PSPA Privacy Notice

Your personal data

The Public Sector Pensions Authority (PSPA) is an independent Statutory Board responsible for the management and administration of public sector pension schemes in accordance in the regulations which govern the schemes.

We do not collect or ask you to provide your personal data over the internet via our website at www.pspa.im

The PSPA will use your information that you have given us or that which is provided to us by your employer, to administer and maintain your pension scheme record, and to calculate and process payments of your pension benefits to you and your dependants.

Your rights

to access and receive in a portable format, a copy of the information we hold about you
request your information be changed if you believe the personal data we hold about you is inaccurate or incomplete
in limited circumstances you will have the right (where the data is no longer needed for the purposes it was collected, where you have withdrawn consent and there is no other lawful basis on which we can continue to process it, you object to processing and there are no overriding legitimate grounds to continue, where the data has been unlawfully processed or where the data has to be erased for compliance with a legal obligation) to request that we erase the information we hold about you. As most of our processing is conducted in order for us to perform a public task and/or comply with a legal obligation, this right will not be available in most circumstances.
to seek to restrict processing of your data in the following circumstances:
i. The accuracy of the data is contested – for a period necessary to allow us to verify its accuracy
ii. The processing is unlawful and you request restriction instead of erasure
iii. We no longer need the data for the purposes it was collected, but you need it in connection with a legal claim
to object to our processing of data which is done on our predominant ground for processing – the exercise of our statutory/ regulatory functions. In this case, we will stop processing unless we can demonstrate compelling legitimate grounds for continuing the processing which override your interests.

Request a copy of your personal information

You can exercise your right to access your data either in writing or verbally, after we are in a position to satisfactory identify you. You can also complete a Subject Access Request form to request a copy of your information. The form tells you what you need to do and will prevent any potential delay.

We follow a procedure when we receive your request and will respond within 1 month. If you aren't happy with our response, you can ask for a review.

Contact us

If you have any queries, or want to request that we change or delete your information, contact the Data Protection Officer at: DPO-SOG@gov.im

Concerns about how we are using your information

If you have any concerns about the processing of your information, contact the Information Commissioner’s Office at:

First Floor,
Prospect House
Prospect Hill,
Douglas
Isle of Man
IM1 1ET

www.inforights.im

Telephone: +44 1624 693260.

Why we process your information

If the terms and conditions of your employment permit membership of a public sector pension scheme, your Employer will automatically enrol you in a scheme and tell the PSPA that you are a new member.

You can instruct your employer that you do not want to be in the scheme.

The PSPA uses your personal data in line with the rules set out in the Data Protection Act 2018 (General Data Protection Regulation (Isle of Man) Order 2018).

The PSPA collects and processes information, including personal, employment and financial data of scheme members, their dependents and beneficiaries in order to carry out its statutory functions as prescribed under the Public Sector Pensions Act 2011 and the schemes listed in Annex A.

Who collects your personal information

Your employer collects personal information from you when you start your employment or take up a contract.

If you want to benefit from a public sector pension and choose to remain in the scheme, your employer will share your personal information with us, so that we can create and maintain a membership record for you in the scheme.

Types of personal information being collected and shared with the PSPA

When you join the scheme, and regularly throughout your membership of the scheme, your employing authority or the body set up to provide payroll services for your employer will tell us which scheme you are in and the following personal information:

Information to identify you: Title, full name, address, date of birth, National Insurance Number, employer payroll reference number.

Information to identify your nominated beneficiaries including children.

Details of your employment: title of your post, name of your employer, starting date, leaving date.

For purposes of maintain accurate records and calculating entitlements: Your gender, employee and employer contributions, pensionable, superannauable and actual pay, the contracted service (hours), the hours your worked.

This information is derived from your employment and payroll record.

The legal basis the PSPA use to process your personal data

The PSPA will only process your personal data if a lawful basis exists. We rely on:

your consent – if we rely on your consent to process your data you may withdraw your consent at any time by contacting the PSPA’s Data Protection Officer
the need to meet its legal obligation in carrying out statutory government functions
the need to meet a request you have made for pension benefits information or a service
the need to prevent or investigate suspected or actual violations of law
the need to protect the public interest
the need to retain information for historical or archiving purposes by the Public Record Office under the Public Records Act 1999

How your personal information will be used

By law, we must process your information to be able to manage and administer your pension scheme membership and ultimately to calculate and provide you with a pension in accordance with the provisions of your scheme.

Depending on your circumstances, this could be to:

identify you and your membership status in the scheme
communicate with you
set up and maintain accurate scheme membership records
terminate your scheme membership
fulfil statutory requirements;
keep historical records of your annual pensionable service and pensionable pay for the purposes of producing:
- an annual benefit statement
- valuation of scheme assets and liabilities
reconcile contributions deducted by your employer
calculate entitlements, authorise the payment of pensions, other benefits and any other sums due on retirement and thereafter including injury benefits
calculate entitlements, authorise the payment of pensions and other benefits to spouses/partners and dependents on death of a pension scheme member
to process and remit benefits related to your scheme to any beneficiary, either appointed directly by you or not
calculating and paying refunds of contributions and providing services to support the purchasing of additional pension and years
calculating and paying the transfer of pension rights to and from other pension providers
maintaining facilities for Additional Voluntary Contributions for scheme members, as laid down in the schemes' regulations
prevent and detect fraud and errors
providing data for or preparing budget estimates of income and expenditure and monitoring actual payments against estimates
maintaining accounts of income and expenditure under the schemes
provide data for analytical purposes to aid the planning of sustainability improvements to the schemes
providing accurate information to other parts of the Government and to the schemes' actuaries for accounting and valuation purposes
providing Cash Equivalent Transfer Values for divorce purposes and the implementation of Pension Sharing on Divorce orders for which income is generated

Establish, exercise or defend legal rights in connection with actual or prospective legal proceedings, including as necessary for the purpose of obtaining legal advice.

