PSPA Privacy Notice

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 2002 (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. 

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.

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. 

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 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

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
• 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.

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

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

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.

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

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

For information on how your information may be shared by the PSPA please refer to its Fair Processing Notice.

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

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

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

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

www.inforights.im

Telephone: +44 1624 693260

This Privacy Notice may change. We will not reduce your rights under this Privacy Notice without your consent. If any significant change is made to this Privacy Notice we will provide a prominent notice on this website so that you can review the updated Privacy Notice.  

The last privacy notice was updated in May 2018.