Data Protection

Data Protection Privacy Notice for the GSK pension plans

Who we are

GSK Pension Plans Trustee Limited is the trustee of the GSK Pension Fund, GSK Pension Scheme and the Glaxo Wellcome Contracted-out Money Purchase Scheme and is also (from 1 October 2023) the trustee of the SmithKline Beecham Pension Plan and the trustee of the SmithKline Beecham Senior Executive Pension Plan.

Within this privacy notice all of the pension plans noted above are collectively referred to as “the Schemes”.

Purpose

Looking after the personal information (known as “personal data”) that we hold for you and all members of the Schemes is very important to us. We hold certain personal data about Scheme members and, where applicable, their dependants and beneficiaries. Most of the information held about you and processed by the Trustee in running the Schemes is personal data – in other words, because we hold information from which you as an individual can be identified, that information is subject to certain protections.

For legal purposes, the Trustee is known as the “data controller”, as we decide the purposes for and the means by which the personal data we hold is processed. Some of the Trustee’s advisors are also data controllers e.g. the Schemes’ actuaries. You can access the Schemes’ actuaries’ privacy notices here:

What information we collect about you

Depending on the circumstances and the stage of your membership, we may hold some or all of the following information about you:

• your name and date of birth
• your gender
• your marital status
• your address and other contact details (e.g. telephone number and email address)
• your national insurance number
• details of your bank account (to pay benefits to you)
• details about your dependants and/or beneficiaries (including their names and possibly details of their gender)
• relevant employment information (including current and past salary information and employment dates)
• details about your pension benefits
• medical and other details about your health

Please note, the above is not an exhaustive list and in some cases, we may hold some other information about you. All the information we hold is in order to properly administer the Schemes and to calculate and pay benefits correctly.

How and why we use that information

The Trustee has a legitimate interest in holding and processing the above information about you as it is needed for us to properly administer the Schemes and to calculate and pay benefits. We also keep the above information to allow us to comply with our obligations towards members under the Schemes’ governing documents, as well as under relevant legislation. Your personal data will generally be collected directly from you or from your employer whilst you are an employee member of the Schemes.

Personal data relating to the Schemes is held on paper and on computer systems. As the “data controller”, the Trustee must process this information fairly and lawfully.

As part of running the Schemes, we may also need to hold and process particularly sensitive information about you and/or your dependants and beneficiaries (known as “Special Categories of Personal Data” (previously referred to as “sensitive personal data”)). Under the legislation, details relating to health, racial or ethnic origin, religious or other similar beliefs, sexual orientation and political affiliations are regarded as “Special Categories of Personal Data”. Except where the legislation allows it, this information cannot be processed or passed to a third party without your explicit consent.

What else we might do with personal data

Although the Schemes are based in the UK, your personal data may be shared outside of the United Kingdom (“UK”), or the European Economic Area (“EEA”). For example, if a Scheme provider performs part of its services outside of the UK or EEA, or you live outside the UK or EEA, or want to transfer your benefits abroad. However, personal data will only be shared outside of the UK or EEA where appropriate safeguards are in place in accordance with data protection law. In those cases, such transfers would generally be made based on the European Commission’s standard contractual clauses or, where relevant, the UK standard contractual clauses. Copies of the EU standard contractual clauses can be found on the European Commission’s website and copies of the UK standard contractual clauses can be found on the Information Commissioner's Office website.

Who we share it with

To properly administer the Schemes, we may share your personal data with third parties, including the Schemes’ advisors as follows:

• GSK’s in-house pension management teams
• the Trustee’s professional advisers, including the Scheme actuary, auditor, investment adviser and lawyers
• the third parties who are responsible for the day-to-day administration of the Schemes
• HM Revenue & Customs and other statutory bodies (such as the Pensions Ombudsman and the Pensions Regulator) – the Trustee can be fined and subject to other action if it fails to provide certain information to these authorities
• the external printers who help us issue various communications we send to you, such as the summary Trustee Report
• our appointed insurance company or companies for the purposes of life insurance and additional voluntary contributions (where applicable)
• depending upon how we pay pensions, the personal data we have to supply in order to efiect a BACS transfer (the Bankers’ Automated Clearing Service), or CHAPS (the Clearing House Automated Payment System in the UK), or a payment via Citibank or Western Union (the administrators’ banking providers when pensions are being paid overseas)
• tracing agencies e.g. if we were to lose contact with you

We may also share personal data with:

• your current, past or future employer which may include group companies which are based outside the UK or EEA (as applicable), where the employer has a legitimate interest in processing the personal data. Where data is sent outside the UK or EEA (as applicable), appropriate safeguards are put in place to ensure that your data is kept secure
• such other third parties as we may from time to time engage for the purposes of the proper and efficient management of the Schemes and their liabilities
• where applicable for eligible pensioners, the Retired Staff Association

How long we keep personal data for

We must keep all personal data safe and only hold it for as long as necessary. To be able to appropriately administer the Schemes and pay benefits correctly in the future, we may be required to keep some of your personal information for the rest of your life (and possibly longer to help us pay any death benefits).

Your rights

• Right of access – you have the right to see personal data that is held about you and a right to have a copy provided to you, or someone else on your behalf, in a machine readable (namely, digital) format
• Right to rectification – if at any point you believe that the personal data we hold about you is inaccurate, you can ask to have it corrected
• Right to restrict processing – you can require the Trustee to restrict/limit the processing of your personal data in certain circumstances, for example, whilst a complaint about its accuracy is being resolved
• Right to object to processing – as we are relying on legitimate interests as a reason for processing, you can object to your personal data being processed, although the Trustee can override this objection in certain circumstances
• Withdrawing consent – where you have given us your consent to processing your personal data, you can withdraw that consent at any time by notifying us (see “Who to contact about your personal” below). However, withdrawing your consent will not affect the processing of any personal data which took place beforehand and it may be possible for the Trustee to continue processing your personal data where this is justified
• Right to be forgotten – you can request that your personal data is deleted altogether, although the Trustee can override this request in certain circumstances

Who to contact about your personal data

If you wish to see your personal data or to exercise any of the rights mentioned above, please contact your appropriate Scheme administrator.

If you wish to make a complaint

If you wish to make a complaint about how we have handled your personal data, please contact the Secretary to the Trustees, Floor CN7, GSK House, 980 Great West Road, Brentford, Middlesex, TW8 9GS.

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 (www.ico.org.uk) whose helpline number is: 0303 123 1113.

Updates to this notice

This notice is the latest version as at 16 October 2023. This notice will be updated from time to time and you can see the current version at any time on www.gskpensions.co.uk/dataprotection. If you would prefer to receive a hard copy of the notice, please contact your Scheme administrator (see “Who to contact about your personal data” above).

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