (for example, your address, phone number and email address);

4. details about who you would like us to consider paying benefits to if you die including, but not limited to, details about your spouse or civil partner;

5. if you have paid additional voluntary contributions, your choice of fund for investing your contributions;

6. whether you have elected to participate in the salary sacrifice scheme.

What information may we collect from other sources (such as your employer)?

These are examples of categories of information we may collect from other sources:

1. personal details (for example, your name, date of birth, marital status);

2. your contact details (for example, your address, phone number and email address):

3. information necessary to calculate and pay your contributions or benefits (for example, your employment history including your pay and any family leave or any other absence from work).

How will we use your personal information and why?

The ways we use your information include:

1. identifying you and your survivors and making sure your details are up to date;

2. communicating with you;

3. calculating and paying your benefits and any benefits payable to your survivors;

4. making trustee decisions – such as whether to agree to early retirement or how to distribute benefits after your death;

5. calculating the actuarial liabilities of the Scheme;

6. if you have paid additional voluntary contributions to the Scheme we may use your information to decide how to invest assets allocated to your account.

Legal basis for using your personal information

We must have a legal reason to use your personal information. This will usually be one of the following:

1. to fulfill our legal obligations (including any contractual obligations), which includes making sure that your benefits are paid correctly;

2. to meet our legitimate interests to administer the Scheme efficiently;

3. to meet AA Developments Limited's (the Principal Employer) legitimate interests in managing and funding the liabilities in the Scheme;

4. because using the information is necessary in relation to a legal claim.

In a few cases, especially where you have given us information about your health, we need your consent to process your data. Where this applies, you may take back your consent at any time by contacting the Head of Pensions using the contact details listed below.

Information sharing

1. We may share personal information with:

   1. the Scheme's administrators, payroll providers, and our advisers (for example the Scheme actuary, our auditors, our medical advisers and our legal advisers) and their sub-contractors to facilitate the administration of the Scheme and your benefits;

   2. other medical advisers where you have requested an ill health pension;

   3. Her Majesty's Revenue and Customs (HMRC) and other Government organisations, including but not limited to the Pensions Regulator, the Pensions Ombudsman and the Pension Protection Fund;

   4. insurance companies or other occupational pension schemes and their advisers with a view to investing in or securing benefits through long term insurance policies or a merger of schemes;

   5. insurance brokers for the purposes of insuring lump sum death benefits or in connection with the Trustee's insurance;

   6. the providers of funds in which members with additional voluntary contributions can choose to invest;

   7. independent financial advisers to enable them to advise on your benefits in the Scheme;

   8. companies who specialise in helping pension schemes to communicate with members about their benefits.

2. We may also provide some of your personal information to the Principal Employer and its advisers to help it to make decisions connected to its role as the Principal Employer. We will only do so to the extent we consider necessary for these purposes.

3. 
   

Security and storage

We have in place measures to protect the security of your personal information and keep it confidential. We review these measures regularly to make sure they remain appropriate.

When sharing your personal information with our administrators or another third party we will make sure that they also have measures in place to protect it and keep it confidential and agree to use the personal information only for the purposes we set out.

We will keep your personal information for as long as we have a relationship with you or your survivors. When deciding how long to keep your personal information after our relationship with you and your survivors has ended, we take into account our legal obligations and regulators' expectations. We may also retain records to investigate or defend potential legal claims.

Your rights

You have rights regarding your personal information, including the right in certain circumstances to access, correct, delete or transfer your personal information or to restrict or object to our use of it. We may need extra information from you to deal with any request. If you would like to discuss or exercise these rights, please contact us.

International data transfer

Your personal information may be transferred to, stored, and processed in a country that is not regarded as ensuring an adequate level of protection for personal information under European Union law. Where your personal information is to be transferred outside the UK (for example by the administrator) we will make sure that there are appropriate safeguards in accordance with applicable legal requirements to protect the information. For more information on any safeguards in place, please contact us.

Changes to this policy

We may update this privacy notice from time to time. You will be able to see when we last updated the notice because we will include a revision date. Updates are effective from the date on which they are posted on the Scheme's website.

How to contact us

The Trustee is the "data controller" responsible for the collection and use of your personal information. If you have questions or concerns please contact the Head of Pensions by using the following contact details:

Phone: 0800 587 7877 (press 3 for pensions then 3 for general enquiry)

Email: pensions@theaa.com

Address: c/o Pensions Department, AA Developments Limited, Fanum House, Basing View, Basingstoke, Hampshire, RG21 4EA

If you believe that we have not resolved your concerns, you can complain to the Information Commissioner's Office at www.ico.org.uk

We encourage you to let us know if your personal information changes or if you think the information we hold about you is out of date.

1 Version 1.0 – adopted by the Trustee in September 2017

Aon Solutions UK Limited (and the Scheme Actuary - together "Aon") has been appointed to provide pensions advisory and calculation services that relate to your membership of the Scheme. In doing so Aon will use personal information about you, such as your name and contact details, information about your pension contributions, age of retirement, and in some limited circumstances information about your health (where this impacts your retirement age) in order to be able to provide these services. The purposes for which we use personal information will include management of the Scheme and your membership of it, funding the Scheme (i.e. helping to ensure that the funds within the Scheme are sufficient to cover the benefits from the Scheme), liability management (that is to say providing advice on the different ways benefits could be determined, and drawn, from the Scheme), scheme actuary duties (which include assessing individuals who are members of the Scheme and assessing how the make-up of the membership may affect the amounts payable and when they become payable so as to manage the Scheme appropriately), regulatory compliance, process and service improvement and benchmarking.

We may pass your personal information to third parties such as financial advisors and benefits providers, insurers, our affiliates and service providers and to certain regulatory bodies where legally required to do so. Depending on the circumstances, this may involve a transfer of data outside the UK and the European Economic Area to countries that have less robust data protection laws. Any such transfer will be made with appropriate safeguards in place.

More detail about Aon’s use of your personal information is set out in our full Privacy Notice. We recommend that you review this notice which is available online at http://www.aon.com/unitedkingdom/products-and-services/human-capital-consulting/aon-hewitt-actuarial-services-privacy-statement.jsp, or you can request a copy by contacting us, including reference to the Scheme name, at:

Data Protection Officer,
Aon Solutions UK Limited (Retirement and Investment UK),
PO Box 730,
Redhill,
RH1 9FH

Appendix 2

Just Group
Policyholder privacy notice (Buy-in)

Click here to read the Policyholder privacy notice (Buy-in).