Keeping your personal information

We will only keep your information for the minimum time necessary.

Your personal data and records will be deleted or anonymised on our files when you reach age 100 or 6 years after the death of you (or your beneficiary), whichever is the later.

PSPA Document Retention Policy Schedule

How we keep your information secure

The security and confidentiality of your information is very important to the PSPA.

We will ensure that:

Safeguards are in place to make sure personal data is kept securely;
Only hold your data on servers that are under the control of the Cabinet Office, Government Technology Services and within the jurisdiction of the Isle of Man;
Only authorised staff are able to view your data;
Maintain security of the systems which hold personal data in line with ISO27001 standard
Maintain security of the systems which hold personal paper based records in line with ISO9001

Who has access to your personal information

PSPA Staff who are employed in the administration of public sector schemes have access to your personal information.

PSPA Staff are required to declare the names of scheme members who are relations, friends or colleagues and do not have access to the records of these persons.

PSPA Board Members do not have access to your records.

Sharing your personal information

We may share your information with other organisations:

with or between other Government Departments, Boards and Offices in order to provide a pension scheme related service or information you have requested
with internal or external auditors to comply with statutory obligations for the audit of the PSPA;
the police or law enforcement agencies where there is a legal requirement to do so
to prevent and detect fraud and mistake
the courts, on production of a valid court order
With the Isle of Man Ombudsman or the PSPA's Lawyers in connection with Internal Dispute Resolution and or legal proceedings

The PSPA shares anonymised data for the purposes of:

scheme valuation and accounting purposes

Who we share your data with

The PSPA shares your personal data with other companies, organisations or individuals only when there is a legal requirement or regulatory function to do so (including complaints to the Isle of Man Pensions Ombudsman).

The PSPA will not sell to, or share, your personal data with any other companies, organisations or individuals

Your information will not be transferred outside the European Economic Area.

The information you provided will be managed as required by Data Protection law.

Public Record Office

Your personal data may be permanently retained for research use at the Isle of Man Public Record Office if the records containing your personal data are selected for permanent preservation under the Public Records Act 1999. The Isle of Man Public Record Office preserves records of Isle of Man public authorities that are of long-term historic and cultural value.

Access to and use of records at the Isle of Man Public Record Office is governed by legislation, in particular the Public Records Act 1999, the Public Records Order 2015 and the Freedom of Information Act 2015.

Some records are made available to the public for research use, whilst others are covered by access restrictions to ensure sensitive information that should be confidential for a period of time is protected. Where your personal data is included in records transferred to the Record Office, an assessment will be made of whether the records should be covered by an access restriction based on this legislation. Access restrictions will be applied to records as appropriate under this legislation to prevent unlawful access to your personal data. Your personal data will not be used by the Isle of Man Public Record Office for any automated decision making.

The Isle of Man Public Record Office is part of the Department for Enterprise and can be contacted at: public.records@gov.im, or

Unit 40A Spring Valley Industrial Estate,
Braddan,
Isle of Man,
IM2 2QS.

The Department for Enterprise Data Protection Officer can be contacted by e-mail at: DPO-DfE@gov.im

The choices you can make about your personal information

You can review your personal information and ensure it is accurate

Where possible we will provide you with access to the information we hold about you so that you can view this information and we can provide a means for you to have this information changed if it is not accurate.

Alternatively you can ask for information we hold about you to be amended by sending your request to the PSPA’s Data Protection Officer at – DPO-SOG@gov.im

To remove your personal information

Where possible we will provide you with access to the information we hold about you so that you can view this information and request that your information is deleted.

Alternatively, you can ask for information we hold about you to be deleted by sending your request to the PSPA Data Protection Officer at – DPO-SOG@gov.im

To ask if we hold personal information about you

You can ask to see what information we hold about you by submitting a Subject Access Request to the PSPA Data Protection Officer at – DPO-SOG@gov.im

Request a copy of your personal information

Complete a Subject Access Request form. The form tells you what you need to do.

To make a complaint

If you are unhappy with the way we deal with your personal information you can submit a complaint to the PSPA’s Data Protection Officer at DPO-SOG@gov.im, who will work with you to resolve any issues.

We follow a procedure when we receive your request and will respond within 1 month. If you are not happy with our response, you can ask for a review.

The contact details for the PSPA are:

Public Sector Pensions Authority
3rd Floor, Prospect House
27-29 Prospect Hill
Douglas
Isle of Man
IM1 1ET

The Data Protection Officer for the PSPA is: C/O Cabinet Office, Government Offices, Buck Road, Douglas, IM1 3PN.

Email: DPO-SOG@gov.im

Information Commissioner Office Contact Details:

First Floor, Prospect House
Prospect Hill
Douglas
Isle of Man
IM1 1ET